Both OTCs and prescription drugs are subject to the same modern challenges of a globalized industry, including supply chain management/security and the need for rigorous quality control, as active ingredients and finished products increasingly are manufactured outside the US. Both types of medications also are subject to the same consumer expectations for specified efficacy, safety, and quality. This is a point made by Dr. Janet Woodcock, director of FDA's Center for Drug Evaluation and Research (CDER), at a USP workshop on OTC quality held in September. Dr. Woodcock noted that while the FDA OTC monograph system has served all parties well for decades, a serious quality problem could be "catastrophic," not only for consumers but for the system itself. Patient harm is rare and we need to keep it that way, Dr. Woodcock noted.
Drug quality is protected through interwoven, critically important safety nets: a strong regulatory body; ethical manufacturers; and the existence of, and adherence to, private and public standards that help assure the identity, strength, quality, and purity of medicines and their ingredients. Public standards in USP–NF are legally recognized under the Food, Drug, and Cosmetics Act, and manufacturers are required to adhere to them. USP is not an enforcing body—it only creates the standards—but FDA is, and may enforce USP's quality standards. Additionally, USP–NF standards are closely connected in law with GMP standards for drugs.The challenge for FDA, USP, and OTC manufacturers—and for consumers—is that standards can get out of date, and this may be particularly true for OTC products where the offerings continually change. This is also true of the approximately 240 drug substances that may be used in OTC monograph products, most of which are older ingredients made by multiple manufacturers. And it can be true as well for prescription medicines that are more closely regulated.
At the September USP workshop, Dr. Scott Furness, director of the Division of Nonprescription Regulation Development at FDA, explained the agency's concerns in more detail, noting that because FDA OTC monograph drugs undergo no pre-market approval, no individual assessment of quality is performed for those drug products also having a USP monograph. Manufacturers assess quality through conformance to the monographs in USP–NF—making the USP monograph even more critical. Furness emphasized that OTC monograph drug products cannot afford to lag behind the quality regulatory standards required for prescription drugs. He also said that one cannot have a safe product that is not also a quality product—the two "go hand in hand." Furness indicated that this is not just a "theoretical concern;" FDA has found OTC products with high levels of impurities that would not be acceptable in a prescription drug.
Together, FDA, USP, and industry are working to modernize USP's monograph standards. There are many benefits here, including: strengthening public standards, increasing consistency of monographs, moving from non-specific to specific procedures, and helping to guard against economically motivated adulteration. Practical benefits for industry include removing non-value-added tests and requirements for hard-to-find, outdated equipment. Because USP standards are used by all manufacturers marketing products in the US, they create a level playing field for the ultimate protection of the consumer.
Under an FDA Modernization Task Force formed in 2010, FDA is assisting USP in prioritizing standards for modernization, using a scientific and risk-based approach. This effort is coupled with USP's own criteria for when a monograph needs updating. In 2011, FDA provided USP with an initial list of OTC priorities, focusing first on acetaminophen and diphenhydramine, as well as a number of inactive ingredients. Acetaminophen drug products rise in concern because of widespread use and lack of control of an impurity (p-aminophenol) potentially damaging to kidneys. FDA later provided USP with a second group of drug substances, some of which are used in OTC monograph products. USP has begun work on updating these standards, along with many others previously identified by USP.