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Pharmaceutical pros elaborate on packaging concerns

Survey respondents vent views on repackaging, paying more for equipment that’s easy to validate, and changes related to FDA’s 21 CFR, Part II.

To find out what issues most concerned pharmaceutical packagers, Packaging World conducted an exclusive mid-April survey on its Packworld.com Web site among a sampling of pharmaceutical readers. Those issues were reported in June (see packworld.com/go/c076).

In this article, survey respondents elaborate on the pros and cons of repackaging, whether their company pays more for equipment that’s easy to validate, and changes in packaging policies related to the Food and Drug Administration’s Title 21 Code of Federal Regulations Part 11, concerning electronic records and electronic signatures. (For more information on 21 CFR Part 11, visit www.fda.gov/ora/compliance_ref/part11.)

Although many respondents indicated their firms would meet FDA requirements, several others noted that the FDA draft guidance would necessitate changes. “It is affecting our procedures greatly. We are implementing lots of procedural changes that result in [the need for] training,” said an engineer with a large northeastern manufacturer and marketer of medical products and pharmaceuticals.

“We have training classes outlined for the time when that does happen, which I’m sure will be in the not-too-distant future,” added a research and development representative with a mid-sized company in the Midwest that provides services to the pharmaceutical, biotechnology, and healthcare industries.

Another R&D respondent, this time in the Northeast, noted “the company view is that complete instrument control and data storage systems may have to be replaced if they can’t be upgraded to be compliant. Also, instrument audit trails will become more strict. Specific productivity on a particular piece of equipment is likely to be somewhat reduced by the enhanced security activities and archiving requirements.” It should be noted that this respondent admitted that he “was not close to packaging in particular.”

Another large company in the Midwest had “new computer systems being phased in and validated to comply with the guidance,” according to a company R&D professional. “Electronic signatures are still not implemented.”

Although no changes were being implemented this year at another large midwestern pharmaceutical company, a quality assurance officer for the firm noted that “corporate is seriously investigating an electronic batch record system to reduce documentation errors and to improve system controls.”

Other survey respondents indicated that their firms were either in compliance with the requirements or that no changes were necessary. Not surprisingly, some professionals voiced uncertainty about the proposed FDA guidelines. A quality assurance person with a smaller firm in the Southeast explained: “We are trying to move toward 21 CFR Part 11 compliance, but ... we are unsure as to what needs to be done. We still use hard copy for most of our Good Manufacturing Practices records.”

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