On Pharma

August 31, 2006

Are Pharma IT Departments Clueless on What Manufacturing and R&D Need?

Filed under: Miscellany — pharmamanufacturing @ 12:44 p.08.

Pharma IT departments are staffed by some exceptionally smart people.  But do all of them really know what their end users need?

An article on Napp Pharmaceutical made me wonder.  The company has reportedly “rethought” its IT infrastructure, for the second time.  In twelve years, Napp has apparently moved from from an old Honeywell system, to a “best of breed” blend of Oracle, i2 Rhythm, and Consilium MES, and is now moving back to a large, integrated platform: Oracle’s e-Business suite, according the article, “Napp Pharmaceutical Ousts Best-of-Breed” —-only a software magazine could get away with a headline like that—in Manufacturing Computer Solutions’ July/August issue. (To download the U.K. journal’s article, click here).

The article makes the point that “monolithic IT” is making a comeback, and triumphing over mix and match or “best of breed.” (Now there’s a word that  I wish someone would eliminate from the English language entirely).

But the article singles out problems with previous systems, mentioning “database synchronization” pointedly.

When these issues come out, do they indicate a problem with the software, or with the IT staff, who, perhaps, couldn’t figure out how to link the different software platforms and, perhaps, didn’t understand what the manufacturing folks really needed in the first place, when they set out implementing the IT?

Data synchronization problems seem to be a common theme for many drug manufacturers.  Could they also be the reason why so many companies fail to achieve all they can from operational excellence and PAT programs?

Could IT and manufacturing be brought closer together, to ensure that the right IT is selected, the first time?

 Do you have any horror stories (or anecdotes of the opposite sort) to tell?

-AMS

August 30, 2006

Schering-Plough to pay $435 million, pleads guilty to charge of selling drugs for unapproved uses, overcharging Medicaid

Filed under: Miscellany — pharmamanufacturing @ 12:44 p.08.

The company has just agreed to pay a massive settlement for unapproved marketing and sales.

-AMS

August 25, 2006

Absorptive capacity:does progressive R&D lead to better product development?

Filed under: Miscellany — pharmamanufacturing @ 12:44 p.08.

Do companies that work on forward-thinking R&D projects make better products that offer them a competitive advantage?  This working paper by Harvard Business School professor Daniel Snow proposes that R&D innovators are much better at incorporating elements from their R&D into current product development. 

He focuses on automobile actuators and EPA emissions standards.  Are there any lessons here for pharmaceutical process development?

August 24, 2006

Ciurczak’s Response on PAT, Potato Chips and Dissolution Testing

Filed under: Miscellany, Process Analytical Technology, The Pharma Industry — pharmamanufacturing @ 12:44 p.08.

Emil Ciurczak responds to Frank Sistare’s comments on his article. Any comments, anyone?

“…I am “cautious” only in that I do not want people to think that PAT is easy or cheap to make work. My early (and current) experiences with NIR are that the salesmen ONLY discuss the application of NIR (fast, simple to operate, nondestructive) and gloss over the (possibly) months to a year of development and validation required for a method to be ready for “prime time.” This could slow PAT development and innovation in the pharmaceutical manufacturing environment.

When any method in a compendial journal (USP, EP, etc.) has troubles, it will show up as trouble. That is, an interference in, say, a Karl Fischer titration will give pretty radical results. A dissolution will show the release rate, no matter what is causing it.

With an NIR prediction, however, you CANNOT possibly a priori know everthing that will change over the lifetime of a product’s manufature. Since everything affects an NIR spectrum, you could potentially fail a good product or pass a bad product, based on an equation built without a new change having been accounted for. It is difficult to fool NIR for a specific analyte, but, considering the complexity of diffuse reflection/transmission (for which no theoretical explanation has been seen, to date), many things could give a false reading.
      

I just completed teaching another 3-day NIR course and some of these things were addressed. I have been doing dissolution predictions since 1989 and have seen as many bogus examples as successful ones. NO equation is static; all predictive methods must be routinely challanged.

Do I think that we should trust NIR? Of course. Do we trust our kids? Of course; but we have them phone us and tell us where they are and when they’re coming home, anyway.

PAT is a TOOL. It is boundless. And it is limited by our imagination. But, will we ever throw away the compendial methods upon which we built PAT? I think the jury is still out on that. I think PAT is inevitable and will be the only means American (and other large) Pharma houses can stave off low cost products from developing countries and the threat of government price controls. It is smart, logical, and will result in better products…”

-AMS
 

Paper and 21st Century Recordkeeping: FDA, Practice What You Preach

Filed under: FDA and Regulatory Issues, Miscellany, The Pharma Industry — pharmamanufacturing @ 12:44 p.08.

FDA has announced a proposed rule for developing an electronic list of all the drugs marketed in the U.S. , as well as an electronic registration system.

Was surprised that this didn’t already exist.  For more information, read on.

 But clearly FDA is “walking the talk” about modernizing its processes.  What took them so long on this point, though, one wonders? And how long will it take for this to move from being a “proposed rule” to an actual rule?

-AMS

Approved vs. unapproved drugs: Most pharmacists unaware of the distinction

Filed under: Drug and Supply Chain Security, FDA and Regulatory Issues, Miscellany, The Pharma Industry — pharmamanufacturing @ 12:44 p.08.

This just in….

National Survey Shows 91% of U.S. Pharmacists Unaware They Dispense Unapproved Prescription Drugs 
    RALEIGH, N.C., Aug. 23 /PRNewswire/ — Medical Marketing Research, Inc.
today announced the results of a nationwide, random-sample survey of 500
U.S. retail pharmacists concerning their dispensing habits for
pharmaceutical products. This survey was designed to specifically measure
pharmacists’ awareness that they may be dispensing products that have never
undergone the Food and Drug Administration (FDA) approval process.

One of the most surprising findings was that 91% of retail pharmacists surveyed
believed that all medication available for dispensing with a doctor’s
prescription had been FDA approved. In fact, the FDA estimates that, in the
United States, as many as several thousand drug products are marketed
illegally, without required FDA approval(i).
    The survey, commissioned by Mutual Pharmaceutical Company/AR
Scientific, was carried out between July 7 and July 17, 2006.
    Additional findings addressed the understanding by pharmacists of a
specific unapproved product — quinine sulfate. Quinine sulfate is a
widely- used treatment for malaria. Although the first FDA-approved
formulation of quinine sulfate just came onto the market in July 2006,
pharmacists continue dispensing formulations that have never undergone FDA
evaluation.
    In addition:

    –  89% of pharmacists surveyed believe that all of the quinine sulfate
        products they dispense are FDA approved

    –  33% of pharmacists either do not know or do not believe that quinine
        sulfate has adverse events related to blood levels

    –  31% of pharmacists either do not know or do not believe that quinine
        sulfate has a specific, potentially life-threatening side effect of
        QT prolongation

    –  36% of pharmacists do not know that the FDA specifically states that
        accumulation of quinine places the elderly at greater risk of adverse
        events
    For more information about this survey, please contact Dan Budwick, BMC
Communications, 212.477.9007 ext. 14.

Michael Moore’s Sicko to be filmed…in Canada

Filed under: Miscellany, The Pharma Industry — pharmamanufacturing @ 12:44 p.08.

After a long period of silence, we’ve heard that filming of M.M’s much anticipated film will begin… in London, Ontario. What better place to film a documentary about U.S. healthcare practices?  (He could have a field day documenting problems with Canada’s healthcare system.  How many physicians have I met in the U.S., who fled that system in horror?)

Sneak peeks will be given at the upcoming Toronto Film Festival…

Advertising Age says your companies are all scared silly about Michael and the movie.  WHY?  It could be an opportunity, no?  Just tape your interview and show what ended up on the cutting room floor.

-AMS

Peter Rost has a new book out

Filed under: Miscellany — pharmamanufacturing @ 12:44 p.08.

It’s coming out in September.  Here’s a link to an ordering page on Amazon. (Never heard of the publisher, Soft Skull Press, and noticed that they’ve already reduced its price. But it’s tough to get anything published and distributed, today…and so few people under a certain age even buy books anymore) Should be an interesting read.

-AMS

Controlling drug counterfeiting: The ball’s in industry’s court

Filed under: Drug and Supply Chain Security, FDA and Regulatory Issues, Miscellany, The Pharma Industry — pharmamanufacturing @ 12:44 p.08.

Just read the American Council on Science and Health’s (ACSH) report on Counterfeit Drugs. 

[First a brief digression on ACSH: There is a great deal of pseudo-science out there today, so the group's professed intentions of de-bunking pseudo-science are extremely worthy.  But, despite the heavyweight credentials of ACSH's advisory board, I tend to take anything that the organization says with a very large grain of salt. Its pronouncements are almost always biased toward industry.

I recall a conference in the late 1980s where a representative of that organization, along with someone from a very large specialty chemical company, completely discounted Love Canal and Times Beach. 

I walked out of the press conference, when I really wanted to ask them "If you believe that the exposure risks are so minimal, and exaggerated by the press, would you please agree to go and live for one year in each of those towns, with your families, and document what happens?"]

ACSH’s report aims to warn the public about the dangers of counterfeit drugs. This is a worthy aim,  considering that so many people are still buying medicines from unlicensed online pharmacies.

There were no new or startling revelations in this report.  Like all the other reports on this subject, it just trotted out the same old statistics and the same stale and incomplete data.

It calls for stronger penalties for counterfeiting, an excellent suggestion. (India has already gone as far as any nation could go on that front, and voted to punish the crime with death. ) 

ACSH’s report also called for increasing security features and developing electronic track and trace capability.  Another excellent point, and some drug suppliers an manufacturers are on their way to having this type of infrastructure in place.

But it also calls for “reduced corruption,” a nebulous goal that could come from a Miss America “what would you do to change the world” speech, “a crackdown on counterfeiting operations in nations where it is prevalent” as well as “adequate regulatory and quality control regimes in developing countries.”  How to achieve these goals was not even addressed, because these are huge problems.  And they can only be solved by the drug industry itself.

Some developing nations such as Nigeria are doing all they can to build enforcement and quality systems. Dora Akunyili, head of Nigeria’s FDA, has put her life on the line to achieve these goals.  But, realistically, it will take decades before all developing nations where counterfeiting is rampant can be expected to have firm quality control regulations in place. It took the U.S. 100 years, didn’t it, to create the FDA that we have in place today?

Instead of pointing the finger at those “developing nations,” couldn’t ACSH have addressed the real problem: the industry’s reluctance to let any word of a counterfeiting incident out, because it might be leaked to the press? 

 Drug companies already have direct connections with FDA’s anticounterfeiting team. They should also have them internationally with local law enforcement, and some of them do.

But if local authorities can’t always be trusted, drug firms should also have connections with international law enforcement.

WIth a few notable exceptions, it’s drug companies that seem to be holding up progress on the global anticounterfeiting front.  Concerns about news leaks and decreased shareholder confidence are very real, but there is also a need for greater accountability to the public.

For a position paper coauthored by someone who’s actually on the front lines fighting the counterfeiting menace (Dr. Akunyili) , click here.

i believe reporting should be mandatory, and international. But I doubt that  will happen any time soon.

-AMS

The latest solution to the medication errors problem: Rex, the talking prescription bottle

Filed under: Drug and Supply Chain Security, Miscellany, The Pharma Industry — pharmamanufacturing @ 12:44 p.08.

And I kid you not.  One company has developed a talking prescription bottle designed to prevent medication errors among blind patients.  The skeptic in me can’t help but wonder whether a product like this could ever be 100% “bug free.” Can’t imagine a more user friendly solution. For a quick look at a video showing how it works, click here.

-AMS

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