Let it be said that the spark that ignited the flame was when FDA leadership asked, â€œDo we know enough about the quality of drugs that are sold in the United States.â€
In 2009, the FDA announced its Safe Use of Drugs Initiative.Â The theory being that one way to make drugs safer is to ensure that they are used as directed. The main strategy was education and the agencyâ€™s efforts were (and are) aimed at physicians, nurses, pharmacists, and patients.
Earlier this year, the agency announced not just an office, but a Super Office of Pharmaceutical Quality, further underscoring that the FDA operates not under a two-dimensional system of safety and efficacy, but a three-dimensional approach that includes quality â€¦ with a capital (indeed a â€œsuperâ€) Q.
Since there is no such thing as a safe substandard product, the agency is putting time, resources, and the use of the bully pulpit to go beyond cGMPs, API and excipient sourcing to develop a risk-based approach that includes data gathered from a variety of sources including manufacturing inspections, adverse event reporting, and substandard pharmaceutical events as evidenced in the agencyâ€™s bioequivalence- driven actions with bupropion in 2012, metoprolol in 2014, and methylphenidate in 2015.
So, in many respects, pharmaceutical quality is both a pre and post-licensure endeavor and, like Safe Use, a scientific and educational enterprise that requires close coordination with many stakeholders. And it wonâ€™t come easily or inexpensively. As Aristotle said that, â€œQuality is not an act, it is a habit.â€
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