Food Safety Assessment - American Chemical Society

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Chapter 12 Good Laboratory Practice Regulations The Need for Compliance W. M. Busey and P. Runge

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Experimental Pathology Laboratories, Inc., P.O. Box 474, Herndon, VA 22070

Historical Perspective - A Brief Overview Through the Federal Food, Drug, and Cosmetic Act, the government has placed the responsibility of establishing the safety of regulated products with the sponsors of those products, and has made the Food and Drug Administration responsible for reviewing their efforts and determining if, in fact, safety has been established. Prior to the promulgation of the Good Laboratory Practice (GLP) Regulations, the agency operated on the premise that reports submitted in support of these products were accurate representations of study conduct and results. However, inspection of several studies conducted for a major pharmaceutical manufacturer revealed unacceptable or questionable laboratory practices and inconsistencies in data (1). Major concerns included: 1. Poorly designed and conducted experiments, inaccurately analyzed or reported. 2. Technical personnel unaware of importance of adherence to protocol requirements, accurate administration of test materials, accurate recordkeeping. 3. Management did not assure critical review of data, proper supervision of personnel. 4. Studies impaired by protocol designs that did not allow for evaluation of all data. 5. Inadequate assurance of scientific qualifications and training of study personnel. 6. Disregardforproper laboratory, animal care, and data management procedures. 7. Failure of sponsors to adequately monitor studies/procedures conducted by contract laboratory facilities. 8. Failure to verify accuracy and completeness of reports prior to submission to FDA. Further investigations of the laboratory facilities involved resulted in eventual convictions on criminal charges of fraud and a great concern for the validity of studies 0097-6156/92/0484-0114$06.00/0 © 1992 American Chemical Society Finley et al.; Food Safety Assessment ACS Symposium Series; American Chemical Society: Washington, DC, 1992.

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already completed. The need for better control of nonclinical laboratory studies was soon recognized by both government and industry. In response to this need, the F D A pursued numerous possible approaches to more controlled and consistent study conduct. After much investigation, review, consider­ ation, and comment the F D A Good Laboratory Practice Regulations were eventually codified as Part 58, Chapter 21 of the Code of Federal Regulations. A l l regulated human and veterinary drugs and devices and food/color additives must comply with their directives.

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Purpose and Content of the Good Laboratory Practice Regulations The primary purpose of the G L P Regulations is to assure the quality and integrity of the studies submitted in support of the safety of regulated products. In order to accomplish this, many "common sense" requirements were incorporated into the regulations. These included provisions for criteria of study design, i.e., protocols and standard procedures; facility and equipment considerations; identification and control of test materials; recordkeeping; and reporting. These requirements reflect the demand for basic experimental structure necessary for conducting any high quality, scientifically sound study; however, the regulations have gone beyond those basics by requiring certain additional securities, primary among them the need for each study to have a study director, who assumes overall responsibility for a given study, and a quality assurance unit responsible for monitoring study conduct, the test facility, and reporting of results (2). The regulations have been divided into several subparts, each dealing with a specific aspect of study conduct. Brief descriptions of each subpart follow (3). General Provisions (Subpart A). This section identifies what products are regulated [58.1], and defines various terms prevalent in the conduct of nonclinical studies [58.2]. These include such terms as "The Act," i.e., the aforementioned Federal Food, Drug, and Cosmetic Act; test and control articles; nonclinical laboratory study; sponsor; testing facility; test system; raw data; specimen; quality assurance unit; study director; study initiation and completion dates; and types of submission applications. The section also addresses services contracted by the testing facility, and inspections by agency personnel. Organization and Personnel (Subpart B). Subpart Β has been designed to define the responsibilities of management, the study director, and the quality assurance unit as they relate to facility operation and conduct of nonclinical laboratory studies. The regulations are specific as to organizational relationships and responsibilities. Management [58.31] has the responsibility for providing qualified and appropri­ ately trained study personnel, assignment of the study director, providing adequate resources, and support of the quality assurance unit by its policies and directives. The study director [58.33] has the overall responsibility for a given nonclinical laboratory study, and serves as the single point of control for all aspects of that study.

Finley et al.; Food Safety Assessment ACS Symposium Series; American Chemical Society: Washington, DC, 1992.

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The quality assurance unit [58.35] is responsible for "monitoring each study to assure management that the facilities, equipment, personnel, methods, practices, records, and controls are in conformance" with the applicable regulations. Among its many responsibilities are maintenance of the facility master schedule, maintenance of all study protocols, periodic inspections of ongoing studies, reporting of inspection findings to management, review of the final study report, and preparation and release of the inspection statement required by the regulations.

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Facilities (Subpart C). Requirements for animal care and supply and test and control material facilities are addressed by this section. Additionally, requirements for adequate laboratory operation areas and specimen and data storage (i.e., archives) are addressed. Equipment (Subpart D). This section requires that equipment appropriate to the task be used for any given procedure, and provides for the periodic maintenance, calibration, standardization, cleaning, and/or inspection of that equipment. Specific standard operating procedures defining these activities and related remedial actions are a primary directive, as is the required recordkeeping of all such procedures. Testing Facility Operation (Subpart E). Standard operating procédures» reagent and solution identification, and animal care requirements are addressed in this section. Standard operating procedures must be established for all routin laboratory operations; specifics are identified by the regulation [58.81(b)]. This regulation also provides for changes to established standard operating procedures and availability of those procedures to laboratory personnel. Reagent and solution identification requirements are outlined, as are the requirements for dating of reagents. Animal care requirements reflect basic directives for the receipt, isolation, housing, maintenance, and feeding of laboratory animals used in nonclinical laboratory studies. These regulations supplement those established by the various animal welfare regulations. Test and Control Article Handling (Subpart F). Subpart F addresses a key area in the conduct of a nonclinical laboratory study in that it provides directive for the characterization and identification of test and control materials, the handling and custody of these materials, and determination of homogeneity and stability of test mixtures. Protocol and Conduct of a Nonclinical Laboratory Study (Subpart G). A primary concern of any experiment is the procedure by which that experiment will be conducted. Subpart G addresses that concern by defining the requirements for the study protocol, that is, the written document that defines the objectives and establishes the procedures to be performed to meet that objective. It must be remembered that the protocol is directive, not documentation. Adherence to the protocol directive is confirmed through the documentation of the conduct of the study. Recordkeeping

Finley et al.; Food Safety Assessment ACS Symposium Series; American Chemical Society: Washington, DC, 1992.

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requirements are also defined by this section, and provide for the consistent recording of results and data so that, if need be, the study can be literally recreated from its documentation. Records and Results (Subpart J). Among the most important facets used to support the safety of a regulated product are the final reports produced for the myriad of studies required to establish that safety. Subpart J identifies what information must be addressed in those reports, and how the related data and materials must be retained. It is essential that the final report provide an accurate reflection of the method and procedures employed and of the raw data resulting from the study. In order that sponsor and regulatory review may be accomplished efficiently and in a timely fashion, it is essential that data records and residual materials be retained in an organized and easily retrievable manner. Disqualification (Subpart K). The F D A ' s power to enforce the G L P regulations is supported by its power to disqualify a testing facility. Such action is not taken without due consideration, and may only be invoked if all three criteria for disqualification as defined by the regulations are present [58.202]. These include: (1) that the facility failed to comply with one or more of the regulations defined in 21CFR 58; (2) that the noncompliance adversely affected the validity of the study(ies); and (3) that lesser actions, such as warnings or rejection of individual studies, had not or would probably not be adequate to achieve compliance. Compliance. Compliance with the G L P regulations is not as easy as it looks, nor is it as difficult as it can be made. It has been noted that "compliance" appears right before "complicated" in the dictionary, but compliance need not be complicated if approached in a common-sense, standardized manner. There are numerous ways by which compliance in a study or a testing facility can be established. However, all involve a thorough and complete understanding of the final objectives. In establishing guidelines for compliance, certain aspects of nonclinical laboratory testing must be considered. Some will necessarily be tailored to the needs of specific situations, but the general considerations should include at least the following: 1. In order to effect the most complete protocol for a study or procedure, full awareness and understanding of regulatory and testing requirements are essential. 2. Standard operating or study-specific procedures should be developed before they are needed and should be reviewed periodically to insure continued compliance with the appropriate regulations. Procedures should be updated and revised promptly. 3. Ensure that all technical personnel are knowledgeable of and properly trained in the procedures they will be required to perform, and that they are aware of how their performance may affect subsequent aspects of the study.

Finley et al.; Food Safety Assessment ACS Symposium Series; American Chemical Society: Washington, DC, 1992.

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4. Anticipate potential problems and concerns and be ready with possible resolutions. 5. Acknowledge unforeseen circumstances or deviations from protocol and/or standard operating procedures with prompt and appropriate documentation. 6. Stress the importance of timely and accurate recordkeeping for all aspects of the study. 7. Periodic review of study conduct and data, not only by the study director and quality assurance unit, but by the operating area's internal quality control mechanisms. 8. Communication between the laboratory, the study director, and quality assurance unit should be continuous, not just limited to Q A inspections. The GLP's may define what is needed for compliance, but they cannot guarantee it. That is the joint responsibility of the study director, management, and the quality assurance unit. Neither can fulfill their respective responsibilities towards compliance without the full support of its partners. These relationships should not be viewed as antagonistic, but as supportive. In reality, such relationships are often hard to achieve and maintain given the complexities of the industry. However, the benefits of a cooperative and supportive relationship greatly outweigh the efforts that must continually be expended to create and maintain such a relationship. It is ultimately on the strength of this relationship that compliance is based. Conclusions - Where Do We Go From Here? As the industry has matured and developed within the regulatory structure, the concerns of the past have diminished but by no means disappeared. The majority of recent inspections by the F D A have been classified as "No Action Indicated," " V A I 1," or " V A I 2" (voluntary action classifications); this reflects the favorable attitude of industry towards maintaining compliance. However, deviations from the G L P Regulations were still present, with the most significant departures being (4): 1. Discrepancies between the final report and raw data. 2. Improper corrections/changes to raw data. 3. Implementation of protocol revisions without proper amendments to the approved protocol. 4. Lack of appropriate standard operating procedures and/or failure to revise SOPs when needed. 5. Incomplete information on facility master schedules and study protocols. Inspectors found archiving and record retention procedures, animal care facilities, and laboratory operations generally in compliance with the regulatory requirements. This is encouraging, since it may be recalled that some of the major concerns that precipitated the G L P ' s involved these areas. The findings cited, however, appear to indicate there is an industry-wide need for tighter control over the "paper" aspects of the nonclinical laboratory study.

Finley et al.; Food Safety Assessment ACS Symposium Series; American Chemical Society: Washington, DC, 1992.

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The GLP's have given the industry the means by which high quality, consistent, and reproducible studies can be conducted; however, the industry cannot comply with those directives without a continued commitment to compliance. Findings from recent G L P inspections indicate that the advantages of these regulations continue to be valid, and that the industry must not only maintain but increase its commitment to compliance. Despite our shortcomings, we have made significant inroads to the goal of "total compliance" set by the FDA; with continued commitment, we as an industry can meet this objective.

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Literature Cited 1. Good Laboratory Practice Regulations; Proposed Rule, Department of Health, Education, and Welfare, Food and Drug Administration, 21 CFR 3e, Federal Register, Vol. 41, No. 225, pp 51206-51209. 2. Taylor, J.M. In Good Laboratory Practice Regulations; Hirsch, Α., Ed.; Marcel Dekker, Inc.: New York, 1989, pp 6-8. 3. Good Laboratory Practice Regulations; Final Rule, Department of Health and Human Services, Food and Drug Administration, 21 C F R Part 58, Federal Register, Vol. 43, No. 247, pp 59986-60020. 4. James, G.W. In Good Laboratory Practice Regulations; Hirsch, Α., Ed.; Marcel Dekker, Inc.: New York, 1989, pp 210-212. RECEIVED August 15, 1991

Finley et al.; Food Safety Assessment ACS Symposium Series; American Chemical Society: Washington, DC, 1992.