Animal Pharmaceuticals Supply Chain Interruptions

Animal Pharmaceutical Supply Chain InterruptionsJ. GreenwaldSeptember 26, 20191

Why Care? Current Status in the US Supply Chain Disruptions versus ShortagesBackground Information From Human Health Drug Supply Interruptions are Not New FDA Efforts to Prevent/Mitigate Human Drug Shortages Industry Perspective ToolsConclusions2OVERVIEWIntroduction

VETERINARY DRUG INTERRUPTIONS:WHY CARE?Note - human drug shortagesaffect veterinarians and animalstoo!AnimalsVeterinariansmay suffermay struggle to provide safe and effective care in atimely mannerAnimal Producers may have lossesPet Ownersmay experience emotional and financial stressRegulatorsmay face difficult choicesmay lose revenue, market share, and reputation3Manufacturers

US VETERINARY DRUG SHORTAGES13 Current DrugReasons for Current Drug ShortagesDemandIncrease8%Shortages on CVM’swebsiteDiscontinuance15%12 resolved DrugManufacturingDelay77%Manufacturing DelayDiscontinuanceNote - CVM only tracks shortages of medically necessary veterinary products (MVNP).Demand Increase4Shortages on CVM’swebsite dating back to 2011

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GLOBAL ANIMAL HEALTHPHARMACEUTICAL SUPPLY CHAINAnimalSheltersExcipient Packaging rsDistributionDistributorsVet ClinicsVetHospitalsVetPharmaciesRetailers6Active IngredientSuppliers

Disruption:any occurrence which hasnegative consequences andcauses some confusion ordisorder on routine supplychain operations (Vakhariaand Yenipazarli, 2008)DISRUPTIONSVERSUS SHORTAGESShortage: a situation that causesproviders to have to makechanges to medications orchoose alterative drugs due toa supply issue (ASHP, 2018) a period of time when thedemand or projected demandfor a drug within the UnitedStates exceeds the supply ofthe drug. (FDSAI Act,Title X)7

DRUG SUPPLY INTERRUPTIONS ARE NOT NEWCause API supplier stopped production Penicillin Gshortage(Science, 1976)Cause Site Transferdue to newGMPrequirement More PenicillinG Shortages(1994, 1999)Mitigation FDA recommended usingPenicillin G Potassium as analternative Emergency Stock of Productallocated on emergency basis bymanufacturer FDA approved a temporarysupplier in Austria8Actions weretaken to preventshortages duringWorld War I(JAMA, 1917)Drug product manufacturerrecalled and stopped productiondue to GMP deficiencies

9FDA Efforts toPrevent and MitigateHuman DrugShortages

FDA DRUG SHORTAGE PROGRAMIn 1999, FDA CDER established a small drug shortage program (DSP) supported manufacturers and pharmacies through year 2000 (“Y2K”problem) many requests received, mostly regional, coordination was beneficialand simple10However, more significant shortages became apparent root causes related to manufacturing issues, broader implications FDA investigated

FDA ECONOMIC ANALYSIS2011: FDA attributed the class wide shortages of sterilepharmaceutical injectables to: scope and volume of products produced by industry not matchedby manufacturing capacity. high rate of patent expirations and increasing generic competition.11The FDA economists thought the issue would resolve itself as new suppliersentered and competed more effectively.

FDA, A Review of FDA’s Approach to Medical Product Shortages, October, 201112FDA 2011 REPORT

FDA, A Review of FDA’s Approach to Medical Product Shortages, October, 201113FDA 2011 REPORT

14FDA 2011 REPORT

FDA 2011 REPORTLongTerm Assess mitigation and prevention strategies and new approaches Determine cause of quality issues and develop approaches to address Encourage manufacturers to create back up plans Assess a “sentinel reporting network” for early warning Communicate drug shortages to the public (website) Improve internal FDA communication Urge transparency of distributor practices Develop a model to predict drug shortagesFDA, A Review of FDA’s Approach to Medical Product Shortages, October, 201115ShortTerm Urge manufacturers to notify FDA in advance of a shortage Develop guidance for industry on reporting Increase FDA drug shortage staffing Maintain a drug shortage database Support legislation (notification and FDA enforcement power)

LEGISLATION Prior to 2011, sole manufacturers of human drugs had to report discontinuances ofmedically necessary drugs to FDA Executive Order 13588, signed in 2011 Empowered FDA to “help prevent and reduce current and future disruptions in the supply of lifesaving medicines” All manufacturers now must notify FDA of potential disruptions and discontinuations of criticalmedicines in advance Food and Drug Safety and Innovation Act (FDASIA), signed July 201216 Title X – manufacturers of life supporting or sustaining drugs, or drugs intended for use in theprevention or treatment of a debilitating disease or condition, must notify FDA if these drugs willbe discontinued or disrupted at least 6 months in advance or as soon as possible FDA enforcement FDA required to make annual reports to Congress, maintain a list of drug shortages, form a taskforce, and execute a strategic plan FDA required to assess risk of shortage prior to issuing warning letters

FDA, Strategic Plan for Preventing and Mitigating Drug Shortages,October, 201317FDA STRATEGIC PLAN FOR PREVENTING ANDMITIGATING DRUG SHORTAGES – 2013

FDA Strategic Plan for Preventing and Mitigating Drug Shortages, October 2013.18FDA STRATEGIC PLAN FOR PREVENTING ANDMITIGATING DRUG SHORTAGES - 2013

FDA STRATEGIC PLAN FOR PREVENTING ANDMITIGATING DRUG SHORTAGES - 2013Strengthen Mitigation Response Develop and/or Streamline Internal FDA ProcessImprove Data/Response TrackingClarify Roles and Responsibilities of ManufacturersEnhance Public CommunicationsDevelop Long Term Prevention StrategiesFDA Strategic Plan for Preventing and Mitigating Drug Shortages, October 2013.19 Develop Methods to Incentivize and Prioritize Manufacturing Quality Identify Early Warning Signals of Shortages Increase Knowledge to Develop New Strategies to Address Shortages

FDA STRATEGIC PLAN FOR PREVENTING ANDMITIGATING DRUG SHORTAGES - 2013CreateAllocationPlansCommunicatewith ContractManufacturersManageInventoryDevelop Shortand Long TermproposalsCommunicatewith FDAInvestigateRoot CausesConsiderClinical TrialsFDA Strategic Plan for Preventing and Mitigating Drug Shortages, October 2013.20Roles andResponsibilitiesof Manufacturers

QUALITY INCENTIVE INITIATIVEWoodcock and Wosinska (2013)“Economic and Technological Drivers of Generic Sterile Injectable Drug Shortages”Shortages of generic sterile injectable drugs are due to:manufacturing-quality issues and disincentives to improve qualityaging, specialized, dedicated facilitiescapacity constraintscost savings initiativesincreased price competitionjust-in-time inventory levelsfocus on price rather than qualityreactive rather than proactive manufacturers (no reward for quality)21

QUALITY INCENTIVE INITIATIVE Manufacturers voluntarily submitquality metrics dataFDA uses metrics data to detect signalsSubmission ofQuality Metrics DataFDA rewards participation by publiclyposting manufacturer name on theQuality Metric Reporter ListThe Quality Metric List is used forsupplier selection and purchasingdecisions22FDA draft Guidancefor Industry

23IndustryPerspectives onHuman DrugShortages

ISPE ECONOMIC ANALYSIS 2017(SURVEY OF 10 COMPANIES)Market withdrawals due to quality issues, new drugs, portfolio optimizationNeed to optimize supply chains and planningDecisions to allocate redundant capacity based on complexity, return oninvestment, and impact on patients in case of shortageAbsence of incentive (contracts/financial) discourages prevention/resolutionof shortages Time and cost associated with regulatory requirements to expandmanufacturing capacity or upgrade equipment discourage change24Limited insight into future demand (esp low volume/ margin products)discourages investment

ISPE DRUG SHORTAGES SURVEY - JUNE 2013The Survey assessed:Major Findings: Aseptic processing equipment wasidentified as a significant factor Production system issues leading todrug shortages or near misses werepresent during technology transfersor product development accordingto a small but significant number ofrespondentsISPE, Report on the ISPE Drug Shortages Survey, June 2013.25Quality RecordsFacilities and EquipmentPackaging and LabelingProduction EquipmentProduction System (Sterile/Non Sterile)Material Systems (Sterile/Non Sterile)Lab Controls (Sterile/Non Sterile)

ISPE DRUG SHORTAGES SURVEY - JUNE 2013Strong Quality System/Compliance/GMPCorporate Goal to Avoid/Prevent Drug ShortageSuccessFactors inPreventingDrugShortagesAbility to ReactStrong Relationship with Health AuthoritiesDedicated ResourcesIncentivesISPE, Report on the ISPE Drug Shortages Survey, June 2013.26Metrics

ISPE DRUG SHORTAGE PREVENTION PLAN - 2014CorporateQuality CultureRobust unicationswith AuthoritiesBuildingCapabilitiesThe plan includes information based on interviews with industry and includes detaileddiscussion, case studies, and examples.27Global plan (or toolkit) presented in the following framework:

ISPE Drug Shortage Prevention Plan - 2014 Assess quality culture Establish decision-making procedures Proactively manage trends and signals Establish a process for problem escalation Supply chain evaluation of robustness and resilience Develop management capability related to managing crises Establish cross functional rapid response teams Conduct regular quality review meetings with crossfunctional attendance28CorporateQuality Culture

ISPE Drug Shortage Prevention Plan - 2014 Establish a life cycle management business process Continuously validate manufacturing processes Ensure management review of deviations, look for trends Ensure investigations surface root causes and effects Ensure timely completion and effectiveness of CAPAs Set up knowledge management system and establish subjectmatter experts Use sound scientific and risk-based approaches Perform a drug shortage focused risk assessment of facilitiesand equipment Maintain lists of critical materials used in manufacturing andestablish risk mitigation strategies for these materials29Robust QualitySystem

ISPE Drug Shortage Prevention Plan - 2014BusinessContinuityPlanning Achieve a healthy supply chain through integration ofsupply chain and quality systems with governed byeffective management Build redundancy based on risks as needed Proactively establish crisis management and disasterrecovery plans30Metrics Establish a variety of drug shortage metrics related toquality, supply chain, and culture as a basis forcontinuous improvement

ISPE Drug Shortage Prevention Plan - 2014 Develop an internal supply risk escalation processCommunicationswith Authorities Rapidly communicate potential supply risks to the regulatoryauthorities Develop plans to resolve the issue Discuss regulatory submission content and timing Foster cross functional training and interaction Create an environment of continuous learning and sharing Utilize mentorship to maximize learning and development31BuildingCapabilities

PDA AND ISPE TOOLSParenteral Drug Association (PDA) Technical Report 68, Risk-Based Approach forPrevention and Management of Drug Shortages (2014) Product level risk based framework Uses a risk triage model Includes TemplatesISPE Drug Shortage Assessment and Prevention Tool (2015)Uses framework from the 2014 ISPE Prevention PlanIntended to help manufacturer’s make a roadmap to the “desired state”Uses gap assessment approachTakes into account – maturity levels32

CONCLUSIONS There are supply disruptions of veterinary drugs which may impact animals, veterinarians,producers, pet owners, regulators, and manufacturers. Supply disruptions are not new. FDA and ISPE have taken significant steps toward prevention and mitigation of human drugshortages and some of this information may be useful to consider for veterinary drugs Open Questions:How many veterinary drug disruptions are there?What is the impact of animal drug disruptions?What are the causes of animal drug shortages?What are we currently doing to prevent/mitigate disruptions?Is there a need to do more to prevent/mitigate disruptions?33

Sep 26, 2019 · Metrics ISPE Drug Shortage Prevention Plan - 2014 Establish a variety of drug shortage metrics related to quality, supply chain, and culture as a basis for continuous improvement Achieve a healthy supply chain through integration of supply chain and