Compliance

02
Sep

Compounding to Get More Scrutiny?

I read two articles today that made me wonder what the next year will look like for enforcement activity in the compounding arena. First was an article by Peter Pitts published in RealClear Health (here) titled “The Compounding Loophole Has Become a Business Model”. The second is a report in the Pink Sheet written by […]

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04
Aug

Inspectional Enterprise, the FDA Is Building for Tomorrow

Today on FDA’s website, Elizabeth Miller, PharmD, Associate Commissioner for Inspections and Investigations, and Lowell Zeta, JD, Acting Chief of Staff and Deputy Commissioner for Strategic Initiatives, penned an article (here) titled Investing in FDA’s Inspectional Enterprise. The article outlined FDA’s view of the evolving nature of the FDA inspections program and outlined several objectives […]

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23
Jul
AI figures following behind a human

From AI Incidents to AI Catastrophes: What Today’s Failures Tell Us About Tomorrow’s Risks

Artificial intelligence is transforming virtually every industry, from healthcare and pharmaceuticals to finance and national security. Yet as adoption accelerates, so does evidence of harm. The Organization for Economic Co-operation and Development (OECD) AI Incidents Monitor (AIM), which tracks publicly reported AI incidents and hazards worldwide now contains more than 16,000 documented incidents and hazards, […]

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22
Jul
Talent cliff visual representation

When Technology Outpaces QA and Regulatory Capability

Have you assessed the strategic risk of your company’s readiness to meet the following regulation in the future? “Each person engaged in the manufacture, processing, packing, or holding of a drug product shall have education, training, and experience, or any combination thereof, to enable that person to perform the assigned functions (21 CFR 211.25(a))” Or […]

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21
Jul
Concerned person looking at paper

Don’t Ignore That Footnote! Not Capable Does Not Equal Exempt

In the pharmaceutical industry, some of the most important regulatory expectations are not always found in the main body of a guidance document. Occasionally, a seemingly modest footnote carries significant implications for the future of compliance. One such example appears in the MHRA GxP Data Integrity Guidance and Definitions (March 2018), which states: “It is […]

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15
Jul
An illustrated thermometer

HVAC Setbacks and Hidden GMP Risks

Pharmaceutical companies are under constant pressure to reduce operating costs without compromising product quality. There are a number of factors that affect operating costs, and energy prices are one of many. Global fuel and energy prices remain volatile due to geopolitical issues. The U.S. Energy Information Administration reported that global oil markets remain in a […]

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10
Jul
Spoke in a wheel

Efficiency in Drug Establishment Requirements for Certain Multiple Sites under a Common Legal Entity

FDA issued a proposed rule titled “Drug Establishment Registration and Drug Listing Requirements for Establishments Engaged in Distributed Manufacturing and Certain Foreign Establishments” to modernize drug manufacturer listing requirements for certain entities. The proposed rule would permit a hub-and-spoke model single listing to identify multiple manufacturing sites engaged in a distributed manufacturing model. Now do […]

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09
Jul

CDMO Growth Creates Data Integrity Risks Across Company Boundaries

The pharmaceutical supply chain is no longer just a chain of physical materials, but rather a complex series of data, data-based decisions, and delegated responsibilities for that data. FDA’s CDER FY2024 Site Catalog reported 4,619 manufacturing sites globally, reflecting the broad scale of the regulated manufacturing network supporting the U.S. drug supply. Within that network, […]

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07
Jul
D-Day Coming for the Use of Certain Peptides in Pharmacy Compounding

D-Day Coming for the Use of Certain Peptides in Pharmacy Compounding

In a previous blog posted on April 16, 2026 (here), we discussed the announcement from FDA regarding an upcoming meeting of the Pharmacy Compounding Advisory Committee to be held on July 23-24, 2026, focused on the inclusion of some active ingredients on the permitted pharmacy compounding list. That post identified seven peptide active ingredients that […]

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