U.S. Food and Drug Administration
Performance Plan
2002

 

Assuring Medical Product Safety

Desired Outcome

Assure the safety of medical products at all stages in the life cycle--production, distribution and consumption.

Why FDA's Contribution is Important

Consumers spend $326 billion annually in the U.S. on medical products. An estimated 1.3 million people are accidentally injured by medical therapy in the U.S. each year, and as many as 100,000 die as a result of preventable medical errors. FDA must be vigilant in monitoring the production, distribution and use of these products because FDA's presence raises the likelihood that public health and safety problems associated with these products will be addressed and because it is critical to citizen safety.

To ensure that these products are safe the Agency must oversee their entire life cycle--from production through distribution, and consumption/use. In the production and distribution phases of the cycle FDA must monitor over 40,000 establishments that manufacture these products. FDA is also responsible for ensuring the safe operation of some 10,000 mammography facilities. In addition, FDA must monitor over 2 million line entries of imported drugs, biologics, animal drugs and feeds, and medical devices that cross our borders annually.

Key Strategies

FDA's three primary strategies for ensuring medical product safety are to: a) enhance global vigilance over product manufacturing and distribution; b) strengthen and focus domestic industry monitoring; and, c) expand and automate the systems which report on adverse events associated with the use of medical products.

In the global arena, FDA plans to enhance the automated import monitoring system (OASIS) to improve cost effectiveness in screening unacceptable imports; and expand import coverage at ports. The Agency will also increase criminal investigations of fraudulent medical product imports. To improve public confidence in the safety of foreign medical products at the source, FDA will implement the European Mutual Recognition Agreement; participate in international standard setting forums such as the International Conference on Harmonization (ICH) to continue to advocate for rigorous standards; and increase the number of foreign inspections.

On the domestic front, FDA will continue to make the most effective use of limited inspection resources by implementing four key strategies: 1) Leveraging through contracts with the states, other third parties and outreach to small firms; 2) Focusing resources on the highest risk firms and medical products--areas which will bring the greatest health benefit; 3) Ensuring that inspectors have the scientific and technological support necessary to make quick and valid judgements about medical device compliance; and, 4) Reengineering the inspection process by implementing quality system inspections that will significantly reduce inspection time and increase effectiveness.

FDA's adverse event reporting strategies are intended to: develop a comprehensive adverse event reporting capability; analyze problems surfaced by these reports so that appropriate interventions can be designed; and educate both health professionals and patients about problems and solutions associated with appropriate product use. Two examples of strategies designed to develop more complete reporting are the Medical Device Surveillance Network (MeDSuN) System and the HHS Patient Safety Task Force. The MeDSuN System is a pilot program that educates and encourages hospital personnel to accurately identify and report injuries and deaths associated with medical products. This year FDA will implement the third phase of the (MeDSuN) to include drug products. FDA is also coordinating with the Department's Patient Safety Task Force to gain synergies from existing systems that are already collecting data on patient safety.

Current Status and Barriers to Future Progress

Global Vigilance -- Imports of all FDA regulated products have been increasing over the last several years--growing at an annual rate of 10 to 12 percent. In FY 2001, FDA physically examined less than one percent of all entries offered for import into the United States. A highly integrated web-enabled import monitoring system is required to allow the Agency to prevent unsafe import entries on a cost-effective basis. The proposed FY 2003 budget will fund the first steps toward establishing such a system. Alternatively, FDA would need restructured regulatory authority that would place more responsibility on exporters to assure that products entering the U.S. are safe.

Domestic Industry Monitoring -- The law requires that FDA inspect certain biologics, human and animal drug and feed, and medical device manufacturers at least once every 2 years. Although at least 50 percent of statutory establishments should be inspected annually, only 22 percent of human drug, and 13 percent of medical device statutory establishments were inspected in FY 2000. FDA will still fall far short of its statutory inspection requirements given current funding levels.

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* FY 02 and FY 03 are still targets

 

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Adverse Event Reporting -- The Agency has developed new standards for over-the-counter drug product labeling designed to increase patient knowledge about the medication and decrease errors in use. FDA is using a nationwide media campaign to inform consumers how to use the new labeling. But the adverse event reporting system must be significantly strengthened. Although we do not know the actual number of adverse events associated with medical products, just the reports we receive have more than doubled in the past ten years.

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FDA needs more expertise in medical epidemiology and statistical analysis to evaluate adverse events associated with increasingly complex medical products, and more educational efforts to correct these problems.

Specific performance commitments for FY 2002 and FY 2003 and actual performance from FY 2001 are outlined in the table that follows.

Performance Goals Summary

FY 2001 Performance Report FY 2002 - 2003 Performance Goals

Program

FY 2001 Goal

FY 2001 Status

FY 2002 Goal

FY 2003 Goal

Global Vigilance
Medical Devices
Goal 11
Inspect 9 percent of Class II and Class III foreign medical device manufacturers. Completed: 11 percent of foreign device manufacturers were inspected during FY 2001.
Inspect 9 percent of Class II and Class III foreign medical device manufacturers. Inspect 9 percent of Class II and Class III foreign medical device manufacturers.
Domestic Industry Monitoring
Human Drugs
Goal 16
Inspect 26 percent of registered human drug manufacturers, repackers, relabelers and medical gas repackers. Not Completed: 18 percent of drug establishments were inspected during FY 2001. Resources were diverted to high-risk inspection situations — particularly monitoring clinical trials with vulnerable populations.
Inspect 26 percent of registered human drug manufacturers, repackers, relabelers and medical gas repackers. Inspect 26 percent of registered human drug manufacturers, repackers, relabelers and medical gas repackers.
Human Drugs
Goal 17
Assure that 90 percent of drug industry is in conformance with FDA requirements. Completed: 95 percent conformance rate is an estimate based on limited baseline data. NA NA
Biologics
Goal 11
Assure that 90 percent of biologics industry is in conformance with FDA requirements. Completed: 99 percent conformance rate is an estimate based on limited baseline data. NA NA
Biologics
Goal 12
Maintain the percentage of plasma fractionator establishments in compliance at 80 percent. Not Completed: 69 percent of these establishments were in compliance in FY 2001. Inspections continue to find compliance discrepancies. NA NA
Biologics
Goal 13
Meet statutory requirement by inspecting 50 percent of blood banks, source plasma operations and biologics manufacturing establishments. Exceeded: 57 percent of the blood banks were inspected during FY 2001. Inspect 50 percent of registered blood banks, source plasma operations and biologics manufacturing establishments. Inspect 50 percent of registered blood banks, source plasma operations and biologics manufacturing establishments.
Animal Drugs and Feeds
Goal 8
Maintain statutory requirement by inspecting 50 percent of registered animal drug and feed establishments. Not Completed: 37 percent of establishments inspected. Resources were redirected to perform BSE inspections in order to minimize risk of BSE introduction into the U.S.
Maintain statutory requirement by inspecting 50 percent of registered animal drug and feed establishments. Maintain statutory requirement by inspecting 50 percent of registered animal drug and feed establishments.
Animal Drugs and Feeds
Goal 9
Assure that 90 percent of animal drug industry is in conformance with FDA requirements. Completed: 99 percent conformance rate is an estimate based on limited baseline data.
NA NA
Animal Drugs and Feeds
Goal 10
Maintain isolate testing rate for Salmonella in the National Antimicrobial Resistance Monitoring System (NARMS) at 12,000. CY 2001: Data not available until March 2002.
CY 2000: Total: 11,000 Salmonella isolates
Maintain isolate testing rate for Salmonella in the National Antimicrobial Resistance Monitoring System (NARMS) at 12,000. Maintain isolate testing rate for Salmonella in the National Antimicrobial Resistance Monitoring System (NARMS) at 12,000.
Animal Drugs and Feeds
Goal 11
N/A N/A Conduct targeted BSE inspections of 100 percent of all known renderers and feed mills handling prohibited material. Conduct targeted BSE inspections of 100 percent of all known renderers and feed mills handling prohibited material.
Medical Devices
Goal 8
Inspect 17 percent of Class II and III domestic medical device manufacturers. Completed: 20 percent
Inspect 20 percent of Class II and Class III domestic medical device manufacturers. Inspect 20 percent of Class II and Class III domestic medical device manufacturers.
Medical Devices
Goal 9
Assure that 90 percent of medical device industry is in conformance with FDA requirements. Completed: 96 percent conformance rate is an estimate based on limited baseline data.
NA NA
Medical Devices
Goal 12
Ensure at least 97 percent of mammography facilities meet FDA standards Completed: 97 percent of the mammography facilities met this requirement.
Ensure at least 97 percent of mammography facilities meet inspection standards. Ensure at least 97 percent of mammography facilities meet inspection standards.
Adverse Event Reporting
Human Drugs
Goal 14
Issue guidance on electronic submission of adverse drug event reports. Roll out AERS datamart to medical officer in new drug review divisions. Completed: Guidance issued. AERS datamart is now being utilized by medical officers in drug review divisions. Accept electronic submissions from drug companies, and code information consistent with internationally accepted standards. Major reporting companies will submit adverse drug reports electronically for all types of reports.
Medical Devices
Goal 13
Implement MedSun System by recruiting 75 hospitals. Not Completed: Only 25 hospitals were recruited, more effort than expected was needed for software development, and increased IT security requirements. Build a medical device surveillance network of 80 facilities. Extend network to 180 facilities.

 

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