U.S. Food and
Drug Administration
Performance Plan
2002
Assure the safety of medical products at all stages in the life cycle--production, distribution and consumption.
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.
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.
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.
*
FY 02 and FY 03 are still targets
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.
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.
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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