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FAQs regarding the revisement of CEP Cholesterol HP of CARBOGEN AMCIS

Regulatory affairs

What kind of inspection has been performed?
Our CMO DISHMAN CARBOGEN AMCIS Ltd voluntarily requested for an inspection as the last one was already 5 years ago. Therefore the current outcome was certainly not expected by our Indian colleagues.
We are not MAH, what do you expect from us?
Please inform your customer(s) who do hold MAs.
When is the revised CEP available?
We do expect the revised CEP, without the Indian production location within the next two weeks, depending on further restrictions due to the COVID-19 outbreak. As soon as the revised certificate is available your RA contact will be informed.
Will the Open Part of the DMF be updated?
As the current Open Part of the DMF is a combined one a separate Open Part for Minakem material will be prepared. Due to the uncertain situation (a.o. Covid-19 virus) we target to have this completed by the end of April.
What are the consequences for the US DMF #25382?
It is hard to predict how FDA will look at EDQM’s and Swissmedic’s report. EDQM will inform all relevant authorities on the outcome, it is up to them to take action(s). A summarized report on the inspection will become available on EUDRAGMP.
Are any other CEPs involved?
Besides the CEP for Cholesterol HP there is one in the name of Carbogen Amcis B.V. which will be suspended (Dihydrotachysterol), the other CEPs on our name remain valid.
Are there other qualified suppliers?
On the CEP of Cholesterol HP also Minakem, France is registered as manufacturer. Also we are preparing plans to add one or two other manufacturers on the CEP.
What do I have to do as MAH?
As MAH you are responsible with regard to the substance concerned and any related marketing authorisation or marketing authorisation application. We will help you as much as possible, for instance with the risk assesment. Therefor we created a document in which we have related the findings to the product. This will help you with the risk assessment. You can find this document below.
Is the last FDA inspection report available?
Yes, it is available. You down download this document below.

Quality assurance

Are there any BST/TSE issues for Cholesterol HP?
No, the product is guaranteed manufactured from New Zealand or Australian wool grease and no other animal derived products are manufactured in Unit 6, the unit where Cholesterol HP is manufactured.
Is this a recall?

This is not a recall, but we advise you strongly not to use the product. Since there is no valid CEP, you cannot use the Cholesterol HP in your drug product if you make reference to the CEP in your registration files.

In the end, the MAH has the final decision.

What is the reason for removal of the CEP?
The CEP is not removed. The manufacturing site of DISHMAN CARBOGEN AMCIS Ltd is removed from the CEP, locations of Carbogen Amcis B.V. (intermediates) and Minakem (final steps) will remain on the CEP.
Can we get a copy of the report?
Yes, you can download the copy below.
Were observation made specifically related to Cholesterol HP manufacture?
No, Unit 6, where Cholesterol HP is manufactured, was not mentioned in the report. However some general observations will also influence Unit 6 such as the handling of recovered solvents and cleaning.
Has any purity or adulteration of cholesterol HP been identified?
No, not specifically. However some general observations will also influence unit 6 such as the handling of recovered solvents and cleaning.
Was the lack of Quality oversight related to the CEP and TSE/BSE?
Overall outcome is non-GMP (critical!), therefore it is related to HP as well.
What is the timeline for Corrective Actions and being recertified?

We are in close contact with DISHMAN CARBOGEN AMCIS Ltd. They are primarily responsible for the CAPA plan to be sent to the EDQM. We are involved in drawing up the CAPA plan.

We expect the submission of a CAPA plan within 3 weeks.

After submitting and executing the CAPA plan, a re-inspection of the EQDM is necessary in order to qualify for lifting the removal of the site. Given the current developments with COVID-19, it is very uncertain what the timelines can be.

Can CGAM B.V. do an analysis on BSE/TSE in Cholesterol HP?

No, but that is not necessary either. The purchase of wool grease and the starting material is done by CGAM BV. This can guarantee that the wool grease is BSE / TSE free. We can demonstrate the traceability.

Is the production method of Cholesterol HP at Minakem (also at the CEP) the same as At DCGAM Bavla?
Yes, you can download the copy of the declaration on Equivalency Cholesterol HP below.

FAQs regarding the suspension of CEP Dihydrotachysterol of CARBOGEN AMCIS

Regulatory affairs

What kind of inspection has been performed?
Our CMO DISHMAN CARBOGEN AMCIS Ltd voluntarily requested for an inspection as the last one was already 5 years ago. Therefore, the current outcome was certainly not expected by our Indian colleagues.
We are not MAH, what do you expect from us?
Please inform your customer(s) who do hold MAs.
How long will the suspension take?

We are in close contact with DISHMAN CARBOGEN AMCIS Ltd. They are primarily responsible for the CAPA plan to be sent to the EDQM. We are involved in drawing up the CAPA plan.

We expect the submission of a CAPA plan within 3 weeks.

After submitting and executing the CAPA plan, a re-inspection of the EQDM is necessary in order to qualify for lifting the suspension of the CEP. Given the current developments with COVID-19, it is very uncertain what the timelines can be.

Are any other CEPs involved?

The other CEPs in the name of Carbogen Amcis B.V. remain valid, except for the Cholesterol HP which will be revised (deletion of one of the production locations).

What do I have to do as MAH?

As MAH you are responsible with regard to the substance concerned and any related marketing authorisation or marketing authorisation application.

We will help you as much as possible, for instance with the risk assessment. Therefore we created a document in which we have related the findings to the product. This will help you with the risk assessment. You can find this document below.

Is the last FDA inspection report available?
Yes, it is available. You down download this document below.

Quality assurance

Is this a recall?

This is not a recall, but we advise you strongly not to use the product. Since there is no valid CEP, you cannot use the Dihydrotachysterol in your drug product if you make reference to the CEP in your registration files.

In the end, the MAH has the final decision.

What is the timeline for Corrective Actions and being recertified?

We are in close contact with DISHMAN CARBOGEN AMCIS Ltd. They are primarily responsible for the CAPA plan to be sent to the EDQM. We are involved in drawing up the CAPA plan.

We expect the submission of a CAPA plan within 3 weeks.

After submitting and executing the CAPA plan, a re-inspection of the EQDM is necessary in order to qualify for lifting the suspension of the CEP. Given the current developments with COVID-19, it is very uncertain what the timelines can be.

Can we get a copy of the report?

Yes, you can download the copy below.