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AF 9-561 FILE

NADA 55-056

John C. Stoner, D.V.!.

Director, Veterinary Professional & Regulatory Affairs

E.R. Squibb & Sons, Inc.

P.0. LOX 4090

Princeton, NJ 00540

Dear Dr. Stoner:

SEP 8 1975

We refer to your letter dated July 29, 1975, in which you submitted a supplemental now animal drug application for your product Princillin (sterile ampicillin suspension) Injection for use in dogs and cats.

The application provides for the addition of the John D. Copanos, Inc., baltimore, (0, as an alternate manufacturer of the subject product.

The labeling provided is identical to that previously approved, except that the qualifier "distributed by" is added and an additional change is the use of a 10 vial carton instead of the single vial carton.

We wish to remind you that a Form 4 exemption for the bulk antibiotic will be needed to permit shipment from Squibb to Copanos unless other appropriate arrangement have been made.

This supplemental new animal drug application is approved.

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This is in further rescease to your August 27 letter on behalf
of Ar. Anthony Mazzocchi, Director of the Citizenship-Legislative
Department of the 611, Chemical and Atonfc Yorkers International
Imion, concerning the possibility that F.R, Squibb and Sons, Inc.,
will relocate their penicillin queration. I regret the delay in
responding.

In order to be as useful as possible with respect to the records
requested by Ar. Mazzocchi (first three items of his letter) and
with the concurrence of Is. Linda Sanchert of your office, we
contacted Mr. Mazzocchi to define the parameters for the requested
records. He requested that the records search cover January 1, 1972,
to the present, and that it should focus on any information relative to
the Squibb facility in New Jersey bearing upon the statement in his
letter that Squibb contends that the Food and Drug Administration (FA)
regulations are requiring the moving of their penicillin operation to
North Carolina. As a result of our records search, we found three
Drug Inspectional Observations (FD For 2276), which appear to meet
Hr. Mazzocchi's request. Copies of these documents are enclose!.
No other relevant documents were found.

The Federal Food, Brug, and Cosmetic Act specifies that a drug shall
be deemed to be adulterated if the nathals and con'itions of manufacture
do not provide assurance that the products are safe, and that they have
the strength quality and purity which they purport to possess. Tha
Food and Drug Administration has no closedown authority, and must rely
on the courts to force such an action. We have worked closely with
phoraceutical manufacturers when inspectional findings revealed
Manufacturing and control deficiencies which crosted a potential for
the promotion of unsafe drugs, and therfore a potential hazari to
public health in the distribution of those drugs. Such has been the
case with the two finis we think dr. bazzocchi is referring to the
First befon icñau Laboratories' 'Milletexville, ferrata olant, a Division
of torican Hospital Spoly Cerporation. the second bafing Tray-nol
Laboratories' plant in Hays, Kansas.

In the case of frday Laboratories a larue orodure of fatravenous
Solutions an inspection fa foceller 1977 to January 1625 revealed
Toribus violatiors of
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In view of the potential hazard to health presented by distribution and use of these products. FDA requested the firm to voluntarily cease operations until its manufacturing systems could be qualified and to recall these products produced with a lack of assurance that they were safe (sterile). The firm complied with this request. McGaw, acting on the problems identified by FDA, accomplished the necessary corrections to achieve compliance with GMP Regulations during the six-month shut-dom period. The plant resumed operations on July 21, 1975, with the concurrence of FDA.

Similar findings questioning product sterility were found during an Inspection of Travenol's Hays facility, a producer of small volume Injectables. The FDA proposed to enjoin Travenol through the Federal District Court in Wichita, Kansas. This Agency and Travenol worked out an agreement whereby the Hays facility was shut down and all products were recalled. We do not know what the firm's intentions are with regard to this plant. Both firms have facilities in other locations.

Current GMP Regulations do not require that penicillin manufacturing facilities ba completely separate from facilities for nonpenicillin products. Based on the experience of FDA, however, there is a potential for hazardous contamination of nonpenicillin drugs with penicillin wherever common equipment or facilities are used for drug production. While the current GMP Regulations have an allowable tolerance for penicillin contamination in nonpenicillin products, the revision of the regulations (Federal Register proposal currently being developed) will delete the allowable tolerance for penicillin contamination of nonpenicillin drugs. The FDA finds that current good manufacturing practice in the industry has, to a large extent, eliminated penicillin cross-contamination by producing penicillin products in a separate building, or a separate area that has an air-handling system independent of other production areas, and is effectively sealed off from other parts of the building to prevent contamination of areas handling nonpenicillin products. The revision of GMP Regulations is expected to require that penicillin products be produced in a separate sealed-off area with a separate air-handling system. This will not necessarily require a separate building.

We do not have a file which reflects the names of firms who propose to build a separate plant for penicillin production. We are aware that some firms have created a separate area within an existing building for the production of penicillin products, while others have constructed a separate plant for the production of penicillin products. In either case, exercising appropriate precautions, compliance with the expected revised regulations can be achieved.

As indicated above, the current GMP Regulations refer to penicillin contamination under Title 21 Code of Federal Regulations, Section 211.58 (1) (copy enclosed). The revision of the CHP Regulations, when proposed in the Federal Register, will provide new conditions for penicillin production and will eliminate the current tolerance for penicillin contamination in nonpenicillin products. The Federal Register proposal, expected soon, will provide a time period and procedure for commenting. With respect to the request for the names of five former FDA employees now consulting for Squibb, we do not have records containing such Information. There is no requirement that a former employee keep us informed as to his occupational activities, nor do we have authority to engage in any surveillance. Of course, former FDA employees are personally responsible for observing the restrictions contained in the Federal Post-Employment statute (18 U.S.C. 207). This statute provides two restrictions on the activities of formar employees. The first precludes any former employee for a period of one year after separation from FDA, from acting as an agent before FDA on any particular matter which was under the employee's official responsibility while in FDA. The second restriction prohibits any former FDA employee from ever acting as an agent before FDA on a particular matter in which the employce participated personally and substantially while employed by this Agency.

Although we have no specific file of former FDA employees consulting for Squibb, through conversation with staff personnel in the Bureau of Drugs, we did learn of one former FDA employee who has contacted FDA with regard to a consulting contract he has with Squibb. The name of this former employce is Amiel Kirschbaum, who several years ago was the Director of the National Center for Antibiotic Analysis, a unit of the Bureau of Drugs. His contact with FDA did not involve the problem of penicillin cross-contamination.

We hope this information is helpful to you and the 011, Chemical and Atomic Workers International Union.

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Init: RCWetherell, Jr.: 10/22/75
GFMeyer: 10/22/75
RMerrill:10/31/75

HF-1 (x) w/ey inc HF-2 w/ nie. w/g

SamFine: 10/28/75 it. by f. Bardner 10.30.75

F/T:MJFromer: nhw:11/4/75

21-689 - 78 - 33

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