Introduction:- Recall is an action taken to withdraw/remove the drugs from distribution or use including corrective action for which deficiencies are reported in quality, efficacy or safety. The defective products related to quality includes Not of Standard Quality, Adulterated or Spurious drugs. Safety and efficacy related recalls include serious adverse reactions and death. Recalls also include drugs prohibited under the Provisions of Drugs & Cosmetics Act and also those products for which product licenses are suspended/cancelled.
Rapid Alert System is to transmit only those alerts whose urgency and seriousness cannot permit any delay in transmission. Assessment must be made of the seriousness of the defect, its potential for causing harm to the patient or harm to animals (in case of veterinary product), consumers, operators and the environment.
Background:- In the Drugs & Cosmetics Act & Rules, there are references for product recalls, complaint and adverse reactions in Para 27 & 28 of Schedule M and also conditions of license for defective product recall in Rule 74(j) and Rule 78(i), but effective and uniform recall procedure, with time lines at every level of supply chain is required and at present auditing and accountability is not in place. This has been observed in instances where drugs declared as not of standard quality by Government Analyst, incidents where serious adverse effects or death have been reported, in case of banned drugs under Section 26 A, defects where in voluntarily the manufacturer withdraws drugs from the market etc.
Recall Classification:- Recall classification is a numerical designation, I, II, or III, that is assigned to a particular product recall that indicates the relative degree of health hazard by country regulatory authorities.
In case of not of standard quality drugs, the recommendations of 39th DCC guidelines for category A,B and C may be accordingly adopted for Class I, Class II and Class III until further recommendations if any. All banned Drugs & Products for which license is suspended, cancelled which are in circulation in market shall also be considered to be Class I recalls only.
Class I is a situation in which there is a reasonable probability that the use of, or exposure to, a defective product will cause serious adverse health consequences or death and as well as banned under 26A of Drugs and Cosmetics Act 1940.
Class II is a situation in which the use of, or exposure to, a defective product may cause temporary adverse health consequences or where the probability of serious adverse health consequences is remote.
Class III is a situation in which the use of, or exposure to, a defective product is not likely to cause any adverse health consequences.
Recall Procedures:- Any batch of a product not meeting the defined quality standards has to be recalled from the market. Recall can be of two types;
- Voluntary Recall
- Statutory Recall.
Voluntary Recall:- Voluntary recall can be triggered by any incident that affects the quality, safety and efficacy of the batch/product in question such as:-
- If the batch or batches are found to be not complying with the regulatory specifications during the post marketing stability study.
- If the batch is found to be defective during investigation of market complaint.
- During any failure investigation, if it is observed that the failure under investigation might have adverse quality impact on already released batch (e.g. possibility of contamination, mix-up, degradation etc).
- If any unusual observation is noted during visual inspection of retention samples which indicate an impact on quality of the product after investigation.
- If the post marketing surveillance reports /pharmacovigilance reports indicates that there is serious safety risk associated with the product.
Statutory Recall:- Statutory recall can be triggered in response to the direction or mandate by the
Drug Regulatory Authorities (Central/State) in one or more of the situations as follows:
- To recall the drug product/batch, considered to be in violation of the laws, it administers such as not of standard quality etc.
- To recall the banned drugs.
- Labeling and / or Promotional materials, that are considered to be in violation of law.
- Product, violation Rule 106 (Diseases under Schedule J).
Levels of Recall:- The level (or depth) of recall of a product/batch shall be determined based on recall classification and level to which distribution has taken place.
There are three levels of recall:-
-Consumer or User Level: which may vary with product, including any intermediate wholesale or retail level. Consumer or user may include individual consumers, patients, physicians and hospitals.
–Retail Level:- recall to the level immediately preceding consumer or user level. It includes retail groceries, pharmacies, hospital pharmacies, dispensing physician, institutions such as clinics and nursing homes, etc.
–Wholesale Level: all distribution levels between the manufacturer and retailer.
All Class I recalls shall be executed to the levels of Wholesale/Distributors, retail, and consumer. In such cases, public announcements shall be made using print/electronic media aids viz. Newspapers, Television, Radio etc.
All Class II recalls shall be executed up to the levels of wholesale and retail. All Class III recalls shall be executed up to the levels of wholesale.
Time Lines for Effective Recall System & Rapid Alert:- Based on the category of risks involved, a time line of within 24 hours up to a maximum of 72 hours for Class I recall, for class II recall up to a maximum of 10 days and for Class III recall up to a maximum of 30 days is allowed.
The time line for initiation of recall procedure to commence from the receipt of information as notified by the concerned State/ Central Drugs Control Department under statutory recall or voluntary recall by the manufacturer on its own.
The recall has to be initiated immediately without any prejudice of the outcome of Section 25(3) and Section 25(4) of the Drugs & Cosmetics Act 1940 for adducing the evidence. The time line for stopping sale/distribution of defective product under Class I shall be ensured within 24 hours and the physical recall being completed within 72 hours. The Class II and Class III recalls shall be ensured upto 10 and upto 30 days respectively.
Procedure for Rapid Alert & Recall System:-
- As soon as the product/batch(es) to be recalled is/are identified, licensee or representative of licensee or QA in charge shall review the information related to the defective product/batch(es) and decide about recall as per the procedure established.
- The decision on recall of the defective product/batch shall be made within 24 Hours up to maximum of 72 Hours for Class I recall upon receipt of the intimation.
- Within 24 Hours of the decision taken for the recall of the product/batch(es) the communication shall be sent stating the severity of the defect, using the fastest mode of communication which may include email, telephone, fax, SMS etc to the entire supply chain.
- The licensee/representative of licensee where the product is marketed shall inform the concerned regulatory authorities where the product batch(es) in question was distributed immediately after the decision of recall has been taken. Further actions on recall will be undertaken according to class of recall.
- Recall classification of the product/batch in question shall be done based on the risk assessment in line with the recall classification as given in definition.
- It shall be the responsibility of the manufacturer and marketing company to inform up to retail level on the reason of recall in his freeze stock notice.
- It shall be the responsibility of distributor/marketing company/ retailer to inform the stock position of product being recalled to his immediate supplier or manufacturer and also his area Drugs Inspector.
- The recall notice received, the stock at that time, the procedure for freezing the stock and returned back records shall be maintained by the distributor/retailer and shall be made available for verification by area Drugs Inspector who shall verify and report on its timely freezing and return.
Stepwise Recall Procedure:- The licensee/representative of licensee/Quality Head in charge shall enter the details in the ‘Recall Log’ and assign a unique recall reference number representing the serial number for a particular year in which the recall has been initiated.
The licensee/representative of licensee/ Quality Head in charge shall inform the Distributor/Marketing Company with fastest mode of communication which may include email, telephone, fax, sms etc. to stop further distribution of the batch(es) in the stock and call back the stock available with the distributors, retailers etc, depending on the seriousness of the defect.
“Product/batch Recall Notice” shall be filled and sent by licensee/representative of licensee/ Quality Head in charge to Distributor / Marketing Company.
Distributor / Marketing Company shall immediately check the distribution record to identify the Customers and Warehouse, depots where the subject product / batches have been distributed and forward the copies of the Recall Notice to them for further necessary action.
The Head of depot(s) shall fill ‘Recall Notification’ and forward it to all distributors to return all unsold stock. Simultaneously, the Heads of respective depots/ware houses shall block the available stock. The Distribution Head shall ensure the blockage of stock for further sale by reviewing the record.
The distributor(s) shall send the “Return Feedback” along with goods (if any) to the depots. All the returned stocks shall be further forwarded to the ware houses.
The Head of ware houses shall send a periodical report to licensee/representative of licensee /QA head of the stock available with them and the returns received from depots.
Head of ware house shall reconcile the stocks of the recalled materials against the total quantity of distributed material and fill the “Summary Report of Product / Batch Recall”. The copy shall be forwarded to licensee/representative of licensee/QA in charge for review and necessary action.
The recall of the product/batch shall be completed depending on the class of recall within the stipulated time.
Follow-Up Action of Recalled Goods:- The follow-up action consists of a check on the effectiveness of the recall, an investigation of the reason for the recall and remedial action taken to prevent a recurrence of the defect.
The licensee/representative of licensee/QA Head shall monitor the recall process of product/batch to determine whether the recall is progressing satisfactorily.
The stocks of recalled goods shall be placed under “Quarantine” and stored separately under lock and key in a secure area until further decision.
Wherever required, QA Head of the manufacturing site shall perform the physical inspection of recalled goods and collect sample from recalled goods for investigation to establish the root cause of the product quality defect.
The investigation of the recalled batch(es) shall be conducted as per the SOP of the licensee, on “Investigation of Non-conformities” to identify the root cause of the failure and initiate corrective and preventive actions.
Impact assessment shall be conducted on other batches of the concerned product and further extended to batch(es) of other product(s), wherever applicable.
If the cause of recall is established to be quality issue associated with any of the raw material used, then the traceability of that material shall be established in all the product/batches.
Alternatively execute the transaction through records to identify the batches / products in which the identified material has been used.
Monitoring the relevant data i.e. Material, Plant and Batch Number in respective batches.
Identify the raw material traceability in different formulations and its functions.
List all raw materials along with batch numbers and the respective quantities used in those batches.
List all the products along with batch numbers and the respective quantities used in those batches.
Calculate the total quantity by adding individual quantities used in various products / batches.
Monitoring of the material movement to get the complete overview of stock for that particular material in the plant and extract the information about total quantity received and the balance quantity.
The balance stock, if any shall be verified against the actual physical stock available. QA shall block the remaining available stock.
All material shall be accounted for after the reconciliation.
The decision to recall, if necessary, any of the impacted batches shall be made after product quality assessment.
Based on conclusion of the investigation findings, the QA Head / representative of licensee shall direct the Distributor / Marketing Company for appropriate disposition of the batch(es) of the recalled goods as per the regulations.
MOCK RECALL:- Mock recall shall be carried out for at least one batch of any product, dispatched for sale where maximum distributors are involved, to test the effectiveness of the arrangements of recall. Effectiveness of recall procedure can also be checked by ‘evaluation of a real recall’.
During mock recall traceability shall be performed for at least, one of the raw material used in the batches identified for mock recall.
Mock Recall shall be performed at least once for the longest distribution chain and whenever there is a change in distributor/marketing company.
Records of such mock recall should be maintained by the QA Head of the company.