1. Common SPL Errors Experienced by FDA DRLS
Paul Loebach
FDA, Center for Drug Evaluation and Research
September 2016

2. Overview Topics we’ll cover in this presentation include:
Basic background of the Drug Registration and Listing System (DRLS)
“Top ten” SPL errors encountered by DRLS Staff
Summary

3. Background Section 510(b) of Food Drug and Cosmetic Act (FD&C)
During the period beginning October 1st and ending on December 31 of each year every person who owns or operates any establishment in any State engaged in the manufacture, preparation, propagation, compounding, or processing of a drug or drugs ... shall register with the Secretary his name, places of business and all such establishments.
Section 510(i) of FD&C
During the period beginning October 1st and ending on December 31 of each year, any establishments within any foreign country engaged in the manufacture, preparation, ... of a drug that is imported or offered for import into the United States shall ... register with the Secretary the name and place of the establishment, the name of the United States agent for the establishment, the name of each importer of such drug that is known to the establishment
Section 510(j) of the FD&C
Every person who registers with the Secretary shall file a list of all drugs which are being manufactured, prepared, ...
21 CFR Code of Federal Regulations
Guidance for Industry: Providing Regulatory Submissions in Electronic Format – Establishment Registration and Drug Listing
Establishes Structured Product Labeling (SPL) as standard

4. Background (cont’d)
2009 – accepting only SPL – did not migrate data from legacy paper system-maintained two systems -
Switched NDC Directory to just electronic data
Published the last of what is now called the “OLD NDC Directory”
Paper listings still technically active
2016 – 21 CFR 207 publishes
Mostly catches us up to current SPL practice, requires electronic submission
All mention of Paper forms gone
Requires UFI, should include FEI if known
Requires annual listing certification.
Effective date is November 2016

5. Top Ten Errors (Notes and Caveats)
Not really the top ten most prevalent
Some are just reoccurring errors and questions we encounter on a regular basis
Some are head scratching or amusing
Some are prevented by automated validations
But we get calls on a daily basis asking why the submission is being rejected
No particular order
Examples not intended to shame or embarrass any particular firm.
Our goal is accurate data!
Highlight errors to the experts so errors can be prevented.

6. Incorrect DEA Schedule Assignment
Top Ten Errors (10)
Incorrect DEA Schedule Assignment
Though these are internal listings by CMs, there were other finished listings that have since been corrected. Validations have been improved.

7. Top Ten Errors (9) Product Listings Referencing Unapproved or Non-existent Application Numbers
Some occurrences received before validations were put in place
Some are claiming an approval inappropriately
Kits containing a component that has a separate approval
Some unauthorized repacked and relabeled products
Non-compliant monograph citations
Some are products where the application has since been withdrawn
Efforts underway to address this

8. Top Ten Errors (8) Product Listings Using Incorrect Strength Representation
Firms don’t understand or know how to express a percentage strength as an appropriate ratio (incorrect calculations, incorrect units, or both)
Continued education of drug companies and SPL consultants/providers is needed
If expressed strength is actually wrong, possible regulatory actions such as flagging in or removal from NDC Directory, and potentially DailyMed.
SPL-drug information says 0.7mL/1mL which turns out to be 70% volume solution (vol/vol%).
The label however says 62%.

9. Top Ten Errors (8 cont’d) Product Listings Using Incorrect Strength Representation Example 2

10. Top Ten Errors (7) Failure to use the Same SetID to Submit an Update
One of the common errors for SPL rejection (that people call us about) is that a DUNS or NDC is linked to another SetID
Occurs on both the registration and listing side. The following doc types should use same setID as original registration/labeler code request/listing file:
Submission of deregistrations, no change notifications
name changes and updates to contact info for labeler codes
Updates to listing, labeling, and delisting of products should all use the same setID as previous/original listing
Company personnel turnover. New person in charge of SPL submissions has no idea where old submissions were saved, or if they were saved.
Can happen if company split packages of same product out into separate SPL
Save all successful submissions! Create new versions from previous submissions to prevent errors.

11. Top Ten Errors (6) DUNS Data do not match Establishment Name and Address
Make sure any address changes or name changes are fixed at Dun and Bradstreet (DnB) first
May be a small delay between when new changes/data is effective at DnB and when FDA can access it for validation
Ensure the DUNS number is associated with the actual establishment address and not the corporate address or another establishment location
Translation differences of foreign data between DnB and company submitting to FDA
FDA uses a “confidence level 10” validation threshold
Minor differences/variations are allowed (e.g. “Inc” vs “Inc.” or “Street” vs “St.”)
Interesting loophole in the logic that was recently fixed allowed for a completely different street number

12. Top Ten Errors (5) Problems with Non-Proprietary Name field
Fields are free text, so validation is difficult to impossible
Due to this, for searching, recommend using a concatenation of Active Ingredient names based on UNII
Sometimes ALL CAPS is used, sometimes Mixed Case. Sometimes it does not identify active ingredients.
Sometimes it’s an actual marketing statement!

13. Problems with Non-Proprietary Name field
Top Ten Errors (5)
Problems with Non-Proprietary Name field
For multiple ingredients, sometimes separated with commas, sometimes the word “and”.
Included strength and still had to provide it later with active ingredients

14. Problems with Non-Proprietary Name field (cont’d)
Top Ten Errors (5)
Problems with Non-Proprietary Name field (cont’d)

15. Top Ten Errors (4) Both Private Label Distributors (PLDs) and their Contract Manufacturers (CMs) must list under their own NDCs
The 2016 version of 21 CFR 207 continues the longstanding requirement that the ultimate responsibility for a PLD’s product listing lies with the registered manufacturing establishment. However, a PLD may still choose to submit its own product listing, acting as an agent for the registered manufacturer.
Regardless of which party submits the PLD’s listing data, the registered manufacturer is still obligated to list the product under its own NDC as well.
These manufacturer listings should employ one of the MANUFACTURED EXCLUSIVELY FOR PRIVATE LABEL DISTRIBUTOR marketing categories.
Listings under these categories are not published.
If a manufacturer makes an identical product for multiple PLDs, it need only list the product once under a single NDC with its own labeler code. However, we expect a unique NDC from each PLD for their version of the product.

16. Hypothetical Supply Chain Listings
Top Ten Errors (4)
Hypothetical Supply Chain Listings
Mfr A : Makes API
Mfr B : Mixes API and presses into tablets
Lab L : performs release testing and QC
Mfr C : Places imprint on tablet, packs and labels it for PLD
PLD : ANDA holder and distributes product
Facility Register? Operations List? Marketing Category
Mfr A Yes API Manufacture Yes Bulk Ingredient
Mfr B Yes Manufacture Yes Drug for Further Processing
Lab L Yes Analysis No --
Mfr C Yes Manufacture, Yes Approved Drug Mfr’d
Pack, Label Exclusively for PLD
PLD No Yes Approved Drug ANDA

17. Top Ten Errors (3) Image Files
When including image files with the SPL:
Ensure all images are JPG format (not GIF, PNG, BMP, etc)
Image files are limited to 1MB each
Ensure that all images included in the zip file are referenced somewhere in the Content of Labeling
Reference the correct images in the correct sections
Package label/Principle display panel
Product images for solid oral dosage forms
Graphs, charts, figures for content of labeling
Ensure all appropriate packaging is represented in the images
Do not include labeling proofs:
Included with an outer carton labeling image

18. Top Ten Errors (2) Changes Requiring New NDCs
SPLs are often rejected when a company changes certain data elements on a product listing. A new NDC Product code is required for any change or difference in:
Active ingredient list (add/delete/change active ingredient UNII
Strength of any active ingredient
Dosage form
Physical characteristics of solid oral dosage forms:
Size
Shape
Color
Flavor
Scoring
Imprint
A new NDC Product code is not required for changes to inactive ingredients (unless it affects a change to one of the characteristics above)
So double check these data elements prior to initial submission. If they are incorrect a fix requires a new NDC!
And the #1 SPL error is…

19. Top Ten Errors (1) Product Listings Referencing Unregistered Establishments
Over 22,000!
Validation prevents the submission of unregistered establishments in the establishment section
Establishments are registered upon initial submission, but then registration expires and/or the labeler switches manufacturing establishments and does not update the establishment section
Required annual updates/certification should take care of some issues
Possible regulatory actions such as flagging in or removal from NDC Directory, and potentially DailyMed, should take care of even more.

20. Top Ten Errors
Summary
Examples not intended to shame or embarrass any particular firm.
Our goal is accurate data!
Highlight errors to the experts so errors can be prevented.
Regulatory actions (Untitled Letters and Warning Letters) can help but take a lot of resources to fix a single error. They are necessary, however, if errors are serious enough and/or firms are unwilling to comply.
Education and outreach is the best remedy. “An ounce of prevention is worth a pound of cure.” You are the experts. Help spread the word to make the data complete and accurate for everyone!

21. Contact information
DRLS Helpdesk
SPL Helpdesk
CDER Direct Helpdesk
Electronic Systems Gateway Helpdesk