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On Patient Safety: COVID-19 Exposes the Dangerous State of Drug and Device Supply Chains

Rickert, James MD

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Clinical Orthopaedics and Related Research: July 2020 - Volume 478 - Issue 7 - p 1419-1422
doi: 10.1097/CORR.0000000000001327
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The coronavirus disease 2019 (COVID-19) pandemic has cast a harsh light on safety inadequacies within our worldwide drug, medical supply, and device supply chains. As of this writing (early May 2020) healthcare providers around the world are doing their important work without enough masks, sterile equipment, and other personal protective equipment [3, 17, 20]. Governments have responded to critical shortages with stopgap measures, like the United States federal accord with 3M (Saint Paul, MN, USA), which seeks to expand the US supply of N95 masks [19]. Additionally, the US government has asked the Indian government to lift its export restrictions on drugs so that the United States does not face such severe shortages of essential medicines [6], while the European Union has asked its member countries to lift their export restrictions to prevent European drug shortages [9]. Important as these actions are, they are temporary fixes. We must address the root causes of our serious medical supply-chain inadequacies to ensure an acceptable and safe supply of drugs and medical equipment for patients the world over.

But the current pandemic did not create our supply-chain inadequacies. Before the outbreak, nearly 2 billion people, most living in poor and middle-income countries, had no access to basic medicines [28]. This tragic situation was caused in large part by high prices that western pharmaceutical companies can command for patent-protected medicines, and the trade agreements that enforce these patents [2]. Indeed, drug costs account for 60% of all expenditures in some low-income countries [28]. I’ll cover the serious safety risk these obvious supply problems cause in a future column; the remainder of this column will address supply-chain problems afflicting western nations, in particular those of the United States.

The western world, in general, is heavily dependent on offshore production of our medicines, medical supplies, and medical devices; the United States is critically dependent on offshore production. Consider that:

  • Malaysia alone makes three out of every four medical gloves on the market [14].
  • India supplies 50% of global demand for various vaccines and 25% of all medicines in the United Kingdom [11].
  • More than 95% of the US supply of medical-grade protective masks comes from China and other overseas manufacturers [17, 18].
  • About 97% of all antibiotics used in the United States come from China [10].
  • Domestic drug producers manufacture only 28% of the active pharmaceutical ingredients (APIs) in the US drug supply [26].
  • Nearly 80% of producers of the drugs listed on the WHO Essential Medicines List—anesthetic agents, antibiotics, and cardiovascular drugs—are located outside the United States [26].

Prior to the current pandemic’s well-documented supply-chain disruptions, the quality and reliability of western drugs sourced from overseas had already been called into serious question. The Government Accountability Office (GAO) has listed the FDA’s difficulty in ensuring the safety of American drugs sourced overseas in its “High Risk Series” for more than a decade [24]. Shortages in the United States of essential medications produced overseas have been reported before. The most heartbreaking of these was the 2019 shortage of vincristine, a chemotherapeutic agent used to treat childhood cancers [21]. Additionally, a 2018 report by the Access to Medicines Foundation, a European organization focused on improving access to crucial medicines, noted the concentration of production of APIs in just two countries—India and China—to be a worldwide safety concern for global access to antibiotics [1]. As an example of this risk, the Access to Medicines Foundation noted that the example of a worldwide shortage of the antibiotic piperacillin-tazobactam was caused by an explosion in just one factory in China—the sole producer of the API needed to produce the antibiotic [1].

In addition to the Access to Medicines Foundation, the FDA, the US Commerce Department, the European Medicines Agency [27], and GAO all have warned, some for many years, of potentially serious disruptions in our access to drugs and medical supplies based on our reliance on underregulated overseas supply chains. The FDA itself in October 2019 [26] and the GAO, most recently in December of 2019 [24], both have discussed the serious obstacles to ensuring drug and device safety in a complex worldwide supply chain that is predominantly located offshore.

For example, the FDA’s overseas inspection program is simply not as strong as its domestic program, which results in a particular area of vulnerability. Unlike domestic inspections, which are typically unannounced, the FDA’s overseas inspections are almost always announced 12 weeks before they occur. And even as the United States continues to depend increasingly on overseas production, the FDA performed 10% fewer foreign inspections from 2016 to 2018, and it has not yet inspected all foreign manufacturing plants [24]. Finally, as if to prove the difficulty in safely managing our supply chains, the FDA has cancelled all overseas inspections of drug and device facilities at least through April 2020 [12], even as many imported low-quality or counterfeit medical supplies flood western markets [7, 13, 23].

The FDA acknowledges one particular shortcoming is its lack of data on where drugs entering the American market are actually being produced [26]. Importantly, the FDA has no visibility into which API supplier an overseas manufacturer sources into its products—such API suppliers do not need to register with the FDA if they ship to a manufacturer outside the US—even if the finished drugs then enter the US market [26]. The FDA notes that medical-device and supply manufacturers are not required to notify them when they expect shortages [25], a shortcoming that tenuous global supply chains exacerbate. Drug and device makers typically regard their manufacturing schedules and suppliers as trade secrets, and do not openly share nonrequired information [5]. All of this must change.

Western nations are either debating or already taking decisive action to improve supply chains. For instance, Germany’s Economy Minister has gone so far as to suggest nationalizing key pharmaceutical producers [8]—Canada has already empowered its health minister to circumvent patents and produce needed medical devices, medications, and vaccines locally, while Israel has lifted patent protections from promising COVID-19 drugs [16]. It is time for decisive action in the United States to shore up our medical supply chains as well.

In the United States, in the short-term, just a small percentage of Congress’ ongoing COVID-19 outlays would go a long way in expanding the FDA’s budget so that they can invest in overseas inspections. The FDA should begin unannounced overseas inspections as though they were domestic inspections. As of this writing, Congress has yet to grant the FDA authority to demand and collect data on sourcing of ingredients and components for drugs and medical devices, respectively, for all products entering the United States, and I believe this ought to be included in one of the COVID-19 relief bills now moving through Congress (again, as of this writing). Western manufacturers should be required to detail their levels of production overseas at specific manufacturing facilities so that we have greater awareness of potential shortages and knowledge of sourcing, and suppliers also should be required to notify the FDA and EMA of any potential manufacturing slowdowns.

In the long term, the United States must all take on a greater percentage of medical manufacturing; happily, a few ideas have been floated on this topic. For instance, a plan has been introduced in Congress to nationalize generic drug manufacturing [22]. Civica Rx, a national nonprofit, was formed to address drug shortages, diversify our nation’s essential drug supply chain, and hold generic drugs as a public asset; this organization has the backing of many industry stakeholders [4]. Orthopaedic surgeons should use our political action committee and professional societies to push for long-term structural changes that address the safety issues threatening our drug and medical supplies.

The FDA believes that use of advanced manufacturing techniques, such as “continuous manufacturing” instead of traditional “batch” manufacturing would improve product quality, reduce cost, and decrease the environmental footprint of the manufacturer—all key components of moving manufacturing back to the United States and Europe [26]. As substantial public money would be required to begin such an effort, some degree of national price-setting for a certain period of time would be appropriate for those drugs and devices manufactured at new advanced facilities. This is similar to the sort of public-private partnership the Trump administration has suggested for rebuilding America’s infrastructure [15]; if carefully designed, this could ensure that American patients and providers both gain access to needed medical products at reasonable prices.

References

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