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[RegAffairs]Re: Mutual Recognition Procedure - TGA & EME

The problem in the case discussed is one of dilution. The MRA is 
between two countries which are not your country of location. The 
prime responsibility for your continued GMP compliance devolves on 
the regulatory agency of your country. They are the ones primarily 
responsible for your actions, they are the ones who can turn up 
without notifying you in advance and they are the ones who would take 
legal action against you. I would therefore expect a third country to 
want to rely on the primary authority rather than via a twice removed 
MRA.

With regards the shortage of inspectors etc, I can only agree with 
you, particularly in the latest story of the FDA inspecting the wrong 
factory in China [and not noticing that it was making different 
materials]-at least that is what the press is reporting.

It is a little surprising to me that no-one has actually posted a 
definitive opinion on this subject-I would have anticipated that 
there must be a ruling somewhere rather than us expressing our 
opinions.

Good luck

Malcolm Ross
Generapharm-Training and Consultancy
Basel-CH


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