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HEPARIN TIMELINE WITH WEB-LINKS
Copyright © 2008. Zoll, Kranz &
Borgess, LLC
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DATE
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EVENT
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1972
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Per
Baxter, SPL is first listed as an approved supplier of heparin for
ESI Lederle (ESI), a division of Wyeth, later acquired by Baxter.
(03/05/08
Baxter: Heparin Press Update.)
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1976
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Per
SPL, SPL is created by Oscar Mayer to process pancreatin and
heparin. (It is later sold to various companies including A.H.
Robins [1983], AHP [1989], Wyeth [2002], Arsenal Capital Partners
[2004], and American Capital Strategies [2006]). (SPL timeline: http://www.spl-pharma.com/timeline.htm)
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1990s
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SPL
begins to explore sourcing its crude heparin from
China
. (03/05/08
Baxter: Heparin Press Update.)
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1996
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SPL
begins producing regular shipments of finished heparin API
processed at its
Wisconsin
facility and sourced from Chinese crude heparin material. (03/05/08
Baxter: Heparin Press Update.)
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1999
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SPL
creates a joint venture with Techpool Bio-Parma Co., Ltd. called
Changzhou-SPL (“SPL-CZ”), (which later opens a facility in
China
for processing crude heparin). (SPL timeline: http://www.spl-pharma.com/timeline.htm
and 03/05/08
Baxter: Heparin Press Update.)
SPL
contends that they discussed the
Changzhou
joint venture with the FDA. (04/29/08
Written Testimony of David G. Strunce before Comm. On Energy and
Commerce.)
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2000
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SPL
builds a heparin API manufacturing facility in
Changzhou
,
China
. (04/29/08
Written Testimony of Robert L. Parkinson before Comm. on Energy
and Commerce.)
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March,
2000
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SPL
contends that it formally notified the FDA of the SPL-CZ joint
venture. (04/29/08
Written Testimony of Robert L. Parkinson before Comm. on Energy
and Commerce.)
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June,
2002
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Baxter
signs a definitive agreement to acquire ESI Lederle (ESI), a
division of Wyeth, which receives their API from SPL for
approximately $305 million. (03/05/08
Baxter: Heparin Press Update;12/20/02
Baxter: “Baxter
Completes Its Acquisition of ESI Lederle;”
10/17/02 Baxter: “Baxter’s
Sales, Earnings to Grow in Third Quarter”)
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Dec.
12, 2002
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Baxter
acquires ESI for approximately $305 million in cash (03/05/08
Baxter: Heparin Press Update;
12/20/02 Baxter: “Baxter
Completes Its Acquisition of ESI Lederle”)
As
part of the agreement, Baxter acquired ESI Lederle's
generic injectable products and patent-expired branded products,
such as Phenergan® (promethazine), Ativan® (lorazepam), heparin,
midazolam and fentanyl to expand its anesthesia and critical care
portfolio. Baxter also acquired the 330,000-square-foot facility
for manufacturing injectable, small-volume drugs located in
Cherry Hill
,
New Jersey
, and 1,000 employees. (12/20/02 Baxter:
“Baxter
Completes Its Acquisition of ESI Lederle”
and 10/17/02 Baxter: “Baxter’s
Sales, Earnings to Grow in Third Quarter”)
Wyeth
Global Compliance begins the first audit of the SPL-CZ facility. (03/05/08
Baxter: Heparin Press Update.)
The 2002 inspection, however, is only for manufacturing two
drugs: a simple, well-known, and well-characterized diuretic,
hydrochlorothiazide, and a simple, semi-synthetic antibiotic,
doxycycline. (The
manufacturing process for each of these drugs is very different
from the extraction process required to produce crude heparin,
which is not produced until 2004.) (04/29/08 Written
Testimony of David
Nelson, Senior Investigator for the Committee on Energy and
Commerce )
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2002
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SPL
contends that it submitted DMF detailing the quality control and
manufacturing processes for heparin API produced at the SPL-CZ
facility to the FDA. (04/29/08
Written Testimony of Robert L. Parkinson before Comm. on Energy
and Commerce.)
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2003
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Wyeth’s
Global Compliance Division finishes conducting its qualification
audit of SPL-CZ. (03/05/08
Baxter: Heparin Press Update.)
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Sept.
2003
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Baxter
contends it conducted a plant inspection of the SPL-CZ facility. (03/05/08
Baxter: Heparin Press Update.)
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Feb.
6, 2004
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Baxter
submits a NDA Prior Approval Supplement (“PAS”) for use of the
SPL-CZ facility as an alternate supplier for heparin API.
Baxter’s NDA PAS references the Drug Master File (“DMF”)
that SPL submitted to the FDA for the SPL-CZ facility. (03/05/08
Baxter: Heparin Press Update
and 04/29/08
Written Testimony of Robert L. Parkinson before Comm. on Energy
and Commerce.)
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June
8, 2004
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Per Baxter, the FDA sends letter
approving SPL-CZ as an alternate supplier for heparin. (03/05/08
Baxter: Heparin Press Update.)
It is later learned, however, that prior to said approval,
the FDA failed to inspect the Chinese facility that did not have
any history of producing a complex, biological-based product for
exportation to the
United States
. (04/29/08 Written Testimony of David
Nelson, Senior Investigator for the Committee on Energy and
Commerce )
Baxter’s
records indicate that they were aware that this plant had never
been inspected by the FDA. (04/29/08 Written Testimony of David
Nelson, Senior Investigator for the Committee on Energy and
Commerce )
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Nov.
2004
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The
SPL-CZ facility first begins to process crude heparin for Baxter.
(03/05/08
Baxter: Heparin Press Update.)
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Sept.
20, 2007
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Baxter claims to
have performed an audit of the SPL-CZ facility and approves its
continued production of API pending satisfactory responses to the
observations included in the report, (which SPL-CZ produces on
01/19/089.) (03/05/08
Baxter: Heparin Press Update.)
(However, the results of this audit differ significantly
from those reported by the FDA, which inspected the Chinese
facility only five months later and found multiple serious
violations so severe that all imports were halted from the
facility. (04/29/08 Written Testimony of David
Nelson, Senior Investigator for the Committee on Energy and
Commerce )
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Nov.
19, 2007
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Pediatric
hemodialysis patients at St. Louis Children's Hospital begin to
experience allergic-type reactions. (CDC MMWR Report: “Acute
Allergic-Type Reactions Among Patients Undergoing Hemodialysis ---
Multiple States, 2007—2008.”)
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End of
Dec. 2007
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Baxter purposes to
have first noticed an increase in the rate of allergic-type
reactions associated with its 1,000 unit/ml 10 ml and 30 ml
multi-dose heparin products, “as part of [its] normal
pharmacovigilance process.” (03/05/08
Baxter: Heparin Press Update)
Baxter is notified of problems by physicians (other than
Dr. Alex Elward at St. Louis Children’s Hospital, see 01/04/08
entry below) and some dialysis centers notify equipment
makers, thinking it is a problem with contaminated dialysis
machines. (03/13/08
Baltimore
Sun, “MD.
Native’s expertise led to drug recall.”)
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Jan.
4, 2008
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St.
Louis Children's Hospital call in its infectious-disease
specialist, Dr. Alexis Elward, to diagnose a mysterious spike in
allergic reactions to kidney dialysis. (03/13/08
Baltimore
Sun, “MD.
Native’s expertise led to drug recall.”)
Baxter
contends that it begin an investigation of heparin adverse events
at this time. (03/05/08
Baxter: Heparin Press Update.)
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Jan.
7, 2008
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The Missouri Department of Health and
Senior Services (MDHSS) notifies the CDC of the allergic-type
reactions among pediatric hemodialysis patients since November 19,
2007, at St. Louis Children’s Hospital. The CDC then solicits
reports of similar allergic-type reactions among hemodialysis
patients nationally through nephrology e-mail lists and public
health notifications. (CDC
MMWR Report: “Acute
Allergic-Type Reactions Among Patients Undergoing Hemodialysis ---
Multiple States, 2007—2008.”)
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Jan.
08, 2008
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Baxter’s
pharmacovigilance group travels to
Fargo
,
ND
to investigation adverse events. (03/05/08
Baxter: Heparin Press Update.)
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Jan.
09, 2008
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In response to its
case-finding measures, CDC is contacted by an unidentified
dialysis supply company that had received reports during the
previous 2-week period of approximately 50 similar reactions among
adult hemodialysis patients at dialysis facilities in six states.
A second unidentified supply company reports learning of similar
reactions from dialysis facilities as early as December 10, 2007.
CDC alerts the Food and Drug Administration (FDA) to the
nationwide reports of allergic-type reactions. (CDC MMWR Report:
“Acute
Allergic-Type Reactions Among Patients Undergoing Hemodialysis ---
Multiple States, 2007—2008.”)
Baxter places
inventory for both the 1,000 unit/mL 10 mL and 30mL products on
hold. (03/05/08
Baxter: Heparin Press Update.)
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Jan.
11, 2008
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Baxter contacts
the FDA about increased adverse drug experience reports at some
dialysis centers. (03/05/08
Baxter: Heparin Press Update.)
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Jan.
14, 2008
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Baxter suspends
the manufacturing of its 1,000 unit/mL multi-dose products. (03/05/08
Baxter: Heparin Press Update.)
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Jan.
16, 2008
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Baxter
communicates additional complaints to the FDA and informs that it
is initiating a recall. (03/05/08
Baxter: Heparin Press Update.)
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Jan.
17, 2008
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Baxter issues a
press release recalling nine lots of Heparin Sodium Injection
multiple-dose vials in 1000 units/mL concentrations of 10mL and
30mL vials, 5000 units/mL concentration of 10mL vials, and 10,000
units/mL for 4mL vials. (01/25/08
Baxter News Release, “Baxter Issues Urgent Nationwide Voluntary
Recall of Heparin 1,000 Units/ML 10 and 30mL Multi-Dose Vials.”)
Baxter issues its
first “Customer Letter” to heparin
“customers/wholesalers/distributors.” (01/17/08
Baxter Customer Letter)
Baxter claims to
have had contact with the FDA regarding adverse event reports on
this date. (03/05/08
Baxter: Heparin Press Update.)
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Jan.
18, 2008
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Baxter claims to
have had contact with the FDA regarding adverse event reports on
this date. (03/05/08
Baxter: Heparin Press Update.)
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Jan.
19, 2008
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Baxter claims to
have had contact with the FDA regarding adverse event reports on
this date. (03/05/08
Baxter: Heparin Press Update.)
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Jan.
22, 2008
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Baxter issues its
second “Customer Letter” to “dialysis center
nephrologists.” (01/22/08
Baxter Customer Letter)
Baxter claims to
have had contact with the FDA regarding adverse event reports on
this date. (03/05/08
Baxter: Heparin Press Update.)
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Jan.
23, 2008
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Baxter issues its
third “Customer Letter” to “renal home patients.” (01/23/08
Baxter Customer Letter)
Baxter claims to
have had contact with the FDA regarding adverse event reports on
this date. (03/05/08
Baxter: Heparin Press Update.)
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Jan.
24, 2008
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Baxter issues its
fourth “Customer Letter” with an update to heparin
“customers/wholesalers/distributors.” (01/24/08
Baxter Customer Letter)
Baxter claims to
have had contact with the FDA regarding adverse event reports on
this date. (03/05/08
Baxter: Heparin Press Update.)
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Jan.
25, 2008
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Baxter
and FDA issues a press release regarding Baxter’s recall. (01/25/08
Baxter News Release, “Baxter Issues Urgent Nationwide Voluntary
Recall of Heparin 1,000 Units/ML 10 and 30mL Multi-Dose Vials.”
and FDA 1/25/08 Press Release: “Baxter
Issues Urgent Nationwide Voluntary Recall of Hepain 1,000 Units/ml
10 and 30ml Multi-Dose Vials;”)
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Jan.
27, 2008
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Baxter claims to
have had contact with the FDA regarding adverse event reports on
this date. (03/05/08
Baxter: Heparin Press Update.)
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Jan.
28, 2008
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Baxter claims to
have had contact with the FDA regarding adverse event reports on
this date. (03/05/08
Baxter: Heparin Press Update.)
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Jan.
29, 2008
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Baxter claims to
have had contact with the FDA regarding adverse event reports on
this date. (03/05/08
Baxter: Heparin Press Update.)
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Jan.
30, 2008
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Baxter claims to
have had contact with the FDA regarding adverse event reports on
this date. (03/05/08
Baxter: Heparin Press Update.)
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Jan.
31, 2008
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Baxter claims to
have had contact with the FDA regarding adverse event reports on
this date. (03/05/08
Baxter: Heparin Press Update.)
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Feb.
1, 2008
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CDC
posts its MMWR (Morbidity and Mortality Weekly Report) “Acute
Allergic-Type Reactions Among Patients Undergoing Hemodialysis ---
Multiple States, 2007—2008”
reporting on the outbreak of acute allergic-type reactions
among patients who have undergone hemodialysis since November 19,
2007.
Baxter claims to
have had contact with the FDA regarding adverse event reports on
this date. (03/05/08
Baxter: Heparin Press Update.)
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Feb.
4, 2008
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Baxter claims to
have had contact with the FDA regarding adverse event reports on
this date. (03/05/08
Baxter: Heparin Press Update.)
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Feb.
6, 2008
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Baxter contends
that it contacted the FDA to report that the company was
contemplating an expanded recall on the multi-dose vials. (03/05/08
Baxter: Heparin Press Update.)
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Feb.
7, 2008
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Baxter initiates
hold on all single and multi dose vials. (03/05/08
Baxter: Heparin Press Update.)
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Feb.
8, 2008
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Baxter reports to
the FDA that there had been 348 unique adverse reaction case
reports, with 94% of the reports related to 1,000 unit mulit-dose
vials, 4% related to the 5,000 unit and 10,000 unit multi-dose
vials, and 2% of the reports related to the 5,000 unit single dose
vial (8 total). Three
of these eight single dose reports concerned situations where
multiple singe dose vials were used to create a large bolus dose.
Since Baxter supplies approximately half of the multi-dose vials
of heparin used in the
U.S.
, Baxter & the FDA decide not to proceed with an expanded
recall. (03/05/08
Baxter: Heparin Press Update.)
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Feb.
9, 2008
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Baxter claims to
have had contact with the FDA regarding adverse event reports on
this date. (03/05/08
Baxter: Heparin Press Update.)
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Feb.
11, 2008
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Baxter and FDA
issue press releases indicating that Baxter has temporarily
stopped manufacturing multiple-dose vials of injectable heparin
due to the potentially life-threatening adverse and allergic
reactions and incidents of hypotension that were reported and re
decision not to proceed with expanded recall. (Baxter
2/11/08 News Release, “Baxter Provides Update on Heparin
Reactions.” and FDA
2/11/08 Press Release: “Baxter’s Multiple-dose vial Heparin
Linked to Severe Allergic Reactions.”)
FDA
also holds its first press conference on the same issue, (2/11/08
FDA Press Conference Transcript), issues a Public
Health Advisory and posts a “Question
and Answers” webpage.
Baxter issues its
fifth and sixth “Customer Letters” to renal home patients and
health care professionals entitled “Important Heparin Safety
Information.” (02/11/08
Baxter Customer Letter to Renal Home Patients and 02/11/08
Baxter Customer Letter to Health Care Professionals)
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Feb.
13, 2008
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Baxter claims to
have had contact with the FDA regarding adverse event reports on
this date. (03/05/08
Baxter: Heparin Press Update.)
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Feb.
14, 2008
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Zoll,
Kranz & Borgess, LLC is the first law firm in the
nation to file suit against Baxter Healthcare Corporation and
other related companies regarding the contaminated heparin.
(For sample complaint, click
here.)
Baxter claims to
have had contact with the FDA regarding adverse event reports on
this date. (03/05/08
Baxter: Heparin Press Update.)
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Feb.
15, 2008
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Baxter claims to
have had contact with the FDA regarding adverse event reports on
this date. (03/05/08
Baxter: Heparin Press Update.)
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Feb.
18, 2008
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FDA holds its
second heparin press conference. (2/18/08
FDA Press Conference Transcript.)
The FDA admits that the SPL-CZ Chinese facility was never
inspected by the FDA.
Baxter claims to
have had contact with the FDA regarding adverse event reports on
this date. (03/05/08
Baxter: Heparin Press Update.)
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Feb.
19, 2008
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APP announces its
ability to meet the heparin demand. In
response, Baxter assembled info on its own supply situation,
including supply that might become available from non-SPL sources.
(03/05/08
Baxter: Heparin Press Update.)
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Feb.
20, 2008
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International
Compliance Team for the U.S. FDA begins a five day inspection of
the Changzhou SPL facility.
Baxter claims to
have had contact with the FDA regarding adverse event reports on
this date. (03/05/08
Baxter: Heparin Press Update.)
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Feb.
21, 2008
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Baxter claims to
have had contact with the FDA regarding adverse event reports on
this date. (03/05/08
Baxter: Heparin Press Update.)
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Feb.
22, 2008
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Baxter claims to
have had a conference call with the FDA on this date to discuss
expansion of the recall in light of APP’s announcement about
their ability to supply the market.
Baxter claims the FDA (including the Office of Drug
Shortage) wanted some time to examine the issue including market
supply of all heparin products. (03/05/08
Baxter: Heparin Press Update.)
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Feb.
26, 2008
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The International
Compliance Team for the U.S. FDA releases its inspection report of
the Changzhou SPL facility. The partially redacted
report
of the inspection establishes
severe deficiencies in the companies manufacturing and inspection
processes.
Baxter claims to
have had contact with the FDA regarding adverse event reports on
this date. (03/05/08
Baxter: Heparin Press Update.)
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Feb.
27, 2008
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Baxter claims to
have received clearance from the FDA to recall all of its heparin
products from the market. (03/05/08
Baxter: Heparin Press Update.)
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Feb.
28, 2008
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In light of
continuing reports of comparable adverse events associated with
the use of multiple-dose heparin vials not within the initial
recall, Baxter and the FDA issue additional press releases
recalling all remaining lots and doses of its multiple-dose vials,
single dose vials, and HEP-LOCK heparin flush products. (FDA
2/28/08 Press Release: “Baxter to Proceed with Recall of
Remaining Heparin Sodium Vial Products” and
Baxter
02/28/08 Press Release: “Baxter to Proceed with Recall of
Remaining Heparin Sodium Vial Products.”)
The same day, the
FDA holds its third heparin press conference providing an update
of the ongoing investigation (2/28/08
FDA Press Conference Transcript), updates its Public
Health Advisory and creates a “Public
Health Update.”
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Feb.
29, 2008
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Baxter issues
three “Customer Letters” to renal home patients,
customers/wholesalers/distributors/dialysis centers, and one
entitled “HEP-LOCK (Heparin Lock Flush Solutions, USP) and HEP-LOCK
U/P (Preservation-Free Heparin Lock Flush Solution, USP”). (02/29/08
Baxter Customer Letter to Renal Home Patient, 02/29/08
Baxter Customer Letter to Customer/Wholesaler/Distributor/Dialysis
Center, and 02/29/08
Baxter Customer Letter: “HEP-LOCK (Heparin Lock Flush Solutions,
USP) and HEP-LOCK U/P (Preservation-Free Heparin Lock Flush
Solution, USP”)
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March
05, 2008
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The
FDA holds its fourth heparin press conference providing an update
of the ongoing investigation, including an announcement that the
contaminate is a “heparin-like substance.” (03/05/08
FDA Press Conference Transcript.)
Baxter
releases its first “Press Update” on the heparin
investigation. (03/05/08
Baxter: Heparin Press Update.)
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March
06, 2008
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The
FDA holds its fifth heparin press conference providing an update
of the ongoing investigation, including an announcement that
German Regulatory authorities had recalled heparin manufactured by
a German company after reports of similar adverse events. (03/06/08
FDA Press Conference Transcript.)
The
FDA also posts webpages regarding screening methods to detect the
contaminate including “Impurity
Evaluation of Heparin Sodium by Capillary Electrophoresis”
and “Impurity
Evaluation of Heparin Sodium by H-NMR Spectroscopy,”
(later updated on 4/8/08).
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March
07, 2008
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The
FDA updates its “Questions
and Answers” webpage.
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March
10, 2008
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The FDA announces
that all heparin coming into the
U.S.
from SPL-CZ is subject to an import alert (import alert 66-40).
(04/29/08 Written
Testimony of Janet Woodcock, M.D. before Comm. On Energy and
Commerce.)
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March
11, 2008
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Three Japanese
companies recalled Heparin made with USP Active Pharmaceutical
Ingredient supplied by SPL. (3/11/08 NY Times Article: “Japan:
Heparin Recalled as Precaution.”)
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March
14, 2008
|
The FDA publishes
online three demonstrative exhibits for the public entitled,
Adverse
Reactions, Analyzing
the Contaminant, and Import
Alert.
The same day, the
FDA also holds its sixth heparin press conference announcing that
20 of the 28 samples taken from Changzhou SPL plant had contained
the contaminant and describing the preventative steps that the FDA
is putting in place at
America
’s borders. An import alert is issued and new testing procedures
are put in place. (03/14/08
FDA Press Conference Transcript.)
The FDA also
issues an assignment to its field staff requiring examination and
sampling of all heparin sodium API coming into the
U.S.
, except sodium heparin API being shipped to firms where the FDA
“knows the recommended tests will be conducted.”
(04/29/08 Written
Testimony of Janet Woodcock, M.D. before Comm. On Energy and
Commerce.)
Baxter releases
its second “Press Update” on the heparin investigation.
(Baxter
03/14/08 Press Release.)
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March
17, 2008
|
SPL-CZ submits its
response to the FDA’s 483 (inspection). (04/29/08
Written Testimony of David G. Strunce before Comm. On Energy and
Commerce.)
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March
19, 2008
|
FDA announces in it seventh heparin
press conference that it had identified the contaminant as
over-sulfated chondroitin sulfate (“OSCS”). (03/19/08
FDA Press Conference Transcript.)
Per the FDA, it costs approximately $20/kilogram (kg) to
produce OSCS versus $2,000/kg to produce crude heparin. It
is later learned, however, that the FDA failed to inspect the
Chinese facility prior to approval. (04/29/08 Written Testimony of
David
Nelson, Senior Investigator for the Committee on Energy and
Commerce .)
Baxter releases
its third “Press Update” on the heparin investigation.
(Baxter
03/19/08 Press Release.)
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March
20, 2008
|
American
Health Packaging (AHP), a subsidiary of AmerisourceBergen
Corporation recalls 1,421 units (25 vials per unit) of 10000 USP
units/ml heparin sodium injection 1ml vials as part of the broader
February 29, 2008 recall of Heparin products made Baxter. The
vials were manufactured by Baxter and then placed by AHP into
individually labeled bags for use in pharmacy automation
equipment. The AHP packages where sold to five hospitals in
Georgia
and
California
. (FDA
03/20/08 Recall Notice: “American Health Packaging Announces a
Recall of Approximately 1,400 Units of Heparin Sodium Vial
Products as Part of Broader Baxter Recall”)
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March
21, 2008
|
B.
Braun Medical Inc. recalls 23 lots heparin solution manufactured
and distributed by B. Braun Medical Inc. nationwide and to
Canada
after being notified by its supplier, SPL, that one lot of Heparin
Sodium, USP Active Pharmaceutical Ingredient acquired by B. Braun
Medical Inc. was contaminated. (FDA
03/21/08 Recall Notice: “B. Braun’s Supplier Recall of Heparin
API Prompts Voluntary Recall of Heparin Solutions.”)
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March
25, 2008
|
French,
Danish and Italian recall batches of Heparin or its active
pharmaceutical ingredient. (03/26/08
Chicago
Tribune Article: “Heparin
Recall Grows to Europe.”)
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March
28, 2008
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Covidien,
formerly Tyco Healthcare, recalls 32 lots of pre-filled syringes
containing heparin due to a notification received from its
supplier, SPL, that two lots of Heparin Sodium USP Active
Pharmaceutical Ingredient acquired by Covidien was contaminated. (FDA
03/28/08 Recall Notice: “Covidien Initiates Voluntary Recall of
Pr-Filled Syringes Containing Heparin.”)
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March,
2008
|
SPL recalls lots
of their heparin API that were distributed to a number of medical
device manufacturers. Products made from those lots were
adulterated by the contaminant. (04/08/08
FDA: Notice to Manufacturers and Initial Distributors of Medical
Devices that May Contain Heparin or are Heparin-Coated.”)
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|
April
08, 2008
|
FDA issues its first adverse event
report of 103 reports of patients who died while taking heparin
since January 1, 2007, with 62 of those deaths involving allergic
reactions or hypotension. (This was later updated on 04/21/08 to
131 deaths with 81 of those death involving allergic/hypotensive
symptoms.) (FDA 4/08/08
“Information on Adverse Event Reports and Heparin.”)
FDA also
issues an “Important
Notice to Manufacturers and Initial Distributors of Medical
Devices That May Contain Heparin or are Heparin-Coated,”
warning of the serious adverse events potentially related
to contaminated heparin and urging that all imported lots of
heparin sodium API be tested by laboratories capable of performing
various FDA recommended test methods. The FDA also requested that
all manufacturers to submit to it within five (5) working days any
adverse reactions related to the use of heparin containing or
coated devices that may have caused or contributed to a death,
serious injury, or reports of malfunctions in which the
malfunction of the device was likely to cause or contribute to a
death or serious injury if it were to occur.
The FDA also
updates its webpage on the screening method “Impurity
Evaluation of Heparin Sodium by H-NMR Spectroscopy.”
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|
April
15, 2008
|
Andrew
von Eschenbach, the head of the U.S. Food and Drug Administration,
states before the Senate Agriculture, Rural Development and
Related Agencies Appropriations Subcommittee on the “2009 Budget
Request for FDA” that the contamination of the heparin was, ``we
suspect, done by virtue of economic fraud.” (Transcript
of Eschenbach Testimony at 04/15/08 Senate Appropriations
Subcommittee Hearing and Video
of Hearing)
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|
April
17 and 18, 2008
|
The
FDA convenes a meeting with international counterparts that have
been working on the heparin issue to discuss laboratory
analysis/data interpretation and good manufacturing practice (GMP)
inspections. Representatives from the regulatory autorities of
Australia
,
Canada
, china,
Denmark
,
European Union
,
France
,
Germany
,
Italy
,
Japan
,
Singapore
and
Switzerland
attend, as well as representatives of the U.S. Pharmacopoeia,
European Pharmacopoeia, and the Massachusetts Institute of
Technology. (04/29/08 Written
Testimony of Janet Woodcock, M.D. before Comm. On Energy and
Commerce.)
|
|
April
21, 2008
|
FDA issues an
update report on the number of reported deaths. According to the
FDA, as of April 21, 2008, there have been 131 reports of death in
patients receiving heparin since January 1, 2007, with 123 of said
deaths reported to the FDA on or after January 1, 2008. (FDA
4/21/08
Updated “Information on Adverse Event Reports and Heparin.”)
Out of the 131 reported deaths, 81 of the reports of death
included one or more allergic symptom(s) or symptoms of
hypotension, with 78 of said deaths reported to the FDA on or
after January 1, 2008.
The same day the
FDA issues a strong warning letter to the Changzhou SPL facility
outlining the “significant deficiencies” at the facility. The
FDA gives Changzhou SPL 30 days to respond and refuses to allow
shipments of the drug until the violations have been corrected.
(FDA 04/21/08 warning
letter.)
The FDA also holds
its eighth heparin press conference regarding the status of the
investigation and testing for over-sulfated chondroitin sulfate,
(04/21/08
FDA Press Conference Transcript), and posts a map
of “Countries
with Contaminated Heparin API.”
Baxter releases
its fourth “Press Update” on the heparin investigation.
(Baxter
04/21/08 Press Release.)
|
|
April
23, 2008
|
The New England
Journal of Medicine publishes the results of a study establishing
a link between the contaminant and the reported adverse reactions.
The article is entitled, “Contaminated
Heparin Associated with Adverse Clinical Events and Activation of
the Contact System.” (Available online for a charge,
by clicking
here.)
|
|
April
25, 2008
|
Baxter CEO Bob
Parkinson discussed heparin at a 2008 quarterly town hall meeting
for Baxter employees worldwide.
(Video.)
|
|
April
29, 2008
|
Leroy Hubley,
Colleen Hubley and Johanna Staples, (all clients of Zoll, Kranz
& Borgess, LLC) speak before the U.S. House Commerce Committee
on Energy and Commerce at a hearing entitled, “The Heparin
Disaster: Chinese Counterfeits and American Failures.”
Written
Testimony of:
·
Leroy
Hubley
·
Colleen
Hubley
·
Johanna
Staples
·
David
Nelson, Senior Investigator for the Committee on Energy and
Commerce
·
Janet
Woodcock, Director of the FDA’s Center for Drug Evaluation
·
David
Strunce, CEO of Scientific Protein Laboratories
·
Clive
Meanwell, CEO of The Medicines Co.
Video:
Panel
I (Witnesses: David Nelson, Senior Investigator for the
Committee on Energy and Commerce, Colleen Hubley, Leroy Hubley,
and Johanna Marie Staples)
Panel
II (Witnesses: Janet Woodcock, Director of the FDA’s Center
for Drug Evaluation and Research, Deborah M. Autor, Director of
FDA’s Office of Compliance, and Regina T. Brown, Consumer Safter
Officer of the FDA’s Division of Field Investigations)
Panels
III and IV (Witnesses: Robert Parkinson, CEO and President of
Baxter International, Inc., David Strunce, CEO of Scientific
Protein Laboratories, Yan Wang, Ph.D., Vice President of Business
Development and Research at Scientific Protein Laboratories, and
Clive Meanwell, CEO of The Medicines Co.)
Text
of Hearing
|
|
May
07, 2008
|
Medtronic, Inc.
announces that it is recalling selected products with a “Carmeda
BioActive surface” that were manufactured with heparin found to
have been contaminated with oversulfated chondroitin sulfate. The
affected devices are disposable products used during
cardiopulmonary bypass (CPB) for heart surgeries. Affected
products include blood oxygenators, reservoirs, pumps, cannulae,
and tubing packs. (FDA
05/07/08 Recall Notice: “Medtronic Initiates Voluntary Field
Actions for Selected Heparin-coated Products Used During
Cardiopulmonary Bypass.”)
|
|
May
09, 2008
|
FDA issues a “Follow-up
Notice to Heparin Device Manufacturers and Initial Distributors,”
asking businesses for additional information, including, but not
limited to, information regarding their medical devices that
contain heparin, the source of said heparin, what actions are
being taken to ensure the minimization of risk to the public and
to protect against contamination in the future.
|
|
May
12, 2008
|
Atrium
Medical Corporation announces that it is initiating a voluntary
and precautionary recall of selected lots of HYDRAGLIDE™ Brand
Heparin-Coated Thoracic Drainage Catheters. Limited lots of Atrium
heparin-coated Hydraglide Thoracic Catheters were manufactured
with heparin found to have been contaminated with oversulfated
chondroitin sulfate (OSCS). (FDA
Press Release, “Atrium
Initiates Voluntary Recall Action Regarding Hydraglide Brand
Heparin-Coated Thoracic Drainage Catheters used for
Autotransfusion during Cardiopulmonary Bypass Surgery.”
Baxter issues its
tenth and eleventh “Customer Letters” to dialysis centers and
hospitals entitled “Important Recall Reminder.” (05/12/08
Baxter Customer Letter: Dialysis Center Important Recall Reminder
and 05/12/08
Baxter Customer Letter: Hospital Important Recall Reminder)
|
|
May
15, 2008
|
FDA updates its
MedWatch info on Medtronic, advising that “the company is
advising customers that selected lots of Trillium-coated products
were also manufactured with heparin containing OSCS. The amount of
heparin on the product is significantly lower than that contained
on the Carmeda product. Based on current data, the benefit of
using the affected products outweighs any potential risk to
patients. The maximum possible patient exposure to heparin from
Trillium is extremely low; therefore, customers can continue to
use the affected Trillium products until a replacement is
available.” (FDA
MedWatch 2008 Safety Alerts)
|
|
May
29, 2008
|
Zoll, Kranz &
Borgess, LLC argue before the United States Judicial Panel on
Multi-District Litigation in
Asheville
,
North Carolina
, that the Heparin Products Liability Litigation in federal courts
across the country be transferred to the Northern District of
Ohio, (located in
Toledo
,
Ohio
) before the Honorable Chief Judge James G. Carr.
Other districts, including the Southern District of
Illinois, District of New Jersey, Southern District of Florida,
the District of Puerto Rico, and the Northern District of
California, were suggested by Baxter Healthcare Corp., Scientific
Protein Laboratories, LLC, and other parties.
|
|
June
3, 2008
|
The FDA announces
that there have been 11 deaths and 86 cases of harmful side
effects since January 1, 2008 that have been linked to use of
medical devices containing heparin. (06/03/08 FDA web update:
"Questions
and Answers on Heparin, Medical Devices and In-vitro Diagnostic
Assays.") The heparin in the majority of these
medical devices were found to be contaminated with OSCS.
|
|
June
6, 2008
|
The United States
Judicial Panel on Multi-District Litigation issues a transfer
order, transferring the Heparin Multi-District Litigation MDL No.
1953 to the Northern District of Ohio, before the Honorable Chief
Judge James G. Carr. (Order.)
|
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