Table 5.2.1

Product Quality Complaint Rate by Product

Definition‘Product Quality Complaint’ = Any complaint received that if confirmed would result in a failure to meet product specifications. This metric should count both confirmed and unconfirmed complaints of this type.
How to CalculateComplaints per million (cpm) = Quality Complaints Received/ Million Units Distributed
Numerator = All Complaints received at manufacturer in the reporting month
Denominator = Six Months Rolling Average of Individual Units Distributed containing drug product in the reporting month/one million
How to ReportBy Product only
Reporting should include both confirmed and unconfirmed complaints
Firm should comment on or explain any trends observed or any seasonal effects.
Unintended Consequences and Recommended MitigationManufacturers might re-define Complaints vs. Inquiries.
Mitigation: Complaints definitions should not change in companies as a consequence of the reporting
In general complaints received will be lagging compared to the product units distributed. Hence, variations in calculated results can be caused by variations in distribution pattern.
Mitigation: Companies can comment on this in the reporting.
Different countries have different ‘cultures’ for complaint ‘threshold’. Mitigation: The reporting is for product sold in the US only.