FDA report on Searle's submission for NutraSweet approval 1977 - Part 6

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20.) Fred Hunter, Technician.

 

Since the Task Force investigation in 1975, there has been a

major internal reorganization. The current organization of

Worldwide Pharmaceutical Research & Development is attached

as Exhibit #3. The only change has been the resignation

of Dr. Robert A Moe, Executive Vice-President. Mr. George

V. O'Bleness, Corporate Vice-President, is temporarily filling

this position.

 

Organizational charts for Preclinical Research and Development

of Products safety Assessment are also attached as Exhibits

4 & 5. There have been no changes in these areas to date.

 

Worldwide Pharmaceutical Research and Development is respon-

sible for research and development of Aspartame and is a part

of the Pharmaceutical/Consumer Product group. The group

President is O.B. Parrish, who reports to James A Buzard,

Executive Vice-President for Operations, G.D. Searle & Co.

The current corporate structure of G.D. Searle & Co. has been

discussed under History of Business.

 

P.T. No. 988S73, 115 Week Oral Tumorigenicity Study in the Rat

was conducted between November 10\971 and February 1974. The

final FDA submission was dated September 1974. Following is

a yearly breakdown of key personnel during this study:

 

1971

 

Robert Moe - Director, Biological Research Department.

Robert McConnell - Director, Pathology - Toxicology Section

K.S. Rao (June, 1971) - Manager, Toxicology Section.

Tony Martinez - Toxicology Laboratory Supervisor.

 

1972

 

Robert Moe - Director Biological Research Department

(January through April)

 

F. Saunders - Director, Biological Research Department (May

through December).

 

Robert McConnell - Director, Pathology - Toxicology Section

 

K.S. Rao - Manager, Toxicology Section.

 

Tony Martinez - Toxicology Laboratory Supervisor.

 

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1973 (January to June)

 

Francis Saunders - Director, Biological Research Department.

 

Robert McConnell - Director, Pathology-Toxicology Section.

 

K.S. Rao - Manager, General Toxicology Laboratory.

 

Tony Martinez - Toxicology Laboratory Supervisor.

 

1972 (July to December)

 

Paul Klimstra - Director, Pre-clinical Research & Development

Department.

 

Robert McConnell - Director, Pathology-Toxicology Section.

 

K.S. Rao - Manager, General Toxicology Laboratory.

 

Tony Martinez - Toxicology Laboratory Supervisor.

 

1974

 

Paul Klimstra - Director, Pre-clinical Research & Development

Department.

 

Robert McConnell - Director, Pathology-Toxicology Section.

 

K.S. Rao - Manager, General Toxicology Laboratory.

 

D. Semler - Toxicology Laboratory Supervisor.

 

A more complete listing of personnel in the Department of

Science, from 1971-1975 is attached as Exhibit No. 64.

This includes the Pathology - Toxicology Department and other

ancillary areas.

 

Curriculum vitae for individuals performing significant func-

tions in the study are attached as Exhibit 12.

 

MANUFACTURE AND TESTING OF SC-19192

 

Seven batches of SC-19192 (diketopiperazine) were used in this

study. All batches were manufactured in-house by Searle Chemist

jack Drogt. The lot numbers, analytical numbers, and quantities

are as follows.

 

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Lot Number Analytical Number Quantity (After Milling)

 

1R 6906

2R 7274

3R 7273

4R 7291 This data removed in released report

5R (JDR-5-18A) 9129

6R (JDR-5-30A) 9805

7R (JDR-5-30B) 9829

 

Bach records covering the manufacture of lots 1R through 5R were

reviewed. Batch records for lot 6R and 7R could not be located

by Searle personnel. analytical reports for all seven batches

were reviewed. Copies of the batch records and analytical records

were obtained and are attached to this report, along with copies

of pages from Jack Drogt's laboratory notebook, and other labora-

tory notebooks relating to the analysis of lots 1R through 7R of

DKP. (See Exhibits 13-23.)

 

We obtained copies of three different specification sheets for

DKP. (See Exhibits 16-18.) We could not determine with certainty

which of the three specifications sheets was in effect at the time

that the 7 lots of DKP used in this study were assayed, because

only one of the three specification sheets was dated. This

resulted in ambiguities for two of the parameters measured:

melting point and identity (IR Spectrum). Specification memorandum

dated Dec. 4, 1969 listed a melting range of 252-256 degrees

C. Another specification sheet (not dated) entitled "Tentative

Specification For SC-19192", listed a melting range of 241-246

degrees C. A third specification sheet entitled "Specification

for SC-19192, Specification No. C 40606C" (not dated) listed

a melting range "at about 243 degrees C.".

 

For identity (IR Spectrum) the first sheet (dated 12/4/69) speci-

fied that "The reference standard shall be considered to be

TJT-12-32 until something better comes along". The second and

third sheets specify that the DKP "Conforms to IR #2358".

 

No data was made available as to dates, method of preparation and

authentication of DKP references standards used.

 

Searle attorney Roger Thies was contacted about this point

Aug. 1, 1977 and said he would attempt to obtain information

regarding this point but later registered doubt as to whether

anything would be found.

 

We asked Searle personnel to tell us which of the specification

sheets was valid for the DKP used in study E-77/78. We were

 

Continue to Part 7

 

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