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FDA Warning Letters, Form 483 Observations, Establishment Inspection Reports

Download more than 400 documents: SOPs, examples, templates, checklists, FDA waning letters, 483 inspectional observations, FDA and other official guidelines, presentations/publications from FDA personnel.

Important: Warning letters should be interpreted in the context of full content. Just looking at extracts may be misleading. And sometimes they include good advice from the FDA not mentioned in the extract

 

W-213

Keywords: Method Verification, Compendial Methods, System Suitability Testing

  • Primary deviations: Compendial methods not verified, no system suitability testing performed .
  • Examples:
    -The test methods performed for heparin sodium USP have not been verified to ensure suitability under actual conditions of use.
    - Specifically, you have failed to conduct adequate verification of USP compendial test methods as applied to the production of your firm's API.
    - The data you provided in your March 17,2008, response did not include information about the suitability, accuracy, and detection limits of certain test methods for API, such as the protein test method, used by your firm
    - In addition, your firm had not conducted suitability testing of the method to determine the limit of detection for the method.
    - You assert that USP <1226>, Verification of Compendia1 Procedures, states that verification is not required for basic cornpendial test procedures that are routinely performed unless there is an indication that the compendial procedure is not appropriate for the article under test.
    - We disagree with your assertions that verification is not required for those USP test methods used by your firm

 

W-205

Keywords: Software validation, revalidation, quality policy, water purification

  • Primary Deviations: Inadequate software validation, quality policy not implemented, water purification system not validated, no revalidation after changes, no purchasing control procedures.
  • Examples:
    - Failure to have management with executive responsibility to ensure the quality policy has been fully implemented and maintained [21 CFR 820.20(a)]. Admittedly, you lack a Quality Plan and a management representative and have continued to operate since 2004
    -Failure to validate your software used for fluid delivery and heat disinfection in your water purification systems [21 CFR 820.70(i) and (b)]. For example, implementations of remote changes in operating parameters change the output of the system. These types of changes require re-validation of the system. You failed to follow your own procedure for change controls when critical limits were changed to suit a client's needs.
    - Failure to validate your water purification systems
    - Failure to establish and maintain purchasing control procedures [21CFR 820.50].
    - There are no incoming component specifications for acceptance and no supplier quality agreement

 

W-204

Keywords: Software validation, acceptance criteria, validation report

  • Primary Deviations: Inadequate validation. No justification why failed test results have been accepted.
  • Examples:
    - Failure to establish and maintain adequate procedures for validating the device software design to conform to the intended uses. For example: The validation results do not meet the pre-determined acceptance criteria, and there was no documentation why the results were acceptable. The validation reports do not contain an evaluation of the validation data and activities. Nor does it contain validation analyses and conclusion.

 

W-202

Keywords:  Design changes, design changes, software changes, revalidation, risk analysis, software testing, code testing, incoming products

  • Primary Deviations: No validation to verify effectiveness of software design changes, no revalidation after software change, no safety risk analysis, inadequate software test protocols and procedures, inadequate incoming product testing
  • Examples:
    - Failure to establish and maintain procedures for the identification, documentation, validation or verification, review, and approval of design changes before their implementation
    - There were no validation test protocol and test results to verify the effectiveness of the software design changes. This ECN did not document or reference design inputs (complaints, service requests, internal engineering testing, etc.) that led to these software design changes.
    - We noted that an engineering test protocol entitled "AV1 System Test Specification and Report Form - ECR 20051028," Revision 1, dated 7/24/06, was in still "Draft" at the time of the inspection and did not document specific test instructions, acceptance criteria, and the report summary to verify that the "software bugs" had been fixed.
    - Your firm was unable to produce records of design validation results, including software validation, to prove that the Best Pro 1 device meets its design specifications for the four treatment modes
    - Your firm failed to conduct and document adequate risk analyses that discuss the safe use of your devices with/without their accessories
    - Your firm's "Memo to File" for the software validation of the Best Pro 1 Device, prepared and dated 4/18/07 during the inspection, and the Software Validation Report, Revision 2, dated 11/7/06, for the Med Best, Med Sport, and Best Pro 1 Devices only document the general functional test requirements without attaching or referencing their software codes, software code testing, I/O (Input/Output) interface testing between the hardware and software, and the actual test results for each of the functional test requirements listed in these two documents
    - Failure to establish and maintain adequate acceptance procedures, including inspections, tests, or verification activities, for incoming product and for documenting the acceptance or rejection of the incoming product

W-201

Keywords: Software validation, Spreadsheets, CAPA, Incoming product testing

  • Primary Software not validated, spreadsheets not validated, implementation of corrective action too late, no procedures to ensure the quality of incoming products, CAPA not documented, CAPA not documented
  • Examples:
    -  Software used as part of the production quality system was not validated for its intended use according to an established protocol [21 C.F.R. 820.70(i)]. Specifically,
    (a) Spreadsheets intended to check for outliers and calculate mean, SC, % CV, value assignments for finished devices.
    (b) Complaint handling software
    (c) Quantrol database program
    - Your response to this observation appears to be adequate but we are concerned that the corrections are scheduled for completion in the fourth quarter of 2007. Your response should explain the need for this length of time.
    - Procedures to ensure that all purchased or otherwise received product and services conform to specified requirements were not established
    - Specifically, independent laboratories evaluated production lots for the purpose of contributing to the device value assignments. Those laboratories were not on the approved vendor list.
    - Corrective and preventive action activities were not documented, including the actions needed to correct or prevent recurrence of nonconforming product and other quality problems, and implementation of corrective and preventive actions.
    - Specifically: (b) Temperature recording charts for [redacted] indicated temperatures were outside the acceptable range on at least four (4) occasions. The corrective action required investigating the effect of temperature fluctuations on the product when the freezers were not within the acceptable range. This evaluation was not performed.

 

W-200

Keywords:  Process validation, automated systems, software validation, root cause, bio-burden, environmental conditions not controlled, equipment calibration

  • Primary Deviations: Processes not validated, automated and semi-automated systems not validated, software not validated, root case of failures not investigated, equipment calibration not documented.
  • Examples:
    - Failure to validate a process whose results cannot be fully verified by subsequent inspection and test-
    - The filling, capping, packaging, and sealing processes, which utilize semi-automated and automated equipment, are not validated. In addition, the software applications controlling these processes are not validated for their intended uses.
    - The software controlling the capping processes has not been validated
    - No investigation was conducted under the firm's CAPA system to determine the root cause for spikes in bioburden
    - No investigation was conducted under the firm's CAPA. system to determine the root cause for the process water failing conductivity testing
    - Failure to establish and maintain adequate procedures to control environmental conditions
    -  Failure to document equipment identification, calibration date, the individual performing the calibration, and the next calibration dat

 

W-199

Keywords: Design validation, software validation, risk analysis for risk analysis, testing, code reviews, training, service calls

  • Primary Deviations: No procedure for design validation, software validation and risk analysis, structural testing not documented, validation of compiler not documented, independent code reviews not documented, personnel taking service calls not trained
  • Examples:
    - Failure to establish and maintain adequate procedures that ensure design validation to include software validation and risk analysis, where appropriate, as required by 21 CFR 820.30(g).
    - For example: The firm failed to document structural (white box) testing of its P.I.N. software, including independent code reviews, and the firm lacks documentation of validation of its compiler.
    - Failure to ensure that all personnel are trained to adequately perform their assigned responsibilities, as required by 21 CFR 820.25(b). For example, training of individuals who take service calls is inadequate since they are responsible for identifying complaints and separating them from other issues in a uniform and timely manner; however, they are not accurately identifying all complaints.

W-198

Keywords:  Software validation, failure investigation, computer access, audit trail, cleaning validation,  CAPA, stability testing, impurity testing

  • Primary Deviations: No impact analysis of actual batch problems on distributed products, drug products not tested for impurities or degradation products, suggested time for corrective action too late.
  • Examples:
    - Appropriate controls are not exercised over computers or related systems to assure that changes in analytical methods or other control records are instituted only by authorized personnel [21 CFR 211.68(b)].
    - Specifically, a) There was a failure to validate the [redacted] software to assure that all data generated by the system was secure. This software runs the laboratory HPLC equipment, generates and stores data, and performs calculations during testing of raw materials, in-process materials, finished products, and stability samples.
    - b) User access levels for the [redacted] software were not established and documented. Currently, laboratory personnel use a common password to gain access to the system and there are no user access level restrictions for deleting or modifying data.
    - Furthermore, your system does not have an audit trail to document changes
    - Regarding computer validation and security issues, you did not provide a time frame for writing and implementation of a computer security SOP. Your response regarding data back-up indicated that a separate server was being considered and would be implemented by "[redacted]" We believe this date was to have read [redacted]. Please explain why this correction cannot be completed in a more timely fashion
    - Based upon your response, it appears that investigations of the Out-of-Specification results cited on the FDA-483 have still not been conducted and documented, nor have you assessed whether any of the failures cited may also affect marketed product lots, for instance, in terms of the ability of the marketed lots to meet all specifications throughout the labeled expiry period
    - Evaluations were not conducted at least annually to review records associated with a representative number of batches, whether approved or rejected
    - Drug products manufactured by your firm have not been evaluated for the presence of impurities and degradation products

W-197

Keywords: Software validation, trend analysis, complaint software, non-conforming products

  • Primary deviations:  Trend analysis and complaint software not validated,. use of non-conforming product not justified
  • Examples:
    - The validation of the software used to perform the trend analysis has not been provided to support your firm's claim that the software can be used effectively to prevent the firm from overlooking complaints. In addition, you have not addressed how you corrected the observations that were made during the FDA inspection. Specifically, you have not provided the documentation of the investigation into the complaints that were identified in the FDA-483. Please provide for FDA review the documentation of investigation into the complaints, revised procedure QSP8.2-2 "Customer Complaints," and the software validation that was performed on the complaint handling software used for trend analysis.
    - -Your firm's response dated 11/09/2006 is not adequate. You stated in your response that you have updated QSP 8.2-2 "Customer Complaints" and revised the customer complaint handling software to allow for trend analysis based on malfunction code. You have not provided-a copy of QSP 8.2-2 "Customer Complaints" for FDA review.
    -  Failure to document the justification for use of the nonconforming product and the signature of the individual(s) authorizing the use

 

W-196

Keywords: Software change,  quality policy, quality system, supplier evaluation, consultant evaluation, incoming products, effectiveness of CAPA,

  • Primary deviations:  Effectiveness of CAPA not verified, hardware and software fault conditions during factory testing and clinical use not investigated, quality policy and quality system not implemented, no or inadequate procedures to ensure the quality of incoming products, no or inadequate procedures to evaluate suppliers, contractors and consultants, no follow up of problems with quality of incoming products, source of quality problems not evaluted
  • Examples:
    -  Failure to establish and maintain procedures for verifying and validating the corrective and preventive action
    - Failure to have management with executive responsibility to ensure the quality policy has been fully implemented
    - Simply replace malfunctioned pressure monitors and pumps, or any other defective components during factory testing, site installation, and subsequent service calls of analyzers is not an effective solution, and cannot be effectively verified nor validated without investigating all possible hardware and software fault conditions occurring during factory testing and field clinical use of the analyzers.
    - Failure to establish and maintain adequate procedure to ensure that all purchased or otherwise received product and services conform to specified requirements, and to include evaluation of supplier, contractors, and consultants, as required by 21 C.F.R. § 820.50. For example, your firm rejected defective components during incoming and finished device testing, documented nonconforming material reports for rejected components, and then sent supplier corrective action reports to your suppliers to notify them of quality issues. However, your firm failed to collectively use these sources of information to re-evaluate the overall quality rating your suppliers as required by your procedures. Additionally, despite the fact that your firm documented negative quality data for the pressure monitors and pumps, your firm has not adequately evaluated the ability of the two suppliers to meet your firm's requirements.
    - Failure of the management with executive responsibility to ensure that an adequate and effective quality system has been fully implemented and maintained at all levels of the organization, as required by 21 C.F.R. § 820.20. For example, your firm's management has not effectively implemented adequate and global corrective actions in a timely manner to correct quality issues across your analyzer product lines. The FDA's current inspection involved the issuance of an 11-item FDA-483 to your firm.
    - Failure to establish and maintain procedures for the analysis of all sources of quality data to identify existing and potential causes of nonconforming product or other quality problems

 

W-195

Keywords: Software validation, software retesting, data integrity, data migration, change control, document changes

  • Primary Deviations: No procedures for design changes, incomplete software validation, SW functions not tested without justification, failure to validate data integrity for data file migration, correct functioning of migration from earlier versions not updated, only from immediate predecessor, effectiveness of CAPA not verified
  • Examples:
    - Failure to establish and maintain procedures for the identification, documentation, validation, or where appropriate verification, review, and approval of design changes before their implementation
    - The software verification/validation for the pump operating software version 4.00.04 and MDL software version 5, and the design of the hardware components associated with the PCA/PCEA module were not completed at the time the re-designed Spectrum pump was released for manufacturing
    - There was no documented verification or validation testing of the PCA/PCEA delivery mode software that was integrated into the Spectrum operating software version 4.00.04
    - Validation of MDL software for Sigma Spectrum pumps was either not performed or it was incomplete
    - Additionally, in all software versions above, two tests to support the "library download deployment and download validation", which were consistently performed in validation of previous iterations of the MDL, were excluded from these protocols. Your firm has not provided any justification as to why these tests were removed from the protocol.
    - Failure to validate the data integrity of the MDL library is especially crucial for versions 5.0.0.25 and 5.0.2, which supports the unvalidated PCA/PCEA delivery modules
    - Testing was not performed to verify or validate that newer versions of the MDL could successfully import the drug library data from older versions of the software.
    - Sigma International's engineers stated that MDL software and data files can be migrated into the most current version of the MDL that is installed on any particular device. However, your firm has not validated that this migration can be performed successfully, without compromising the integrity of the data that is transferred from older MDLs to newer MDLs
    - The following test was successfully completed without failures: Importing Drug Libraries from MDL v2.0.0-0002 to MDL v4.00.02 to MDL v5.0.0.25, MDL 5.0.1 to v5.0.2. However, based upon our review, it appears that your firm's tests only verify that any given version of the MDL would successfully import software and data files from its immediate predecessor
    - Failure to establish and maintain procedures for verifying or validating the corrective and preventive action to ensure that such action is effective
    - Failure to establish and maintain procedures for changes to a specification, method, process or procedure
    - Failure to maintain records of changes to documents that include a description of the change, identification of affected documents, signature of approving individual, approval date and when the change became effective
    - Failure of management with executive responsibility to ensure that the established quality policy is understood, implemented, and maintained at all levels of the organization

 

 

W-194

Keywords: GLP, raw data, reason for change, responsibilities of QAU, integrity of study data

  • Primary Deviations: Incomplete study records, no reason for change of study records, QAU not fulfilled its responsibilities, raw data, no assurance of the quality and integrity of study report, no final study report, no or inadequate testing and calibration of equipment
  • Examples:
    - Failure of the study director to assure that all experimental data were accurately recorded and verified and document the reason for any change in the entries
    - For study xxx your study director failed to assure that dosing were accurately recorded to confirm that study animals received protocol-specified doses of the vehicle.
    - Failure of QAU to assure that reported results in the final study report accurately reflected the raw data
    - Failure of QAU to maintain written and properly signed records of each periodic inspection
    - Failure to identify the test and control articles with appropriate characteristics in the final report
    -  Failure to adequately test, calibrate, and/or standardize all equipment used the generation, measurement and assessment of data

 

W-193

Keywords: Batch records, method validation, cleaning validation, equipment calibration

  • Primary Deviations: Incomplete batch records, insufficient documentation of method validation, inadequate documentation of laboratory equipment calibration, shipment of APIs to US from non certified manufacturing site
  • Examples:
    - Batch production records do not include complete information relating to the production and control of each API batch
    - Method validation documentation did not include appropriate data to verify that the analytical method produced accurate and reliable data
    - Production equipment was not adequately cleaned and was not maintained in a good state of repair
    - Laboratory equipment calibration was not adequately documented.

W-192

Keywords: Data security, raw data, passwords, laboratory software

  • Primary deviations: no individual passwords, ability to overwrite raw data.
  • Examples:
    - Validation of the (brand name) laboratory software used to control instruments, generate data, perform calculations, and store data from raw material and finished product testing failed to demonstrate adequate security. Analysts have the ability to overwrite original data, and are not required to utilize the protection of individual passwords.
    - The corresponding EIR further states: During discussions and lab demonstrations, it was determined that neither system prevents analysts from overwriting original raw data. A review of the software validation showed initial failures for modules demonstrating the ability to delete or overwrite data. Documentation in the validation report stated that this capability could not be changed. During the laboratory demonstration, I observed the statement, "Data will be overwritten" with the option to ignore this.
    - In addition to the ability to overwrite original data, the analysts are not required to utilize the protection of passwords since they are considered to have "limited access". I stated that each analyst needs to have their own password to access the system to help ensure data security and to track the usage by individuals.

 

W-191

Keywords: Vendor software, software validation

  • Primary deviations: vendor supplied computer software not validated,
  • Examples:
    -The performance of the computer software has not been verified. Specifically your firm has not verified your computer software program in all aspects of their donor referral operations to ensure that electronic records are trustworthy, accurate and reliable. The related EIR further explained: The firm uses a computer software program called (brand name) that is manufactured by (vendor name).
    - During the inspection, I asked if the computer software has been validation to assure that it performs for it's intended use. I was told that the software was validated by the manufacturer. The managing director provided me a copy of the letter the received from (the vendor). The letter indicated that the software was validated. She also the gave me a copy of validation information that was obtained from (the vendor) during the inspection.
    - I told the managing director I still need to see what they have done to validate the system since the computer was making a decision to accept or reject potential donors. The managing director and the Manager of the Communications Center told me that they were unaware they the company had to validate the software because it was validated by (the vendor) and that was their reason for purchasing the version of software instead of the COTS (Commercial Off The Shelf) version of the software that is also manufactured by (the vendor).  

 

W-190

Keywords: IQ, OQ, PQ, retrospective validation, legacy systems, no review of electronic records

  • Primary deviations: no validation of legacy systems, no formal change control. no design control for customized software elements, no review of electronic records
  • Examples:
    - No IQ, OQ or PQ has been performed throughout the life of the system. No validation reports have been generated historically.
    - Current efforts to retrospectively validate the system have progressed through the approval of an IQ protocol, however, this protocol has not yet been executed. OQ and PQ efforts have not yet been developed as part of these current validation efforts.
    - The (system) has not been maintained under established procedures for change control. This is true throughout the life of this software application.
    - The firm has failed to generate or maintain design control documentation sufficient to define all customized elements making up the (system) configuration (i.e., functional or structural design documentation defining all program making up (the system)
    - Electronic records generated during manufacture of APIs were not reviewed prior to release of validation lots or for any lots manufactured thereafter to include the most recently released API lot.
  •  

 

W-189

Keywords: Microsoft Excel, Microsoft Word, Off-the-shelf software, Validation

  • Primary deviations: Off-the shelf software not validated
  • Examples:
     Failure to assure that when computers or automated data processing are used as part of the production or quality system the manufacturer shall validate computer software for its intended use according to an established protocol, as required by 21 CFR 820.70(i).
    - Electronic records are used but there was no software validation.
    - No procedures are established to validate for its intended purpose the Microsoft Word or Microsoft Excel software used in creating and maintaining nonconformance records, product return records, internal audit corrective records, or corrective action records.

 

W-188

Keywords: Laboratory, Electronic Audit Trail, Chromatographic integration

  • Primary deviations: No or inadequate electronic audit trail, no audit trail for chromatographic reintegration
  • Examples:
    - Operations that could affect the integrity of chromatographic data files … are not controlled by electronic audit trails that maintain who, why and what was changed to any given sample record
    - There are no records of user transactions when data is deleted, copied, renamed or purged
    - The firm can not determine if reintegration of a sample occurred once or several times

 

W-187

Keywords: Stability Testing, Quality Control Unit, Laboratory investigations, electronic audit trail, automated computer time-out, method validation, method transfer

  • Primary deviations: Electronic audit trail not reviewed, electronic audit trail does not identify the the person who made the change, no automated computer time-out, operators and supervisors can delete raw data, raw data from contract testing labs not reviewed, proper functioning of established methods not verified after modifications, no follow-up on unknown chromatographic peaks, failing impurity results not reported, no or inadequate training, responsibilities of quality control unit not in writing, inadequate cleaning and maintenance of equipment, no or inadequate failure investigation
  • Examples:
    - Appropriate controls are not exercised over computers or related systems to assure that changes in master production and control records are instituted only by authorized personnel
    - The audit trail generated within xxx does not truly reflect the identity of the responsible individuals. Individuals have been able to log on to the system under an other individuals account and make changes which then show up on the audit trail to the first individual.
    - Changes made by PERSON 1 are attributed to PERSON 2 on the (electronic) audit trail.
    - The firm's review of laboratory data does not include the audit trail/revision history to determine if unapproved changes have been made.
    - The xxx system computers in the lab do not time-out. If an employee fails to log off a computer and walks away other individuals can easily access the computer under the first employees account.
    - The firm routinely assigned method validation chemists, lead chemist, and laboratory supervisors system administrator status with the ability to modify and delete raw data files in the HPLC data acquisition system
    - Records maintained of any modifications of an established method employed in testing do not include the data to verify that the modification produced results that are at least as accurate and reliable for the material being tested as the established method
    - The firm does not receive and review all raw data from contract testing laboratories
    - The accuracy, sensitivity, specificity, and reproducibility of test methods have not been established and documented
    - The firm failed to perform finished product test method transfers for 34 products
    - The firm has failed to perform method validations, method verifications, or method transfers for any of the laboratory test methods used to test active pharmaceutical ingredients

 

W-186

Keywords: Method validation, method transfer, process control procedure, sampling plans, test procedures

  • Primary deviations: Analytical methods transferred without method transfer or revalidation protocol, no or inadequate product specifications, no or inadequate sampling plans.
  • Examples:
    - Failure to establish production and process control procedures designed to assure your drug products have the required identity, strength, quality and purity. For example, the validation protocols for xxx and xxx do not provide assurance that the manufacturing process quality throughout the production process/
    - failure to establish scientifically sound and appropriate specifications, standards, sampling plans, and test procedure designed to assure products conform to appropriate standards of identity, strength, quality, and purity. For example, there is no scientific justification for testing 30 capsules for content uniformity during process validation.
    - Failure to establish and document the accuracy, sensitivity and reproducibility of test methods employed. for example, methods that were validated at one facility and transferred to xxx site are being used without method transfer or revalidation protocol,.

 

W-185

Keywords: Software and computer system validation, back-up, limited access, audit trail, data encryption, accurate copies

  • Primary deviations: Inadequate storage and back-up, missing ability to discern invalid or altered electronic records, access to computer records without unique user ID and password, no or inadequate validation, inaccurate copies of electronic records.
  • Examples:
    -Failure to store records so as to minimize deterioration, prevent loss and back up of automated data processing systems
    - The electronic data did not correlate with the paper records; you had not established an electronic data back-up procedure; and finally, data was copied onto the server from one system to the next via floppy: therefore, no limited access or data protection had been established
    - You failed to adhere to the requirements established by the stability protocol in that, the method for tracking (i.e. Microsoft Excel) the number of samples placed in the incubator was unauthenticated.
    - You failed to encrypt and/ or physically secure your data back-up system to comply with the requirements to prevent deterioration or deletion of the analyzer data- You failed to encrypt and/ or physically secure your data back-up system to comply with the requirements to prevent deterioration or deletion of the analyzer data
    - Failure to adequately validate the intended use of this PC and its software
    - The dedicated PC [redacted] attached to the [redacted] was not secure in that access to the data on [redacted] was not granted by a unique username and password or equivalent method
    - there as no documentation associated with the electronic data for whom was responsible for collection of the analytical results as several quality control personnel have access to the [redacted] no software changes in the study data could be detected as there was no audit trail capability; and finally, the electronic data did not correlate with the paper records.
    - your response and have concluded that it is inadequate because no system validation was conducted to ensure accuracy, reliability, consistent intended performance, and the ability to discern invalid or altered records

 

W-184

Keywords: IRB, clinical investigations, review procedures

  • Primary deviations: Failure to follow required written procedures, failure to use expedited review procedures.
  • Examples:
    - Review of the inspection report indicates that the IRB failed to follow written procedures for conducting initial and continuing review of research
    - The IRB's written procedures state that "the IRB shall consist of thirteen (13) members." Since October 12, 2005, the IRB membership roster has listed only 12 members.
    - The IRB's written procedures state that "meetings will be held on an as-needed basis, but no less than quarterly." However, the IRB records indicate that the IRB has met at intervals greater than three months on four occasions since August 2004.
    - Failure to use expedited review procedures only for certain kinds of research involving no more than minimal risk or for minor changes in approved research [21 CFR 56.110]
    - Failure to ensure that the IRB reviewed proposed research at convened meetings at which a majority of the members of the IRB were present

 

W-183

Keywords: Clinical trials, investigational plan, investigator agreement

  • Primary deviations: Missing records, inaccurate data corrected, unapproved deviation from investigational plan, no or inadequate
  • Examples:
    - Failure to ensure adequate monitoring of the investigation
    - Data were missing and inaccurate data was corrected for Subject [redacted]
    - Failure to secure the investigator's compliance with the signed investigator agreement, the investigational plan, applicable FDA regulations, and any other conditions of approval imposed by the reviewing IRB or FDA
    - There are repeated deviations from the investigational plan, spanning several years, with no apparent steps taken to bring the clinical investigators into compliance, which indicates failure to ensure investigator compliance

 

W-182

Keywords: Method validation, USP, standard methods, stability testing, method documentation, change control, OOS, batch records

  • Primary deviations: Failure to validate changed USP standard methods, missing validation for stability indicating methods, insufficient documentation of test methods, insufficient documentation of changes, no follow-up of oos situations, failure to release products that do not meet USP requirements, incomplete batch records
  • Examples:
    - Your firm uses USP methods to analyze your products, but changes have been made to the USP methods and no validation has been performed. For example, for Migrazone Capsules, the USP uses three different wavelengths to analyze the three active ingredients. Your firm changed the method to use [redacted] of or all three actives and no validation of the new procedure was performed.
    - Failure to follow your firm's written stability testing program as required by 21 CFR 211.166(a) in that your firm has no validation data to demonstrate that the method used to analyze products for stability is capable of detecting degradation of the products
    - Your firm lacks complete written methods that fully describe the procedures, equipment, parameters and specifications to be used in the analysis of individual products.
    - Written instructions for analyzing products include cross outs and changes to the instructions without any documentation as to why these changes were made
    - Review of chromatograms revealed that, in certain instances, out of specification results which were recorded on the chromatograms had no corresponding reference or raw data recorded in the official laboratory bound notebook. In these cases, the data was recorded in the notebook only when the sample was retested and results found to be within limits. For example...
    - Your firm has released products purporting to meet USP requirements when, in certain cases, they fail to meet such requirements. For example ...
    - Laboratory control results are not included in batch records as required by 21 CFR 211.188(b)(5). Analytical results are only maintained in laboratory notebooks

 

W-181

Keywords: Cleaning records, sampling plans, test procedures, building design

  • Primary deviations: Failure to keep records for the maintenance, cleaning, and sanitizing of equipment. Failure to establish sampling plans, test procedures, or laboratory control mechanisms for testing your finished product Failure to have adequate building design.
  • Examples:
    -For example, your firm lacked an adequate assessment of the cross-contamination risks posed by the manufacture of several potent compounds (e.g. cytotoxic and hormone products, as well as other products of high pharmacologic activity) at your facility.
    - Failure to have adequate building design and construction used in manufacture, processing, packing, or holding of drug products to facilitate cleaning, maintenance, and proper operations
    - There were no equipment cleaning records for several of the product contact, multi-use formulation mixing rods. The investigators observed that there was no evidence to demonstrate that the mixing rods were dedicated to specific products.
    - Investigators observed black colored particles in at least one evacuated sterile vial. The microbiologist performing sterility testing on the vials was observed removing the vial with the black colored particles and replacing the vial. No sampling plan or test procedures were available to justify replacement of the finished product evacuated vial.

 

W-180

Keywords: Cleaning validation, quality control unit, failure investigation, oos, raw data, laboratory notebooks, input-output checking, retesting

  • Primary deviations: Inadequate cleaning validation, quality control units failed adequate investigation, no or inadequate failure investigation, raw data not documented in laboratory notebooks, oos retesting without supervisory approval, electronic data files not routinely checked for accuracy, discrepancies in electronic data
    Examples:
    - Our investigators observed numerous instances where the quality control unit failed to adequately investigate and resolve laboratory deviations and out-of-specification test results involving drug products that ultimately were released for distribution into interstate commerce
    - Our investigators uncovered out-of-specification test results in laboratory raw data that were not documented in laboratory notebooks, and found that products were released based on retesting without any justification for discarding the initial out-of-specification test results.
    - The chromatographic test data reflecting the out-of-specification test results were not recorded in laboratory notebooks. Instead, a new sample preparation was injected within the same chromatographic run without supervisory approval, as required by your firm's SOP
    - A review of the laboratory notebook shows the sample dilution value in the laboratory notebook was overwritten, without being signed and dated.
    - There was a failure to check for accuracy the inputs to and outputs from the "Total Chrom Data Acquisition System," which is used to run your firm's HPLC instruments during analysis of drug products. For example, electronic data files were not routinely checked for accuracy and, as mentioned in the above observations, our investigators found numerous discrepancies between the electronic data files and documentation in laboratory notebook.

 

W-179

Keywords: Computer validation, training, document control, CAPA, root cause

  • Primary deviations: Computer systems nor validated, training needs not identified, failure to follow document controls requirements, no or inadequate CAPA procedures, no validation or verification that implemented CAPA activities are effective
  • Examples:
    - Failure to establish and maintain procedures for implementing corrective and preventive actions. The procedures must include verifying or validating the corrective. and preventive actions to ensure that such actions are effective and do not adversely affect the finished device, as required by ...
    - Failure to investigate the cause of nonconformities relating to product, processes, and the quality system, as required by 21 CFR 820.100a)(2). For example, the following procedures, Complaint Handling, Defect Tracking and Trending, Nonconforming Material and Repair of Equipment, do not include procedures for performing failure investigations.
    - Failure to have production and process controls for automated processes, as required by 21 CFR 820.70(i). when computers or automated data processing systems are used as part of production or the quality system . A manufacturer is required to validate computer software for its intended use according to an established protocol. For example, databases that are maintained for data analysis and other tracking and trending functions, including complaint and services access databases, have not been validated for their intended use.
    - Verification or validation of CAPA is required and no documentation was attached or referenced to CAPA 440C.

 

W-178

Keywords: Ongoing equipment qualification (PQ), procedures, PQ, training, quality control unit, records, failure investigation

  • Primary deviations: No or inadequate performance qualification, no or inadequate written procedures for production and process control, no or inadequate quality control unit, failure to perform investigation, no or inadequate training, procedures not followed, failure to maintain complete equipment calibration records records .
  • Examples:
    -Failure to routinely calibrate, inspect, or check automatic, mechanical, or electronic equipment according to a written program designed to assure proper performance [21 CFR 211.68(a)].
    - Specifically, your cryogenic pumping system lacks qualification according to a written plan to assure all parts of the system, including the pump, power supply, electric components, vacuum hold and cryogenic jacket, will operate properly for their intended use every time.
    - Failure to establish adequate written procedures for production and process control designed to assure drug products have the identity, strength, quality and purity they purport or are represented to possess
    - Failure to establish an adequate quality control unit having the responsibility and authority to approve or reject all drug products, and the authority to review production records to assure no errors have occurred or, if errors have occurred, they have been fully investigated, as required by 21 CFR 211.22(a). Specifically .......
    - Quality control unit personnel failed to perform an investigation into the failure of the filling equipment to fully pressurize the cylinders during a filling operation, in violation of 21 CFR 211.192
    - Failure to maintain complete records of the periodic calibration of laboratory instruments required by 21 CFR 211.160(b)(4) and 211.194(d)

 

W-177

Keywords: Bioequivalence, retrospective review of study data, analytical methods, no procedures, pharmacokinetic profiles, failure investigations

  • Primary deviations: invalid retrospective review of study data, inadequate documentation to demonstrate accuracy of analytical methods, providing incorrect information to the FDA, missing studies in retrospective review, lacking procedures for critical steps in retrospective review, failure to investigate pharmacokinetic profiles with unexpected concentration results, no timely information of study sponsors about invalid data.
  • Examples:
    -Failure to demonstrate that the five year retrospective review is effective and capable of discriminating between valid and invalid data
    - Failure to assure that the analytical methods used for in vivo bioavailability studies could accurately measure the actual concentration of active drug ingredient, or its metabolite, achieved in the body. "Long term use" is not a sufficient assurance of assay accuracy.
    - For these reasons you have not demonstrated that the reported concentration results in Study xxx are accurate.
    - You provided incorrect incorrect information to FDA regarding the status of undergoing retrospective review
    - You failed to appropriately include studies in the retrospective review
    - There is no assurance that reviews were conducted in accordance with original or revised procedures
    - You failed to investigate the cause of anomalous results, or re-assay the affected samples. Contrary to your response, the frequency of occurrence is not a justification for accepting anomalous study results
    - Although you discontinued use of the xxx method in August 2005, you failed to inform study sponsors that the data generated with this method was invalid.

 

W-176

Keywords: Clinical studies, subjects safety, subject rights, supervision of personnel, signatures, review reports, record maintenance

  • Primary deviations: failure to protect the rights, safety, and welfare of subjects under care, failure to personally conduct or adequately supervise the above references clinical trial, no evidence of lab report review, failure ton conduct the study in accordance with the investigational plan, failure to prepare and maintain adequate and accurate records, failure to promptly report to the sponsor any adverse effect that may reasonably be regarded as caused by, or probably cause by, the drug.
  • W-175Examples:
    - You did not adhere to the applicable statutory requirements and FDA regulations governing the conduct of clinical investigations
    - Because this subject had a history of peptic ulcer disease and an incident of gastrointestinal bleeding she was at substantial risk for GI bleed related to treatment with aspirin.
    - The record does reflect that you reviewed the subject screening assessments and related subject records in accordance with the protocol
    - You delegated certain study tasks to an individual not qualified to perform such tasks
    - You permitted an individual with no medical training to evaluate laboratory results for clinical significance. The lab reports were not co-signed by you, therefore thee is no indication that you reviewed them
    - The case history did not contain any other documents to validate the subject's enrollment and completion of clinical investigation

 

W-175

Keywords: Process validation, software validation, design verification, SOPs, incoming product control, complaint handling

  • Primary deviations: Inadequate procedures for monitoring and control of parameters for validated processes, inadequate process control procedures, inadequate procedures for incoming product control and documentation, inadequate complaint handling procedures, no or inadequate software
  • Examples:
    - Failure to establish, and maintain procedures for monitoring and control of parameters for validated processes to ensure that the specified requirements continue to be met
    - Where the process cannot be fully verified by subsequent inspection and test, the process shall be validated with a high degree of assurance and approved according to established procedures.
    - The validation activities and results, including the date and signature of the individual(s) approving the validation and where appropriate the major equipment validated, must be documented. For example, your firm has not validated the software used in the xxx device. The xxx device has a microprocessor programmed with specific -software to control the xxx and alternate the xxx Procedures for validating the device design to ensure that the device conforms to defined user needs and intended uses have not been provided, nor has the software validation been performed
    - Failure to establish and maintain process control procedures, including documented instructions, standard operating procedures (SOPs), and methods, that define and control the manner of production
    - Failure to establish and maintain procedures for finished device acceptance to ensure that each production run, lot, or batch of finished devices meets acceptance criteria
    - Failure to establish and maintain procedures for acceptance of incoming product, including documentation of acceptance or rejection
    - Failure to establish and maintain adequate complaint handling procedures for receiving, reviewing, and evaluating complaints by a formally designated unit

 

W-174

Keywords: CAPA, complaints, training, equipment calibration, process validation, received product testing

  • Primary deviations: training procedures not implemented, no or inadequate procedures for equipment calibration and inspection, no procedures for process validation and monitoring, CAPA procedures not established and implemented, complaint files not maintained, specifications of all purchased or otherwise received products and services not verified
  • Examples:
    -Failure to establish, implement, and control procedures to ensure that equipment used in production and measuring are routinely calibrated, inspected, and checked for accuracy Specifically, no records are maintained for the inspection, checking, adjustment and calibration of scales, production furnace, and filling machine
    - Failure to ensure complaint files are maintained and that all oral and written complaints are documented upon receipt and are processed in a uniform and timely manner
    - Failure to establish, implement, and control procedures for the validation of production processes and control and monitoring of process parameters
    - Failure to implement and control procedures to ensure that all purchased or otherwise received product and services conform to specified requirements
    - Failure to establish, implement, and control procedures for Corrective Action and Preventive Action (CAPA)
    - Failure to ensure that training procedures identifying training needs are implemented and training activities are documented

 

W-173

Keywords: Audit of contract laboratories, certificate of analysis, responsibilities of quality unit, reserve samples, API, repackaging, container closure systems, equivalency

  • Primary deviations: failure to conduct audits of contract laboratories, failure to validate the authenticity of suppliers COAs, reserve samples not retained, equivalency of container closure system not documented
  • Examples:
    - Failure to validate the authenticity of supplier's COAs of a periodic basis in lieu of full compendia testing of APIs that you package
    -Failure to conduct audits of contract laboratories that perform testing-of-incoming API. Your SOPs indicate that these audits are to be conducted every two years
    - Failure to maintain written procedures that describe the responsibilities and procedures applicable to the quality control unit
    - Failure to retain reserve samples of each batch of each API that you repackage. There were a number of instances your firm received complaints regarding product integrity. Your firm failed to conduct complete investigations into these complaints regarding the APIs that you repackage because no reserve samples were available to examine
    - You have not demonstrated that the container closure systems into which these APIs are repackaged are identical or equivalent to those in which the APIs are received

 

W-172

Keywords: failure investigations, contract laboratory, repair, passwords, audit trail, security, method change, signatures on test results, power failure

  • Primary deviations: insufficient written records of failure investigations, investigations not extended to other batches, missing HPLC peak not investigated, no investigation regarding HPLC malfunctions requiring external repair, impact of power failure not investigated, laboratory records not signed by the analyst, analyst not identified, failure to use group passwords to log-on to computer systems, changes of methods by authorized persons not ensured, no review of audit trail, contract laboratory not qualified
  • Examples:
    - Written records are not always made of investigations into unexplained discrepancies, nor did investigations of unexplained discrepancies extend to other batches of the same drug product or other drug products that may have been associated with the specific failure or discrepancies
    - The reference standard injection following assay and content uniformity testing of xxx, failed to show any peaks due to a leaking column. There was no documented investigation of this deviation, there was no assessment of the impact of the leaking column on the xxx analysis or any other analysis conducted with the same column, and the observation was made during the previous inspection, yet no investigation was conducted.
    - There was no documented investigation regarding HPLC malfunctions requiring external repair. Both HPLC xxx and xxx required repair in June 2005; however there is no documentation regarding whether the malfunctions impacted any analyses, and if so, what the corrective actions were regarding those analyses.
    - Power failures occurred during analyses of xxx. Investigations did not document the impact on the analyses, any re-testing or resampling, or if the power outage impacted any other analyses
    - Laboratory records fail to include the initials or signature of the person who performs each laboratory test [21 CFR § 211.194(a)(7)]. Specifically, laboratory analysis records for analyses performed on HPLC xxx and xxx do not indicate which analyst performed the injections.
    - Failure to maintain complete records of any modification of an established method employed in testing [21 CFR § 211.194(b)]. Specifically, the records of laboratory methods stored in the xxx computer system do not include the identity of the person initiating method changes.
    - Appropriate controls are not exercised over computers or related systems to assure that changes in analytical methods or other control records are instituted only by authorized personnel
    - Laboratory managers (QC and R&D) gained access to the xxx computer system through a common password. Analysts were not required to use individual passwords; they operated the system following the login by the laboratory managers.
    - Due to the common password and lack of varying security levels, any analyst or manager has access to, and can modify any HPLC analytical method or record. Furthermore, review of audit trails is not required.
    - Failure to follow written procedures applicable to the quality control, unit [21 CFR § 211.22(d)]. Specifically, the contracted laboratories responsible for performing analyses on Active Pharmaceutical Ingredients and other drug components, used in the finished drug products, such as LOD, nitrogen content; microbial limits, and specific rotation, have not been qualified by the quality unit as per your firm's written procedures.

 

W-171

Keywords: Complaints, service, repair, design, risk assessment

  • Primary deviations: Service records not maintained, inadequate handling of complaints, not all possible risks identified and documented
  • Examples:
    - Failure to establish and maintain procedures to ensure that the design requirements relating to a device are appropriate and documented
    - Your firm failed to identify, approve, and document appropriate design inputs prior to the start of its formal design of the Frye Adjusting Instrument
    - Failure to establish and maintain procedures for validating the device design to ensure that the device conforms to user needs and intended uses
    - Your firm failed to adequately identify and document all possible risks associated with your device and document the results of your firm's risk analysis
    - Failure to establish and maintain complaint handling procedures for receiving, reviewing, evaluating, and documenting complaints by a formally designated unit
    - Failure to maintain service reports for serviced devices, as required by 21 CFR § 820.200(d). For example, your firm failed to maintain service reports for each device returned to your firm for servicing or repair (e.g. the name of the device, the date of service, the individual(s) servicing the device, the service performed, and the test and inspection data).
    - Your firm failed to document the results of its analysis or evaluation of emails of complaints and service reports in order to identify existing and potential causes of nonconforming product. You stated that you mentally evaluated complaints and servicing or repairs of returned devices but that you had not documented any evaluations.

 

W-170

Keywords: process control, change control, training, product identification

  • Primary deviations: no adequate production and process controls, inadequate change control, no performance verification after the change, missing records of communication, training not documented
  • Examples:
    - Failure to establish and maintain adequate production and process controls that include documented instructions, standard operating procedures (SOP), and methods that define and control the manner of production
    - Failure to establish and maintain procedures for changes to a specification, method, process, or procedure, including verification or validation of such changes
    - Failure to promptly remove obsolete documents from all points of use
    - Your firm changed the xxx Cooler-Heater device's internal timer setting in two instances. The reason for the changes, the review and approval for the changes, and the effective date of the changes were not documented
    - Your firm failed to conduct, document, and maintain the results of the verification testing of each change o determine whether or not each change affect operations and performance specifications
    - Your firm failed to maintain records of communication with the specification developer to document who initiated and authorized the changes, the signature of the approving individual(s), the approval date, and an effective date of each approved change
    - Failure to establish and maintain procedures for identifying product during all stages of receipt, production, distribution, and installation to prevent mixup
    - Your firm stated that three individual employees involved in the assembly of the xxx Cooler-Heater devices had been trained but that your firm could not provide any documentation of their training.

 

W-169

Keywords: Buildings, equipment cleaning, maintenance, calibration, laboratory controls, records, signature, failure investigation

  • Primary deviations: Inadequate buildings, no or inadequate maintenance and cleaning of equipment, insufficient intervals for equipment calibration, inadequate laboratory controls, test procedures not followed, incomplete laboratory records, initials or signature of a second review person missing, inadequate failure investigation
  • Examples:
    -Buildings used in manufacture of injectable products are not always maintained in a good state of repair,
    -Equipment and utensils are not always cleaned, maintained and sanitized at appropriate intervals to prevent malfunction or contamination
    - The calibration of instruments was not always conducted at suitable intervals
    - Deviations from written procedures not justified
    - Test procedures were not always followed
    - Laboratory records did not always include a description and identification of the sample received for testing, the date the sample was taken, the date the sample was received for testing and the data derived from testing.
    - Laboratory did not enter the date on which the results are read into the logbook.
    - There were not always the initials or signature of second person showing that the original records have been adequately reviewed by a second person
    - The investigations did not always extend to other batches of the drug or other drug products that may have been associated with specific failure or discrepancy

 

W-168

Keywords: supplier evaluation, process validation, complaints, computer validation, training, quality system

  • Primary deviations: No or inadequate procedures for design control, no documentation that products have been developed in accordance with design control, inadequate review of complaints, no procedures for evaluation of suppliers, contractors, and consultants, no notification of changes by the supplier, effective and complete procedures for implementing corrective and preventative action operations, no validation of the manufacturing processes, no or inadequate validation of computer systems, insufficient controlling the storage of product in order to prevent mix-ups, no or insufficient training, quality system not fully implemented
  • Examples:
    -written procedures for controlling the design of the Hemoglobin Alc Reagent and formulation changes to the Liquid Glucose Hexokinase Reagents were not adequately established during the implementation of these design projects
    - design history files do not demonstrate that these devices were developed in accordance with the design control requirements
    - Your firm failed to ensure complaints involving possible failures are adequately reviewed and evaluated to determine if investigations are necessary
    - Your firm failed to establish procedures for the evaluation of suppliers, contractors, and consultants
    - For example, there is no documentation to demonstrate that your firm has evaluated the importer or is aware of the manufacturer from Asia supplying the reagents used to produce the Hemoglobin Alc Reagent
    - In addition there are no clear agreements from the suppliers to notify you of changes
    - Your firm failed to validate computer software used to control automated production and quality system operations, as required by 21 CFR 820.70(i). For example, your firm has not validated the software used to produce labels and manage your complaints
    - Your firm failed to follow procedures for controlling the storage of product in order to prevent mix-ups, damages, or other adverse effects

 

W-167

Keywords: Part 11, electronic records, integrity, stability testing, documentation, storage conditions, people resources

  • Primary deviations: Electronic raw data not saved, laboratory records incomplete, inadequate documentation of storage conditions of samples, insufficient personnel and equipment in the quality control unit for testing
  • Examples:
    - Operating parameters were maintained with the relevant xxx. However, electronic raw data was not saved.
    - According to the Director of Quality Assurance, xxx began saving electronic raw data just recently at the beginning of February 2006. However, that was not observed during the inspection
    - The SOP allows "discarding" data due to variation in the xxx area or any other reason
    - Your firm failed to establish and follow an adequate written stability testing program design to assess the stability characteristics of drug products.
    - Storage condition for samples retained for stability testing are not adequately documented
    - The Quality Control Unit lacks adequate laboratory resources (personnel equipment) for conducting stability testing of drug products

 

W-166

Keywords: Part 11, electronic records, raw data, method validation, USP methods, SOP, paper notebooks

  • Primary deviations: No FDA-483, Inspectional Observations, issued to the firm. Several items have been discussed verbally with management:
  • Examples:
    - I explained that computerized records that the firm keeps to make it easier to sort or find certain information would not necessarily have to comply with Part 11 regulations. As an example, I explained that if the firm has a database for complaints, but still records everything on paper (and the paper copy is the official record), the database would not have to comply with Part 11. However, if the database was their only record, the database would have to comply with Part 11
    - if not using the methods listed in the USP, firm's methods have to be validated and/or shown to be as good as or better than the USP methods.
    - firm needs to have a system for accountability for raw data. Raw data was recorded onto a loose leaf piece of paper. The firm must have a a system of accountability in place to assure that raw data is being lost. I further explained that the firm could use bound laboratory notebooks or pre-numbered laboratory worksheets to fulfill this requirement.
    - firm needs to either update SOPs so that they reflect what is actually being done at the firm or follow SOPs as written.

 

W-165

Keywords: Part 11, electronic records, integrity, API, calibration
Includes 483 - Establishment Inspection report (EIR) - Company's response letter - FDA's answer

  • Primary deviations: Failing integrity of QC results, no testing of bulk solvents prior to receipt, failure to retain and review alarm history printout and equipment cleaning:
  • Examples:
    - There is no system for assuring the integrity of blank sheets used in the recording of results in the paper documentation system
    -  The computerized system is not secure in that it is possible for data entered to be changed. This was observed following a request during inspection for a challenge to be performed during which it was determined that previously recorded input including sample gross and net weights and the final result could be changed..
    - There is no written procedure regarding the documentation and review of deviations which occur during sterility testing
    - Testing which is performed on incoming lots of solvent to the tank farm is limited to identity testing
    - The xxx used in the manufacturing in-process laboratory and the QC laboratory was not calibrated .

 

W-164

Keywords: Equipment qualification, IQ/OQ/PQ, procedures, cleaning validation, failure investigation, washing facilities, testing, preventive maintenance

  • Primary deviations: Equipment not performing, procedures not followed, inadequate equipment qualification, PQ protocol missing, validation protocol not followed, inadequate cleaning validation procedures, missing failure investigation, master production and control records not signed, inadequate washing facilities, insufficient testing, missing preventive maintenance, forms inadequate to record complete IQ information, IQ/OQ not performed
  • Examples:
    - Failure to ensure that automatic, mechanical, or electrical equipment or other types of equipment will perform a function satisfactorily. For example.....
    - Failure to follow your standard operating procedure
    - For example, , Inspection and Testing of Manufacturing Equipment, which applies to all activities for testing and inspection of equipment at Cody Labs, and the Installation Qualification Manufacturing Equipment form do not fully describe the requirements for equipment qualification, including environmental conditions for equipment operation.
    - There is no requirement for a Performance Qualification protocol
    - The Validation Master Plan does not contain an operational qualification for xxx
    - In addition, the validation protocol should be followed and any deviations or variations from the approved protocol should be investigated
    - Written procedures for cleaning and maintaining equipment used in the manufacture, processing, packing, or holding of a drug product, are inadequate
    - There is a failure to investigate a batch that did not meet specifications
    - Failure to test each batch of API to determine conformance to specifications
    - The forms contained in the SOP are not designed to allow recording of the information that they are required to contain under the SOP. For example, there are no provisions in the form to record or check the specifications against which the Installation Qualification (IQ) is to be performed.
    - There was no Preventative Maintenance (PM) on this equipment
    - In fact, the IQ and OQ were not performed

 

W-163

Keywords: Process control, procedures, environmental monitoring equipment, batch records, log book, documentation, signature

  • Primary deviations: procedures and protocols not followed, location of equipment used for environmental monitoring not documented, drawing prepared from memory, batch records not complete, incomplete log-book information
  • Examples:
    - Written production and process control procedures not always followed and documented at the time of performance-
    - The samples that were taken were documented as 115g, 3.5 g and 115g which are all outside the range allowed in the protocol
    - Relying on the recollection of of an employee eight months after protocol was executed is not good practice
    - Lob-book did not contain complete and/or accurate documentation
    - We expect that all entries in logbooks, batch records, laboratory documentation and all other documentation be signed by the person who performed the operation.
    - Having a supervisor sign does not give the same level of accountability
    - Your response did not contain a global evaluation of other logbooks where entries may be performed similarly
    - Complete, true and accurate records are the foundation for good GMPs. Reliable documentation is a control which raises assurance of the quality of the product manufactured.
    - Practices such as back dating and signing for actions not performed are a serious violation

 

W-162

Keywords: Reference standards, method validation, change control, stability testing, cleaning validation, quality control unit, sampling, process, validation, retrospective validation, analytical equipment calibration, glass wa

  • Primary deviations: No adequate quality control unit, inadequate cleaning methods, collected samples not representative, no written validation plan or written validation protocols plan, inadequate change control for analytical methods, failure to maintain records of method modification, inadequate method validation
  • Examples:
    - Failure to have a quality control unit adequate to perform its functions and responsibilities.
    - Failure to establish and follow validated sampling and testing procedures of in process materials and drug products
    - There is no data available to establish the purity of the reference standards used to assay finished products
    - The calibration of analytical instruments is not being conducted in accordance with your established program
    - All methods do not include system suitability tests to ensure that the system is operating properly
    - Volumetric glassware is not always used to take volume measurements during assays of active ingredients in drug product
    - There is no data available to establish that analytical methods used to assay finished products meet appropriate standards for accuracy and reliability
    - Failure to maintain complete records of any modification of an established method employed in testing, including the reason for the modification and data to verify that the modification produced test results at least as accurate and reliable for that material being tested as the established method

 

W-161

Keywords: Laboratory, calibration, equipment qualification, equipment testing, balance, HPLC, GC, acceptance criteria, outside contractor

  • Primary deviations: Calibration performed by an outside contractor not verified. Insufficient testing for operational qualification, SOP not followed for testing, no procedures for HPLC and GC performance verification, no specific directions and limits for accuracy to assure chromatography performance, incomplete documentation of GC system calibration, acceptance criteria not included in GC system calibration documents
  • Examples:
    - The laboratory does not perform an adequate testing and /or calibration to verify its performance and accuracy.
    - The laboratory does not verify that the calibration performed by an outside contractor is complete and performed as required by the established standard operating procedure "HPLC Maintenance and Operational qualification". This SOP requires four tests for the operational verification: power up, diagnostics, accuracy, reproducibility and linearity tests. The reproducibility and linearity tests have not been performed.
    - - The xxx class mass used for balance calibration did not comply with the USP 0.1% requirement for mass measurement uncertainty
    - The balance used to weigh more than 20 mg did not comply with the USP 0.1% requirement for balance measurement uncertainty
    - The firm does not have a written procedure that includes requirements for the performance verification of HPLC and GC systems. They do not have specific directions
    - During the inspection, the firm did not provide an SOP for the performance verification of the HPLC and GC systems. Actually, they are contracting services for the verification of those systems, and then they are adopting contractor's SOP. Each of them has different SOPs, which includes different types of tests that does not compare. The firm should establish a procedure to assure uniformity providing specific directions and requirements for all GC Systems. Also, it will apply to HPLC systems.
    - Documentation of the GC system calibration performed by an outside contractor is incomplete. It does not include the following information: xxx

 

W-160

Keywords: OOS, CAPA, IQ, OQ, PQ, equipment, calibration, maintenance, design verification, design review, document approval

  • Primary deviations: No procedures for CAPA established and maintained, root cause for non-conforming product not identified, effectiveness of CAPA not verified, IQ and OQ not documented, settings for PQ not documented. Lack of adequate procedures for equipment calibration, checking and maintenance. No documented design verification. Approval of documents not documented.
  • Examples:
    - Your firm failed to establish and maintain procedures for implementing corrective and preventive action. In particular, you do not have a procedure to identify the action(s) needed to correct and prevent recurrence of non-conforming product and other quality problems as required by xxx
    - Your firm failed to analyze processes, quality records, service records, and other sources of quality data to identify existing and potential causes of non-conforming product
    - Your firm's corrective and preventive action (CAPA) procedure does not include a requirement that each CAPA be verified or validated to ensure that such action is effective and does not adversely affect the finished device
    - Where the results of a process cannot be fully verified by subsequent inspection and test, the process must be validated with a high degree of assurance and approved according to established procedures
    - Lacks documentation of installation and operation qualification of equipment,
    - Failed to document settings used for the Performance Qualification
    - Your firm failed to establish and maintain procedures to ensure that equipment is routinely calibrated, inspected, checked, and maintained
    - In particular, your firm did not establish and maintain procedures for calibrating temperature and speed controls on xxx

 

W-159

Keywords: GLP, electronic raw data, audit trail, automated data entry, study report, study protocol, system identification

  • Primary deviations: insufficient documentation of changes, insufficient information in the study report, study protocol not followed, no identification of automated systems
  • Examples:
    - Failure of testing facility management to assure that test articles or mixtures were appropriately tested for identity, strength, stability, and uniformity, as applicable (21 CFR 58.31(d))
    - Failure to include a description of all circumstances that may have affected the quality or integrity of the data in final study reports
    - Specifically in your summary and conclusion section of the final report you did not communicate that you have lacked critical data, or that you had reservation about drawing study conclusions
    - The final reports prepared by your study director for studies xxx did not include characteristics of the test article such as strength, purity, and composition.
    - Failure to indicate the reason for change in automated data entries. In several instances, entries in the xxx collection/notes and audit trails failed to provide the reason for changing the raw data. For example, audit trail entries for study xxx demonstrate that observation of "normal' were removed without explanation.
    - Failure to have approved written protocols written for each study
    - Not all nonclinical laboratory studies were conducted in accordance with the protocol
    - In various instances, the protocols for studies xxx did not identify the automated systems that were used for data collection.

 

W-158

Keywords: Quality control unit, OOS, failure investigations, annual reports, NDA-field alert report, laboratory test results, computer system audits, training, retesting, manufacturing investigations

483, 12 items

  • Primary deviations: no review of computer audit trail, no failure investigations, incomplete annual reports, NDA-Field Alert report not submitted, incomplete laboratory records, missing computer system audit, lack of training on SOPs and GMP, missing conclusions and follow up from failure investigations, procedures not followed, inadequate manufacturing investigations
  • Examples:
    - The quality control unit lacks authority fully investigate errors that have occurred
    - The quality unit failed to review electronic data as part of batch release
    - The quality unit failed to review computer audit trails
    - Resampling after OOS results without failure investigations
    - An NDA-Field alert Report was not submitted within three working days of receipt of information concerning a failure of distributed batches
    - OOS results were substituted with passing results by analysts and supervisors. The substitution of data was performed by cutting and pasting of chromatograms, substituting vials, changing sample weights and changing processing methods
    - Laboratory records do not include complete data from all tests, examinations and assay necessary to assure compliance with established specifications and standards, e.g., OOS data, chromatograms, sample weighs
    - Audits were not conducted of the data acquisition system used to run the HPLC instruments during analysis of drugs
    - There was no documentation of the number of retests to be performed as required by the SOP
    - Manufacturing investigations into rejected batches of drugs did not include an evaluation of the validated manufacturing process

 

W-157

Keywords: Change control, design, risk analysis,, testing, incoming product testing, device master records, internal audits, CAPA

  • Primary deviations: inadequate change control procedure, no documentation of risk analysis, inadequate testing and documentation, failure to maintain device master records, no procedures for quality audits.
  • Examples:
    - Failure to establish and maintain procedures for the identification, documentation, validation or verification, review and approval of design changes before their implementation
    - Your firm failed to provide documentation explaining whether your firm or the specification developer has conducted and documented any risk analysis of the design change or the rationale for not conducting a design risk analysis. There is no documentation documenting all possible risks that can adversely affect the patient and the controls that can be implemented to reduce the probability and severity of risks
    -The "Pass/Fail" portion of the power unit testing was filled out before the power unit testing was actually conducted
    - The test results were not documented in sufficient details to demonstrate how the power unit passed its finished product testing. The test results were simply recorded as either "Pass" or "Fail". For example, your firm failed to explain and document quantitative test results and specific acceptance criteria for the power unit's test parameters, such as the electrode temperature, safety alarm functions, current and voltage output, elapsed timer, and stimulation counter.
    - Recommendation: Due to the serious and repeat nature of the inspectional observations cited by the FDA and Texas DSHS, we suggest your firm use a qualified quality system consultant to help identify any gaps in your firm's quality system in order to establish and implement complete and comprehensive quality system procedures that will (a) correct the inspectional observations issued at the conclusion of the inspections on November 2002 and 2005, and the items identified in this warning letter, and (b) prevent a recurrence of CGMP violations 

 

W-156

Keywords: Water systems, diagrams, process validation, cleaning validation, batch record review, training, instrument calibration, reserve samples, testing, product specification, distribution records, analytical method, USP standard, failure investigation, labeling, SOPs

  • Primary deviations: missing diagrams, no installation qualification, no operation qualification, no batch record review, inadequate GMP training, inadequate equipment calibration, inadequate storage of reserve samples, SOPs not approved, inadequate procedures for sampling and testing
  • Examples:
    -There was no diagram of the water system
    - Batch records not reviewed by QC,
    - Routine calibration not performed according to a written program
    - Conductivity meters not calibrated to an NIST traceable device
    - Batch records lack a description of name of the equipment
    - No reference in analytical method to recognized standard method.
    - Current SOPs not reviewed and approved by QCU

 

W-155

Keywords: Electronic records, electronic signatures, Part 11, Equipment calibration, equipment qualification, certificate of analysis, review of records

  • Primary deviations: missing Certificate of Analysis, inadequate equipment calibration, failure to review production and control records by QA, no recalibration after equipment move.
  • Examples:
    - Electronic records are used but the do not meet employee accountability responsibility and signature manifestion requirements to ensure that they are trustworthy, reliable and generally ewquivalent to paper records-
    -Failure to establish laboratory controls which include the calibration of instruments, apparatus, gauges and recording devices at suitable intervals in accordance with an established written program containing specific directions, schedules, limits for accuracy and precision and remedial action in the event the accuracy and/or precision limits are not met [21 CFR 211.160(b)(4)].
    - Specifically, your firm does not have a Certificate of Analysis (COA) for ...
    - The procedure is unclear and is inconsistent with the manufacturer's recommendation which advises to calibrate the [redacted] Oxygen Analyzer each time the analyzer is moved.
    - Failure to routinely calibrate, inspect, or check automatic, mechanical, or electronic equipment according to a written program designed to assure proper performance [21 CFR 211.68(a)]. Specifically, your firm has not performed any equipment qualification on the "mobile" cryogenic pumping system.

 

W-154

Keywords: Equipment calibration, equipment qualification, certificate of analysis, review of records

  • Primary deviations: missing Certificate of Analysis, inadequate equipment calibration, failure to review production and control records by QA, no recalibration after equipment move.
  • Examples:
    - Failure to establish laboratory controls which include the calibration of instruments, apparatus, gauges and recording devices at suitable intervals in accordance with an established written program containing specific directions, schedules, limits for accuracy and precision and remedial action in the event the accuracy and/or precision limits are not met [21 CFR 211.160(b)(4)].
    - Specifically, your firm does not have a Certificate of Analysis (COA) for ...
    - The procedure is unclear and is inconsistent with the manufacturer's recommendation which advises to calibrate the [redacted] Oxygen Analyzer each time the analyzer is moved.
    - Failure to routinely calibrate, inspect, or check automatic, mechanical, or electronic equipment according to a written program designed to assure proper performance [21 CFR 211.68(a)]. Specifically, your firm has not performed any equipment qualification on the "mobile" cryogenic pumping system.

 

W-153

Keywords: capa, process validation, change control, quality systems

  • Primary deviations: inadequate corrective and preventive actions, inadequate process validation, inadequate change control procedure
  • Examples:
    -Failure to establish and maintain an adequate corrective and preventive action procedure which ensures identification of actions needed to correct and prevent the recurrence of nonconforming product and other quality problems, as required by 21 CFR 820.100(a)(3).
    - Failure to validate changes to your manufacturing process with a high degree of assurance to ensure that specified requirements are met as required by 21 CFR 820.75(c).
    - Validation did not include verification assurance that the changes did not affect the device
    -Failure to identify the acceptance status of product throughout manufacturing, packaging, labeling, and servicing of the product to ensure that only product which has passed the required acceptance activities is distributed or used.

 

W-152

Keywords: root cause, capa, compliant handling, management responsibility

  • Primary deviations: no root cause analysis, insufficient complaint handling
  • Examples:
    - You are responsible for investigating and determining the causes of the violations identified by the FDA. You also must promptly initiate permanent corrective and preventive action of your quality system. Failure to promptly correct these deviations may result in regulatory action being initiated by the FDA without further notice. These actions include, but are not limited to, seizure, injunction, and/or civil penalties. Additionally, no premarket submissions for Class III devices to which QSR deficiencies are reasonably related will be cleared until the violations have been corrected. Also, no requests for Certificates to Foreign Governments will be approved until the violations related to the subject devices have been corrected.
    - You have failed to establish complaint handling procedures sufficient to ensure that all complaints are documented and processed in a uniform and timely manner, as required by 21 CFR 820.198(a).
    - Management with executive responsibility has failed to ensure that an adequate and effective quality system has been fully implemented and maintained at all levels, as required by 21 CFR 820.20
    - You have also failed to establish a policy of overall intentions and direction of your firm with respect to quality

 

W-151

Keywords: stability testing, failure investigation, batch reprocessing, missing records

  • Primary deviations: No adequate stability test program, missing failure investigation, missing procedure for the reprocessing of batches, missing records regarding unexplained discrepancies
  • Examples:
    - You have failed to establish an adequate stability testing program to determine appropriate expiration dates for all your drug products (21 CFR 211.166(a) and (b)
    - You have failed to investigate failures of a batch or any of its components to meet their specifications (21 CFR 211.192).
    - You do not maintain any written records regarding unexplained discrepancies and batch failures as required by 21 CFR 211.192
    - Batches are routinely reprocessed when initial release specifications fail.
    - None of the stability failures, described above, were the subject of an investigation as required by 21 CFR 211.192
    - You have not established written procedures for the reprocessing of batches to ensure that they will conform to all established specifications (21 CFR 211.115).

 

W-150

Keywords: CAPA, complaints, audits, document control, quality system, training

  • Primary deviations: No or inadequate CAPA system, inadequate complaint handling procedures, no quality audits, inadequate organizational structure, inadequate document control, failure to review effectiveness of quality system by management with executive responsibility, insufficient personnel with necessary education.
  • Examples:
    Significant deviations include, but are not limited to, the following
    - Analyzing processes, work operations, complaints, returned product and other sources of quality data to identify existing and potential causes of nonconforming product
    - Investigating the cause of nonconformities relating to product, processes, and the quality system
    - Identifying the actions needed to correct and prevent recurrence of nonconforming product and other quality problems
    - Verifying or validating the CAPA to ensure that such action is effective and does not adversely affect the finished device

 

W-149

Keywords: API, testing, impurity testing, supplier testing, certificate of analysis, solvent recovery, labeling system

  • Primary deviations: Insufficient testing of individual batches, supplier testing not verified, no procedures for solvent recovery, inadequate proof of incoming labels.
  • Examples:
    - The laboratory did not have an adequate impurity profile that identifies organic, inorganic and solvent impurities to monitor unidentified and apparent impurities in the API
    - The microbiological laboratory fails to document the lot number and expiry date of xx
    - The reliability of the supplier's certificate of analysis (COA) was not established in that a complete analysis was not performed with the COA at the appropriate intervals.
    - Procedures for solvent recovery have not been established to ensure that solvents are controlled and monitored
    - Incoming labels received from the vendor are not proofed against the master label

 

W-148

Keywords: API, testing, raw data, failure investigations, equipment design, English language, equipment maintenance

  • Primary deviations: Insufficient testing of individual batches, insufficient recording of raw data, inadequate failure investigation, inadequate equipment design, inadequate equipment maintenance
  • Examples:
    - The individual batches are not tested for residual solvents
    - Laboratory records do not include all raw data. For example, weights determined during the preparation of standard solutions were not recorded
    - Critical production deviations may not have been investigated and documented.
    - Production equipment was not designed to minimize contamination
    - Equipment was not maintained in an adequate state of repair.
    - If you whish to to continue to ship APIs to the United states, you should evaluate all equipment and written procedures and your employees adherence to written procedures, for compliance with this standards.
    - Failure to promptly correct these deficiencies may result in the refusal to permit entry of these APIs or finished products made from these APIs into the United States.
    - Please submit documentation, with English translation, of these corrections.

 

W-147

Keywords: Audits, CAPA, risk assessment, complaint handling, validation, test equipment, training

  • Primary deviations: no audits of records, inadequate validation of workstation test equipment, inadequate compliant handling, inadequate procedures for CAPA, inadequate risk assessment.
  • Examples:
    - There is no indication that your firm conducted periodic checks or audits of the records during this time to assure the validity of the data.
    - Failure to establish and maintain procedures for implementing corrective and preventive actions (CAPA ) to include requirements for analyzing processes, work operations, concessions, quality audit reports, quality records, service records, complaints, returned product, and other sources of quality data to identify existing and potential causes of nonconforming product, or other quality problems, as required by 21 CFR 820.100(a)(1)
    - For example, your firm performed risk assessments for product failures without documenting how the severity or likelihood of occurrence used in the assessment was determined, in violation of your own procedures.
    - For example, the validation of the workstation test equipment used as part of the final device testing system; did not include a process capability challenge, did not ensure that the test equipment used was capable of functioning as necessary to capture results at both the high and low ends of the test specifications, and did not include challenges with known failures to ensure the equipment detected fault conditions.s.

 

W-146

Keywords: audits, CAPA, risk assessment, complaint handling, validation, test equipment, training

  • Primary deviations: no procedures for validating the device design, no formal risk analysis for software changes, no procedures for finished device acceptance, inadequate installation, inadequate inspection, no procedures for supplier assessment.
  • Examples:
    - Failure to establish and maintain adequate procedures for validating the device design to ensure that the device conforms to user needs and intended uses and include risk analysis, as required by 21 CFR 820.30(g) (FDA 483, Item 151.
    - For example, a formal risk analysis of the original system design and software changes to correct software bugs that caused incorrect functionality or performance problems, and to enhance the product, has not been documented. Although your software release notes briefly describe the nature of unresolved software bugs in a particular software version, they do not explain the impact of these software bugs on user needs and intended uses. For example, in the workflow release notes, dated 6/24/04, software version 2.Otr17 described that "the scores for the left eye and right eye was reversed, and the macular edema value used previously was confusing."
    - Status of design changes was not documented to explain why certain design changes were not implemented to correct Software bugs
    - The "Workflow Release Notes by xxx has no status information or discussion of the test releases of software versions v2.xx36 through v2.xx40
    - Failure to establish and maintain procedures for finished device acceptance to ensure that each production run, lot, or batch of finished devices is not released for distribution until all the requirements are completed as required by 21 CFR 820.80(d) [FDA 483 item 3]. For example, your firm has not documented the signature(s) of approval needed to release xxx for distribution
    - Failure to establish and maintain procedures for adequate installation and inspection, as required by 21 CFR 820.170(a) and document the installation activities and inspection results, as required by 21 CFR 820.170(b) [FDA 483 Item 5]. For example, your firm's device installation procedure was in the draft form at the time of our inspection, and your firm has not maintained records of installation activities and inspection results of the retinal image acquisition subsystem of the 3DT system at the clinical sites.
    - Failure to establish and maintain procedures to ensure that all purchased or otherwise received product and services conform to specified requirements, as required by 21 CFR 820.50 [FDA 483, Items 10, 11, 12, and 13). For example, your firm has not (a) evaluated the suppliers for their ability to meet your firm's requirements; (b) defined the quality requirements that each supplier must meet; (c) defined the frequency of supplier evaluations; and (d) documented supplier evaluations.

 

W-145

Keywords: Part 11, electronic records, electronic medical record (EMR) system, computer validation, audit trail, accurate and complete copies, invalid and altered records

  • Primary deviations: missing documentation for validation and other part 11 requirements
  • Examples:
    Our review of the inspection results also noted that you use an electronic medical record (EMR) system to maintain medical and other clinical data for your patients, including study subjects . You told Mr. xxx that data obtained during study visits are entered directly into the EMR, and no paper records are used. A follow-up letter from you to Mr. xxx, dated January 31, 2005, detailed the name of the EMR system and the means by which study subject information is entered
    Please note that Title 21, Code of Federal Regulations, Part 11, "Electronic Records; Electronic Signatures" outlines specific requirements that must be met for any system that is being used to maintain required records . In addition to the information requested above, please submit the following:
    - documentation of the validation of your EMR system to ensure accuracy, reliability, and the ability to detect invalid or altered records;
    - documentation of the ability to generate accurate and complete copies of records suitable for inspection, review, and copying by the agency;
    - documentation of a secure, computer-generated, time-stamped audit trail that can independently record the date and time of operator entries and actions that create, modify, or delete electronic records, and to verify that record changes do not obscure previously recorded
    information.

 

W-144

Keywords: complaints, suppliers, contractors, software validation, change control

  • Primary deviations: no or inadequate software validation, no quality requirements for suppliers, contractors and consultants, no supplier audits, inadequate change control
  • Examples:
    - Failure to perform software validation, as required by xxx. Specifically, the xxx controller unit, software version xxx was changed to xxx. The change in the software allowed for adjustment in the speed of the water pump, and inverse pulsing from the A valve to the B valve when the speculum was clogged. Your firm did not have any documentation showing that the current software version was validated.
    - Failure to establish and maintain the requirements, including quality requirements, that must be met by suppliers, contractors, and consultants, as required by xxx. Specifically, your firm did not have any documentation showing audits of the contract manufacturer responsible for manufacturing the disposable xxx which is used with the xxx. Your firm also did not define the type and extent of control to be exercised over the product, suppliers, and contractors.
    - Failure of management with executive responsibility to ensure that an adequate and effective quality system has been fully implemented and maintained at all levels of the organization, as required by 21 CFR 820.20(a). Specifically, management with executive responsibility has failed to ensure that an adequate and effective quality system has been established. There was no management oversight for employees responsible for manufacturing, finished device release, distribution, and for maintaining quality system records.

 

W-143

Keywords: System suitability testing, process validation, part 11, method validation, OOS, laboratory controls, impurities, QA procedures, training, vendor qualification, refractive index detector, electronic records, stability testing

  • Primary deviations: no or inadequate failure investigation, inadequate process validation, inadequate method validation, inadequate instruction for testing, insufficient justification for impurity specifications, QA procedures not followed, insufficient training on cGMP and operations, failure to establish controls and procedures to establish authenticity, integrity and security of all electronic records, failure to qualify suppliers, IQ/OQ o