Selected passages from the FDA letter
Quoted FDA text from the published dataset. These selected excerpts are not the complete letter.
Passage 1Your firm failed to thoroughly investigate any unexplained discrepancy or failure of a batch or any of its components to meet any of its specifications, whether or not the batch has already been distributed (21 CFR 211.192).
Passage 2Your firm failed to test samples of each component for identity and conformity with all appropriate written specifications for purity, strength, and quality. Additionally, your firm failed to withhold components from use until sampling, testing, examination, and release by the quality control unit (21 CFR 211.84(d) and 21 CFR 211.84(a)).
Passage 3You failed to perform adequate identity testing on each shipment and lot of incoming components at high risk of contamination. Additionally, you used expired raw material in the manufacture of drug products before receiving retest results and subsequently released those batches for distribution after the material failed retesting. For example:
Passage 4Your firm failed to establish adequate written procedures for production and process control designed to assure that the drug products you manufacture have the identity, strength, quality, and purity they purport or are represented to possess (21 CFR 211.100(a)).
Citations in the original letter
As cited in this historical letter, not a statement of current regulatory requirements.
- 21 CFR 210
- 21 CFR 211.192
- 21 CFR 211.84(d)
- 21 CFR 211.84(a)
- 21 CFR 211.100(a)