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 establish laboratory controls that include scientifically sound and appropriate specifications, standards, sampling plans, and test procedures designed to assure that components, drug product containers, closures, in-process materials, labeling, and drug products conform to appropriate standards of identity, strength, quality, and purity (21 CFR 211.160(b)).
Passage 2Your 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 3Your firm failed to conduct, for each batch of drug product, appropriate laboratory testing, as necessary, required to be free of objectionable microorganisms (21 CFR 211.165(b)).
Passage 4Your firm failed to clean, maintain, and, as appropriate for the nature of the drug, sanitize and/or sterilize equipment and utensils at appropriate intervals to prevent malfunctions or contamination that would alter the safety, identity, strength, quality, or purity of the drug product beyond the official or other established requirements (21 CFR 211.67(a)).
Passage 5You failed to demonstrate that your cleaning and disinfection practices are adequate to remove contaminants from shared equipment used to manufacture household cleaners as well as your topical OTC drug products. Although you did not validate your equipment cleaning methods, you continued to manufacture your topical OTC drug products using the same equipment that you use to manufacture numerous cleaners in your facility, including **(b)(4)** Bathroom Cleaner.
Passage 6Your firm failed to conduct at least one test to verify the identity of each component of a drug product (21 CFR 211.84(d)(1)).
Passage 7Failure to address violations may also cause FDA to withhold issuance of Export Certificates. FDA may withhold approval of new applications or supplements listing your firm as a drug manufacturer until any violations are completely addressed and we confirm your compliance with CGMP. We may re-inspect to verify that you have completed corrective actions to address any violations.
Citations in the original letter
As cited in this historical letter, not a statement of current regulatory requirements.
- 21 CFR 201.128
- 21 CFR 201.61(a)
- 21 CFR 210
- 21 CFR 211.160(b)
- 21 CFR 211.192
- 21 CFR 211.198
- 21 CFR 211.165(b)
- 21 CFR 211.67(a)
- 21 CFR 211.84(d)(1)
- 21 CFR 330