Selected passages from the FDA letter
Quoted FDA text from the published dataset. These selected excerpts are not the complete letter.
Passage 1FDA laboratory testing of a batch of this product detained at the border found that it contained an average 0.07% ethanol and an average of 66% methanol v/v. Therefore, this hand sanitizer drug product is adulterated under section 501(d)(2) of the FD&C Act in that the active ingredient, ethanol, was substituted wholly or in part with methanol, a dangerous chemical when in contact with human skin or ingested.
Passage 2the substitution demonstrates that the quality assurance within your facility is not functioning in accordance with Current Good Manufacturing Practice (CGMP) requirements.
Passage 3ARGENT Defense Group HAND SANITIZER is an unapproved new drug introduced or delivered for introduction into interstate commerce in violation of section 505(a) of the FD&C Act, 21 U.S.C. 355(a)
Passage 4this hand sanitizer is misbranded under section 502(a) of the FD&C Act, 21 U.S.C 352(a), because its labeling is false or misleading. As noted above, ARGENT Defense Group HAND SANITIZER is labeled to contain ethyl alcohol 70% v/v. However, FDA laboratory analyses revealed that samples of this product contain less ethyl alcohol (ethanol) than indicated.
Passage 5this product is misbranded under section 502(ee) of the FD&C Act, 21 U.S.C. 352(ee) because ARGENT Defense Group HAND SANITIZER is a nonprescription drug subject to section 505G of the FD&C Act, 21 U.S.C. 355h, but does not comply with the requirements for marketing under that section and is not the subject of an application approved under section 505 of the FD&C Act, 21 U.S.C. 355.
Citations in the original letter
As cited in this historical letter, not a statement of current regulatory requirements.
- 21 CFR 201.128
- 21 CFR 330.1(e)
- 21 CFR 330