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 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 2Your firm failed to have, for each batch of drug product, appropriate laboratory determination of satisfactory conformance to final specifications for the drug product, including the identity and strength of each active ingredient, prior to release (21 CFR 211.165(a)).
Passage 3Your firm failed to adequately test your drug products for the identity and strength of the active ingredient, benzalkonium chloride (BZK), prior to release and distribution.
Passage 4Your firm failed to test samples of each component for identity and conformity with all appropriate written specifications for purity, strength, and quality (21 CFR 211.84(d)(1) and 211.84(d)(2)).
Passage 5You failed to conduct an identity test on each shipment of each lot of components used in the manufacture of your drug products, (e.g., BZK, **(b)(4)**). You also failed to determine whether each component conformed with all appropriate written specifications for purity, strength, and quality before using them.
Passage 6Failure 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 207.77(a)
- 21 CFR 210
- 21 CFR 211.67(a)
- 21 CFR 211.165(a)
- 21 CFR 211.84(d)(1)