FDA Warning Letter Explorer
Drugs · Oct 17, 2024

Diora Kimya Sanayi ve Ticaret Limited Sirketi

5 extracted findings · 4 model-assigned issue types

FDA source excerpt, selected passage

Your firm failed to conduct at least one test to verify the identity of each component of a drug product. Your firm also failed to validate and establish the reliability of your component supplier’s test analyses at appropriate intervals

Findings and supporting evidence

Model-assisted readings, not an exhaustive interpretation. Compare with the extracted source findings below.

Components & suppliers21 CFR 211.84(d)(1)

Failed to perform identity testing on each component lot and relied on supplier COAs without validating supplier reliability.

Supporting FDA text
Source excerpt · automated text-match check

Your firm failed to conduct at least one test to verify the identity of each component of a drug product. Your firm also failed to validate and establish the reliability of your component supplier’s test analyses at appropriate intervals

Laboratory controls & testing21 CFR 211.165(a)

Released drug product batches without performing required assay testing and transcribed supplier results to finished product COA.

Supporting FDA text
Source excerpt · automated text-match check

Your firm failed to perform appropriate testing on your drug product prior to release for distribution. You stated to our investigator that assay testing was not performed on approximately (b)(4) batches of your including (b)(4) distributed to the U.S. market between 2022 and 2024.

Production & process controls21 CFR 211.100(a)

Failed to complete process validation, cleaning validation, and equipment qualification for manufacturing.

Supporting FDA text
Source excerpt · automated text-match check

You failed to adequately validate your production and process controls used in the manufacture of your drug product. You have not completed process validation and cleaning validation studies for your non-dedicated equipment.

Registration, listing & premarket

Failed to maintain drug listing, resulting in product inactivation and misbranding.

Supporting FDA text
Source excerpt · automated text-match check

Personal CARE Antibacterial Soap (NDC 72133-049) was not certified as required and was inactivated as of January 31st, 2024.

Findings extracted from the letter

Selected FDA passages, not the complete letter.

01
Your firm failed to conduct at least one test to verify the identity of each component of a drug product. Your firm also failed to validate and establish the reliability of your** **component supplier’s test analyses at appropriate intervals (21 CFR 211.84(d)(1) and 211.84(d)(2)).
02
Your 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)).
03
Your firm failed to perform appropriate testing on your drug product prior to release for distribution. You stated to our investigator that assay testing was not performed on approximately **(b)(4)** batches of your including **(b)(4)** distributed to the U.S. market between 2022 and 2024. Additionally, your firm transcribed component test results for **(b)(4)** and glycerin from your supplier’s COA directly to your finished product COA without confirmation of the results.
04
Your firm failed to establish 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)).
05
You failed to adequately validate your production and process controls used in the manufacture of your drug product. You have not completed process validation and cleaning validation studies for your non-dedicated equipment. Additionally, you lacked documentation that the equipment used to manufacture your drug product was qualified and suitable for its intended use.

What FDA requested

Model-assisted summary. Consult the letter for complete requests and conditions.

  • Provide details of supplier qualification program and incoming testing for each component.
  • Conduct analysis of retain samples or previously used components for quality attributes.
  • Provide risk assessment or retrospective review of released products without testing.
  • Provide supportive documentation and timelines for process validation and equipment qualification.
  • Provide protocol-driven cleaning validation procedure.
  • Conduct retrospective impact assessment of deficiencies on distributed products.
  • Engage qualified consultant for comprehensive six-system CGMP audit.
  • Ensure Personal CARE Antibacterial Soap is properly listed with FDA.

Sections and clauses cited

As cited in this historical letter, not a statement of current regulatory requirements.

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