FDA warning letter · Drugs

Elemental Herbs Inc. d/b/a ALL good

Issued · Posted by FDA

Selected passages from the FDA letter

Quoted FDA text from the published dataset. These selected excerpts are not the complete letter.

Passage 1

Your firm failed to establish an adequate quality unit and the responsibilities and procedures applicable to the quality control unit are not in writing and fully followed (21 CFR 211.22(a) and 211.22(d)).

Passage 2

Your firm failed to follow an adequate written testing program designed to assess the stability characteristics of drug products and to use results of stability testing to determine appropriate storage conditions and expiration dates (21 CFR 211.166(a)).

Passage 3

Your firm failed to establish an adequate stability program and determine appropriate expiration dates for over-the-counter (OTC) drug products that you own and distribute, specifically:

Passage 4

Failure to address violations may also cause the FDA to withhold issuance of Export Certificates. The 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 201.66
  • 21 CFR 210
  • 21 CFR 211.22(a)
  • 21 CFR 211.166(a)
  • 21 CFR 310.545(a)(18)(i)(B)
  • 21 CFR 310.545
  • 21 CFR 330
  • 21 CFR 330.2