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 test samples of each component for identity and conformity with all appropriate written specifications for purity, strength, and quality. 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)).
Passage 2Your firm failed to establish adequate 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)).
Passage 3You failed to provide data to demonstrate you have adequately validated your manufacturing processes used to manufacture your OTC drug products and to demonstrate your processes are reproducible and controlled to consistently yield drugs of uniform character and quality. Additionally, you failed to provide data to demonstrate the qualification of your manufacturing equipment (e.g., **(b)(4)**, bottle filling, tube filling, etc.).
Passage 4You failed to provide data regarding the validation of your **(b)(4)** system that is used as a component for your products and during equipment cleaning. Furthermore, you also failed to show that your **(b)(4)** system is adequately monitored to ensure it consistently produces **(b)(4)** that meets appropriate microbial limits.
Passage 5Your 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)).
Citations in the original letter
As cited in this historical letter, not a statement of current regulatory requirements.
- 21 CFR 201.128
- 21 CFR 210
- 21 CFR 211.84(d)(1)
- 21 CFR 211.100(a)
- 21 CFR 211.160(b)
- 21 CFR 211.22
- 21 CFR 330