FDA Warning Letter Explorer
Drugs · Apr 19, 2022

Fresh Farms LLC

6 extracted findings · 4 model-assigned issue types

FDA source excerpt, selected passage

Your firm failed to establish an adequate quality unit with responsibilities to ensure adequate oversight for the manufacture of your OTC drug products. For example, you failed to ensure that the responsibilities of the quality unit are in writing and fully followed, that your products specifications are established…

Findings and supporting evidence

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

Quality unit & oversight21 CFR 211.22(a)

Firm failed to establish an adequate quality unit and to ensure responsibilities were in writing and fully followed; batch release was not adequately documented.

Supporting FDA text
Source excerpt · automated text-match check

Your firm failed to establish an adequate quality unit with responsibilities to ensure adequate oversight for the manufacture of your OTC drug products. For example, you failed to ensure that the responsibilities of the quality unit are in writing and fully followed, that your products specifications are established and approved, and that the final review of each batch and its related information are adequately documented and completed before release and distribution.

Components & suppliers21 CFR 211.84(a)

Incoming components, including ethanol (API), were not tested prior to use.

Supporting FDA text
Source excerpt · automated text-match check

You failed to sample, test, and examine components used in the manufacture of your OTC drugs including ethanol which is used as an active pharmaceutical ingredient (API) in the manufacture of (b)(4) Hand Sanitizer drug product. During the inspection, you stated that you did not test your incoming raw materials prior to use.

Laboratory controls & testing21 CFR 211.165(a)

Release testing for identity and strength of active ingredients was not performed on any batches.

Supporting FDA text
Source excerpt · automated text-match check

You failed to perform release testing for batches of (b)(4) Hand Sanitizer labeled as containing ethanol. During the inspection, you stated that no release testing was performed on your drug products.

Records & data integrity21 CFR 211.188

No executed batch records were prepared for any drug product batches.

Supporting FDA text
Source excerpt · automated text-match check

You lacked executed batch records for batches of (b)(4) Hand Sanitizer drug product you manufactured. During the inspection, you stated that no batch records were prepared.

Findings extracted from the letter

Selected FDA passages, not the complete letter.

01
Failure 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)).
02
Your firm failed to withhold from use each lot of components, drug product containers, and closures until the lot had been sampled, tested, or examined, as appropriate, and released for use by the quality control unit (21 CFR 211.84(a))
03
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)).
04
You failed to perform release testing for batches of **(b)(4)** Hand Sanitizer labeled as containing ethanol. During the inspection, you stated that no release testing was performed on your drug products. Drug products must be tested for identity, strength, quality, and purity prior to release. Testing is essential to ensure that the drug products you manufacture conform to all pre-determined quality attributes that are appropriate for their intended use, including microbiological specifications.
05
Your firm failed to prepare batch production and control records with complete information relating to the production and control of each batch of drug product produced (21 CFR 211.188).
06
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.

What FDA requested

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

  • Specify what you have done to address any violations and to prevent their recurrence.
  • If you cannot complete corrective actions within 15 working days, state your reasons for delay and your schedule for completion.

Sections and clauses cited

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

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