FDA Warning Letter Explorer
Drugs · Aug 15, 2023

Gadal Laboratories Inc.

4 extracted findings · 4 model-assigned issue types

FDA source excerpt, selected passage

Your firm failed to qualify your suppliers and adequately test the components used to manufacture your finished drug products, including pediatric over-the-counter (OTC) (b)(4) products.

Findings and supporting evidence

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

Components & suppliers21 CFR 211.84(d)(2)

Failed to qualify suppliers and adequately test components, including active ingredients and excipients.

Supporting FDA text
Source excerpt · automated text-match check

Your firm failed to qualify your suppliers and adequately test the components used to manufacture your finished drug products, including pediatric over-the-counter (OTC) (b)(4) products.

Components & suppliers21 CFR 211.84(d)(2)

Approved an active ingredient from an unqualified supplier without establishing COA reliability.

Supporting FDA text
Source excerpt · automated text-match check

(b)(4), one of your active ingredients is sourced from an unqualified supplier and was approved for use without establishing the reliability of your suppliers’ certificate of analysis (COA).

Components & suppliers21 CFR 211.84(d)(2)

Microbiological testing for an excipient lacked specificity on objectionable organisms.

Supporting FDA text
Source excerpt · automated text-match check

The microbiological testing of (b)(4) excipient in your supplier qualification document only included a general statement that it should be free from pathogens but lacked any further specificity on microorganisms that your firm considers to be objectionable.

Components & suppliers21 CFR 211.84(d)(2)

Lacked specific identity tests for high-risk components before use in manufacturing.

Supporting FDA text
Source excerpt · automated text-match check

You lacked a specific identity test to detect (b)(4) and (b)(4) in all shipments, containers, and lots of (b)(4) and (b)(4) before use in the manufacturing of drug products.

Production & process controls21 CFR 211.100(a)

Failed to adequately validate production and process controls for OTC drug products.

Supporting FDA text
Source excerpt · automated text-match check

You failed to adequately validate your production and process controls. You did not have assurance that you are capable of consistently manufacturing OTC drug products with defined quality attributes.

Production & process controls21 CFR 211.100(a)

Failed to adequately qualify and test the water system for chemical and microbiological standards.

Supporting FDA text
Source excerpt · automated text-match check

You also failed to adequately qualify and test your (b)(4) system to assure the (b)(4) produced from the system consistently meets chemical and microbiological standards and is suitable for use as a raw material in drug manufacturing or for cleaning.

Production & process controls21 CFR 211.100(a)

Failed to thoroughly validate cleaning processes and verification program.

Supporting FDA text
Source excerpt · automated text-match check

You have not thoroughly validated your cleaning processes and your cleaning verification program does not adequately detect potential cross-contamination between products or microbiological contamination.

Quality unit & oversight21 CFR 211.22(d)

Replaced inactive ingredients without documented rationale or stability studies.

Supporting FDA text
Source excerpt · automated text-match check

You replaced the inactive ingredient with another inactive ingredient, without documented scientific rationale and justification, in multiple batches of your OTC drug products.

Records & data integrity21 CFR 211.22(d)

Laboratory data recorded on uncontrolled sheets, in pencil, and altered with correction fluid.

Supporting FDA text
Source excerpt · automated text-match check

Analysts documented original laboratory data on uncontrolled sheets of paper. Analysts also recorded raw data in pencil and changed written data using correction fluid to obscure the original result.

Findings extracted from the letter

Selected FDA passages, not the complete letter.

01
Your firm failed to validate and establish the reliability of your component supplier’s test analyses at appropriate intervals (21 CFR 211.84(d)(2)).
02
Your firm failed to qualify your suppliers and adequately test the components used to manufacture your finished drug products, including pediatric over-the-counter (OTC) **(b)(4)** products. For example,
03
Your firm failed to establish adequate written responsibilities and procedures applicable to the quality control unit and to follow such written procedure (21 CFR 211.22(d)).
04
Failure 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.

What FDA requested

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

  • Comprehensive independent review of material system and supplier qualifications
  • Remaining DEG/EG test results for finished products and retains within 30 days
  • Full risk assessment for products within expiry containing DEG/EG-risk ingredients
  • Risk assessment of components released without appropriate purity, strength, quality testing
  • Review of microbial effectiveness testing for multi-use non-sterile products with CAPA
  • Chemical and microbiological specifications for each incoming component lot
  • Description of component lot testing and COA validation program with SOP
  • Summary of COA reliability testing results and SOP

Sections and clauses cited

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

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