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 thoroughly investigate any unexplained discrepancy or failure of a batch or any of its components to meet any of its specifications, whether or not the batch has already been distributed (21 CFR 211.192).
Passage 2Your firm failed to follow an adequate written testing program designed to assess the stability characteristics of drug products (21 CFR 211.166(a)).
Passage 3You failed to follow your written stability procedure for your finished drug products. For example, you did not complete timely stability testing for approximately **(b)(4)** stability samples for U.S. commercial drug products within the stipulated timeline (**(b)(4)** after sample pull). Stability testing was overdue by 3 months or longer for a large proportion of your samples.
Passage 4Your 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)).
Passage 5Your firm failed to perform method validation (or verification, as appropriate) of test methods to ensure they were suitable for their intended use. Your senior leadership confirmed multiple test methods used for incoming API and drug product testing of quality attributes, such as **(b)(4)** content, identification, and specific rotation, have not been validated, verified, or appropriately transferred.
Citations in the original letter
As cited in this historical letter, not a statement of current regulatory requirements.
- 21 CFR 210
- 21 CFR 211.192
- 21 CFR 211.166(a)
- 21 CFR 211.160(b)