Drugs

Gulf States International, Inc.

FDA issued a warning letter to Gulf States International, Inc. (Union Springs, AL, United States) on Sep 12, 2023. Subject: Refusal to Provide Access to and Copying of Records.

From the letter: “On September 9, 2022, the FDA sent an electronic request for records and other information pursuant to section 704(a)(4) of the Federal Food, Drug, and Cosmetic Act (FD&C Act), 21 U.S.C. 374(a)(4), to the contact e-mail address provided in…”

Union Springs, AL, United StatesIssued Sep 12, 2023Posted Sep 26, 2023No close-out recorded

At a glance

What a reviewer notes before reading: findings, citations, the response deadline and what the letter warns of.

Violations
1 finding · 1 issue type
Cited
No CFR or ISO section
Response due
Not stated in the letter
FDA asks for
3 actions
Named as possible actions
Refusal of admission
Issued by
Center for Drug Evaluation and Research
Published status
No close-out recorded

AI assisted findings

Model-assisted reading of each issue. Open one to see the FDA text it comes from, and check it against the full letter.

01Records & data integrity · 21 U.S.C. 374(a)(4), 21 U.S.C. 331(e)The firm failed to respond to FDA's records requests under section 704(a)(4), constituting a refusal to permit access to or copying of records as required, which is a prohibited act under section 301(e).
On September 9, 2022, the FDA sent an electronic request for records and other information pursuant to section 704(a)(4) of the Federal Food, Drug, and Cosmetic Act (FD&C Act), 21 U.S.C. 374(a)(4), to the contact e-mail address provided in your registration file. This request went unanswered, as did another email request sent on September 27, 2022. On October 3, 2022, you sent an email acknowledging FDA’s request, but did not respond to the 704(a)(4) request. FDA attempted to contact you by phone on November 16, 2022, and left a voicemail requesting that you provide a response by October 31, 2022. FDA also attempted to contact you by phone on September 6, 2023, and left a voicemail with your firm requesting a response within 24 hours. You failed to respond to these attempted communications or otherwise provide the requested records or other information.
21 U.S.C. 374(a)(4)21 U.S.C. 331(e)Read it in the letter

What FDA requested

  • Provide records and other information pursuant to section 704(a)(4) of the FD&C Act, as requested in the FDA's electronic request sent on September 9, 2022, and subsequent follow-up communications.
  • Confirm or update your registration and/or drug listing status.
  • Indicate whether you will respond to the request for records and other information.

FDA Warning Letter

15 paragraphs · 1 section

Text as published on FDA.gov, retrieved Sep 8, 2026. Layout added for reading; the wording is FDA’s. View on FDA.gov (opens in a new tab)

1Warning Letter 320-23-37

10 paragraphs

September 12, 2023 Dear Mr. Holmes:

Your firm is registered with the United States Food and Drug Administration (FDA or Agency) as a manufacturer of over-the-counter (OTC) drug products; specifically, products listed include (b)(4). On September 9, 2022, the FDA sent an electronic request for records and other information pursuant to section 704(a)(4) of the Federal Food, Drug, and Cosmetic Act (FD&C Act), 21 U.S.C. 374(a)(4), to the contact e-mail address provided in your registration file. This request went unanswered, as did another email request sent on September 27, 2022. On October 3, 2022, you sent an email acknowledging FDA’s request, but did not respond to the 704(a)(4) request. FDA attempted to contact you by phone on November 16, 2022, and left a voicemail requesting that you provide a response by October 31, 2022. FDA also attempted to contact you by phone on September 6, 2023, and left a voicemail with your firm requesting a response within 24 hours. You failed to respond to these attempted communications or otherwise provide the requested records or other information. Pursuant to section 704(a)(4), FDA’s request and follow-up communication included a sufficient and clear description of the records sought.

It is a prohibited act under section 301(e) of the FD&C Act (21 U.S.C. 331(e)) to refuse to permit access to or copying of any record as required by section 704(a).

Because your firm failed to respond to the section 704(a)(4) records requests and associated communication attempts,1 we have no indication of the level of quality assurance for drugs registered as manufactured at your facility.

Respond to this letter within 48 hours to confirm or update your registration and/or drug listing status and indicate whether you will respond to the request for records and other information. If you are no longer manufacturing drugs, delist all the drugs previously listed with FDA, using the last lot expiration date as the marketing end date of the product, and deregister your facility accordingly.

The Agency may conduct an inspection to verify information provided and/or to evaluate the compliance of your manufacturing operations.

Continued non-response regarding questions of the quality assurance of the drugs manufactured at your facility may lead to inclusion on (b)(4).

You may provide additional information for our consideration as we continue to assess your activities and practices.

Send your electronic reply to CDER-OC-OMQ-Communications@fda.hhs.gov.

Identify your response with FEI 3007520648 and ATTN: Rory Geyer.

Sincerely, /S/

Francis Godwin Director Office of Manufacturing Quality Office of Compliance Center for Drug Evaluation and Research, FDA

___________________

1 During the COVID-19 public health emergency, which expired on May 11, 2023, a number of (b)(4) products have been recalled due to quality issues including from substitution with other drug substances, impurities at unacceptable levels, and subpotency. The Agency has reached out to registered OTC drug firms with (b)(4) included in their product listing, to assess the overall quality of the drugs registered as manufactured by these firms.

Citations and trends

Each 21 CFR section, ISO 13485 clause and issue type in this letter, how often it appears across all letters, and its trend by the year FDA issued the letters. 2026 runs to Nov 3, 2026, compared with the same dates last year. Select a row or a bar to see those letters in Letters. As cited in this historical letter, not a statement of current requirements.

This letter cites no 21 CFR section or ISO 13485 clause.

Issue types

Record details

Issuing center
Center for Drug Evaluation and Research
Issuing office
Center for Drug Evaluation and Research
Location
Union Springs, AL, United States
Letter posted date
Sep 26, 2023
Letter issue date
Sep 12, 2023
Addressed to
President and CEO
Inspection dates · model-assisted
Sep 9, 2022 to Sep 6, 2023
Response window
Not verified in this snapshot. Consult the original letter.
Record length
490 words · 4 recorded redactions
Published status
No published close-out
Original letter
View on FDA.gov (opens in a new tab)
Dataset last checked
Nov 11, 2026 · How this is built

A response window is not a calculated due date. Source excerpts are selected passages. Finding interpretations and categories are model-assisted. Verify the original letter before relying on a finding.

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