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 establish and follow appropriate written procedures that are designed to prevent microbiological contamination of drug products purporting to be sterile, and that include validation of all aseptic and sterilization processes (21 CFR 211.113(b)).
Passage 2You failed to demonstrate that your manufacturing process is capable of preventing microbial contamination of your over-the-counter (OTC) drug product, pi yen chin ophthalmic redness reliever drops, containing naphazoline hydrochloride (HCl) 0.1%. For example,
Passage 3Your firm failed to establish and follow an adequate written testing program designed to assess the stability characteristics of drug products and to use results of stability testing to determine appropriate storage conditions and expiration dates (21 CFR 211.166(a)).
Passage 4Your 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 5Your firm failed to thoroughly investigate unexplained discrepancies and out-of-specification (OOS) results. For example,
Passage 6Your firm failed to clean, maintain, and, as appropriate for the nature of the drug, sanitize and/or sterilize equipment and utensils at appropriate intervals to prevent malfunctions or contamination that would alter the safety, identity, strength, quality, or purity of the drug product beyond the official or other established requirements (21 CFR 211.67(a)).
Citations in the original letter
As cited in this historical letter, not a statement of current regulatory requirements.
- 21 CFR 200.50(a)(1)
- 21 CFR 201.128
- 21 CFR 210
- 21 CFR 211.113(b)
- 21 CFR 211.166(a)
- 21 CFR 211.192
- 21 CFR 211.67(a)
- 21 CFR 330
- 21 CFR 349.18(b)
- 21 CFR 349