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 ensure that laboratory records included complete data derived from all tests necessary to ensure compliance with established specifications and standards (21 CFR 211.194(a)).
Passage 2You failed to accurately document microbiology sampling and testing results for components used in your over-the-counter (OTC) drug products.
Passage 3Your 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 4You failed to adequately validate your alternative microbial methods used to test drug products to assure the methods were equivalent to or better than United States Pharmacopeia (USP) methods.
Passage 5Your firm failed to exercise appropriate controls over computer or related systems to assure that only authorized personnel institute changes in master production and control records, or other records (21 CFR 211.68(b)).
Citations in the original letter
As cited in this historical letter, not a statement of current regulatory requirements.
- 21 CFR 210
- 21 CFR 211.194(a)
- 21 CFR 211.160(b)
- 21 CFR 211.68(b)
- 21 CFR 211.22