Selected passages from the FDA letter
Quoted FDA text from the published dataset. These selected excerpts are not the complete letter.
Passage 1Your firm lacked an adequate quality unit (QU) to exercise appropriate procedures and controls to ensure your over-the counter (OTC) drug products are manufactured in compliance with CGMP.
Passage 2your CMO lacks an adequately designed aseptic processing room where ophthalmic drop products are manufactured and has not performed the following: • Dynamic airflow visualization studies for aseptic processing
Passage 3• (b)(4) effectiveness testing for benzalkonium chloride containing ophthalmic products
Passage 4“Green Glo, NDC 17238-920,” “BioGlo, NDC 17238-900,” and “Vista Gonio Eye Lubricant, NDC 77790-022” are manufactured at (b)(4) and (b)(4), establishments that are not duly registered with FDA. Under section 502(o) of the FD&C Act, a drug is misbranded if it was manufactured in an establishment not duly registered under section 510. Therefore, “Green Glo, NDC 17238-920,” “BioGlo, NDC 17238-900,” and “Vista Gonio Eye Lubricant, NDC 77790-022” are misbranded drugs under section 502(o) of the FD&C Act.
Citations in the original letter
As cited in this historical letter, not a statement of current regulatory requirements.
- 21 CFR 207
- 21 CFR 211.22