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 conduct, for each batch of drug product, appropriate laboratory testing, as necessary, required to be free of objectionable microorganisms (21 CFR 211.165(b)
Passage 2Your firm failed to conduct testing for **(b)(4)** for non-sterile **(b)(4)** drug products prior to release and at appropriate intervals for stability. See FDA’s guidance document, *Microbiological Quality Considerations in Non-sterile Drug Manufacturing*, for help minimizing the risks of harmful microbiological contamination of **(b)(4)** drugs at https://www.fda.gov/regulatory-information/search-fda-guidance-documents/microbiological-quality-considerations-non-sterile-drug-manufacturing.
Passage 3You failed to perform adequate testing for purity, strength, quality, and identity for the components used in the manufacture of your **(b)(4)** drug products. In addition, you relied on your suppliers’ certificates of analysis (COA) without establishing the reliability of your component suppliers’ test analyses at appropriate intervals.
Passage 4Failure to address violations may also cause FDA to withhold issuance of Export Certificates. FDA may withhold approval of new applications or supplements listing your firm as a drug manufacturer until any violations are completely addressed and we confirm your compliance with CGMP. We may re-inspect to verify that you have completed corrective actions to address any violations.
Citations in the original letter
As cited in this historical letter, not a statement of current regulatory requirements.
- 21 CFR 201.128
- 21 CFR 207.57(b)(1)(ii)
- 21 CFR 207.29(a)(1)
- 21 CFR 210
- 21 CFR 211.22
- 21 CFR 211.100
- 21 CFR 211.165(b)
- 21 CFR 211.84(d)(1)
- 21 CFR 211.22(d)
- 21 CFR 211.22(a)
- 21 CFR 211.100(a)
- 21 CFR 211.22(c)