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 have, for each batch of drug product, appropriate laboratory determination of satisfactory conformance to final specifications for the drug product, including the identity and strength of each active ingredient, prior to release. Your firm also 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(a) and 211.165(b)).
Passage 2You failed to conduct identity, strength, and impurity testing for your finished drug products. Also, you did not perform testing for microbiological attributes such as total counts and objectionable microorganisms for your finished drug products. In addition, you had not established finished drug product specifications since drug product manufacturing began in November 2020.
Passage 3Your firm failed to conduct at least one test to verify the identity of each component of a drug product. Your firm also failed to validate and establish the reliability of your component supplier’s test analyses at appropriate intervals (21 CFR 211.84(d)(1) and 211.84(d)(2)).
Passage 4You failed to ensure that incoming lots of active pharmaceutical ingredient (API) were suitable for use in manufacturing.
Passage 5Failure 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 210
- 21 CFR 211.22
- 21 CFR 211.100(a)
- 21 CFR 211.67(a)
- 21 CFR 211.137(a)
- 21 CFR 211.165(a)
- 21 CFR 211.84(d)(1)