Selected passages from the FDA letter
Quoted FDA text from the published dataset. These selected excerpts are not the complete letter.
Passage 1You failed to test your purchased bulk water to assure it was of acceptable quality for use in drug production. You also failed to establish the reliability of your component supplier at appropriate intervals. Your firm has not demonstrated that the water was suitable for its intended use and minimally met the USP purified water monograph.
Passage 2Your 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 3You failed to adequately investigate finished drug product sample results that were out of limit (OOL) for microbiological contamination. For example, you failed to identify a root cause and implement adequate CAPA. You state that you have rejected and destroyed the contaminated batch, however, you could not provide supporting documentation.
Passage 4Your 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 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 207
- 21 CFR 207.57(b)
- 21 CFR 207.57(b)(2)
- 21 CFR 210
- 21 CFR 211.22(a)
- 21 CFR 211.84(d)(1)
- 21 CFR 211.84(d)(6)
- 21 CFR 211.192
- 21 CFR 211.165(b)
- 21 CFR 211.22
- 21 CFR 211.22(d)
- 21 CFR 211.160(b)
- 21 CFR 211.100(a)