FDA warning letter · Biologics

Utah Cord Bank LLC

Issued · Posted by FDA

Selected passages from the FDA letter

Quoted FDA text from the published dataset. These selected excerpts are not the complete letter.

Passage 1

Failure to validate and approve a process according to established procedures where the results of processing cannot be fully verified by subsequent inspections and tests. The validation activities and results must be documented, including the date and signature of the individual(s) approving the validation [21 CFR 1271.230(a)]. For example:

Passage 2

Failure to establish and maintain procedures appropriate to meet core CGTP requirements for all steps that you perform in the manufacture of HCT/Ps. You must design these procedures to prevent circumstances that increase the risk of the introduction, transmission, or spread of communicable diseases through the use of HCT/Ps [21 CFR 1271.180(a)]. For example, you have not established and maintained procedures that include, but are not limited to the following:

Passage 3

Failure to maintain records concurrently with the performance of each step required in Subpart D and Subpart C of 21 CFR 1271. The records must identify the person performing the work and the dates of the various entries, and must be as detailed as necessary to provide a complete history of the work performed and to relate the records to the particular HCT/P involved [21 CFR 1271.270(a)]. For example, you have not maintained complete records that include, but are not limited to, the following:

Citations in the original letter

As cited in this historical letter, not a statement of current regulatory requirements.

  • 21 CFR 1271
  • 21 CFR 1271.190(d)
  • 21 CFR 1271.220
  • 21 CFR 1271.230(a)
  • 21 CFR 1271.3(ff)
  • 21 CFR 1271.195(c)
  • 21 CFR 1271.180(a)
  • 21 CFR 1271.195
  • 21 CFR 1271.200(b)
  • 21 CFR 1271.210
  • 21 CFR 1271.250
  • 21 CFR 1271.260
  • 21 CFR 1271.265
  • 21 CFR 1271.270(a)
  • 21 CFR 1271.195(d)
  • 21 CFR 1271.200(e)
  • 21 CFR 1271.210(d)
  • 21 CFR 1271.260(e)
  • 21 CFR 1271.215
  • 21 CFR 1271.320(b)