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 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 2You failed to adequately investigate contamination identified in your drug products.
Passage 3Your firm failed to adequately investigate and determine the root cause of glass particulate contamination in multiple batches of Cyanocobalamin Injection USP 1000mcg/mL, 1mL found out of limits (OOL) or above alert limits. Without identifying a root cause, you conducted successive visual inspections of batches until glass particulates were within specification and then released batches of Cyanocobalamin Injection USP 1000mcg/mL, 1mL, even though there was potential for glass contamination.
Passage 4Your firm failed to establish and follow appropriate written procedures that are designed to prevent microbiological contamination of drug products purporting to be sterile, and that include validation of all aseptic and sterilization processes (21 CFR 211.113(b)).
Passage 5You failed to ensure adequate aseptic behavior and adequate airflow simulations to prevent potential contamination.
Passage 6Your firm failed to establish adequate written procedures for production and process control designed to assure that drug products you manufacture have the identity, strength, quality, and purity they purport or are represented to possess, and to follow all of your written production and process control procedures (21 CFR 211.100 (a) and 211.100 (b).
Citations in the original letter
As cited in this historical letter, not a statement of current regulatory requirements.
- 21 CFR 210
- 21 CFR 211.192
- 21 CFR 211.113(b)
- 21 CFR 211.100