3. Failure to properly maintain buildings used in the manufacture of API in a clean condition.Gotta say, "foul odors" is one that I haven't seen before.
For example, our investigator observed filth, insects, wet layers of [redacted] unidentified material on the floors, and foul odors in the cold rooms used to store raw materials and intermediates used in the manufacture of your finished API. Firm officials noted that the rooms had never been cleaned.
We acknowledge your corrective actions, including cleaning, and adding the cold rooms to your pest control program.
(How is that not a discretionary judgment on the part of the inspector? Granted, if you're smelling something rotting, it's probably a prima facie case of your warehousing not being sufficiently clean.)