Showing posts with label the popo of white oak. Show all posts
Showing posts with label the popo of white oak. Show all posts

Wednesday, February 21, 2024

483 of the week: lying QC manager edition

Via FiercePharma, these tidbits from an FDA inspection (PDF) of Sichuan Deebio Pharmaceutical: 
The Form 483 relays an especially troubling event during the inspection when Sichuan Deebio’s quality control team leader provided “misleading information” about records on the results of a microbiology test.

At first, the quality control chief lied about viewing those test results, logging them and leaving them with another team member on a different floor of the facility, the FDA contends in its report. Then she changed tack, claiming she had not read the results, before switching back to a story similar to her first. At last, the QC chief “finally” admitted that she was “not telling the truth about recording the results on respective data worksheets, and no worksheet existed,” investigators wrote in the Form 483.

To make matters worse, investigators subsequently asked the quality leader how she kept track of the test results, to which she replied that they were “in her ‘mind.’”

There's a lot of lab results in my mind (well, there was), but I usually tried to write them down really quickly.  

Friday, June 23, 2023

Ars Technica: Shredded documents found at cisplatin manufacturing facility in India

Via Beth Mole at Ars Technica, this alarming description of the quality problems at a single cisplatin manufacturer that precipitated the current cisplatin and carboplatin shortage: 

The current shortage was triggered late last year when the Food and Drug Administration inspected a drug manufacturing facility owned by Intas Pharmaceuticals in Ahmedabad, India. Inspectors found egregious violations. Afterward, Intas voluntarily shut down the facility, which had supplied around half of the generic cisplatin and carboplatin in the US.

The stunning inspection report, released in January, leaves no doubt as to why the plant was shut down. In addition to various manufacturing violations, including laboratory and quality control problems, inspectors reported finding a truck 150 meters from the facility loaded with plastic bags full of shredded and torn documents. When the inspector dug into the documents, they realized they were quality-control documents and analytical weight slips.

In another instance, the inspection report notes that an employee, upon learning the FDA inspectors were walking through the quality-control lab, ran to the balance room and "immediately rushed and tore apart balance printouts along with Auto Titrator spectrums and threw the torn pieces into the small trash container located next to the balance. Later, he threw [redacted] acid solution inside the same trash in an attempt to destroy the evidence." The bag of torn, acid-soaked reports was later found stuffed under a staircase.

The FDA has since tried working with other manufacturers to boost production of the cancer drugs and is exploring temporarily importing drugs from China to ease the shortage. But many generic drug facilities already work at capacity, making a boost in production difficult to impossible. It's also unclear how much the imported drugs will help.

Pretty old hat stuff, to be honest. For some reason, this seems to be a pretty common thing to find with certain drug manufacturers. Seems to me that the hospitals and pharmacies in the US have cut the prices for these particular drugs a bit too low, and they need to raise the price to keep some decent manufacturers still in the game...

Wednesday, January 18, 2023

Warning Letter of the Week: vermin edition

In a letter to the general manager of Optum Infusion Services, this observation: 

The FDA investigator noted that drug products intended or expected to be sterile were prepared, packed, or held under insanitary conditions, whereby they may have become contaminated with filth or rendered injurious to health, causing your drug products to be adulterated under section 501(a)(2)(A) of the FDCA. For example, the investigator observed that:

1. You did not perform adequate product evaluation and take appropriate corrective action after vermin was observed in your production area. Vermin are a source of microbial contamination. Therefore, your products intended to be sterile were produced in an environment that may not provide adequate protection against the risk of contamination.

Seems bad for a compounding pharmacy!  

Wednesday, July 27, 2022

Warning Letter of the Week: try, try again edition

In a letter to the Chief Executive Officer of Bioiberica, SAU, the Center for Drug Evaluation and Research notes these issues: 

1. Failure to establish written procedures to monitor the progress and control the performance of processing steps that may cause variability in the quality characteristics of your intermediates and API.

You failed to establish appropriate monitoring and controls for reworking batches of [redacted] USP, API. In 2020 and 2021, approximately 23 batches of [redacted] USP, API were reworked in your industrial [redacted] because of microbiological out-of-specification or non-conforming high [redacted], a class 3 residual solvent, content results. The use of the industrial [redacted] was not part of the established process validation for [redacted] USP, API. The investigator documented this [redacted] was used to rework multiple batches from [redacted] to as many as [redacted] times until acceptable results were obtained. No studies had been performed to establish the effectiveness of this rework step. Additionally, your industrial [redacted] was not equipped with real time [redacted] monitoring or a [redacted] summary to monitor the performance of the [redacted].

No product too holy to be reworked, folks! (Guessing that they chose to use a different piece of equipment than what they laid out earlier.) 



Monday, June 14, 2021

FDA releases memo on Emergent Biosolutions cross-contamination problem

Words you do not want to be in a FDA report about your vaccine manufacturing facility (emphasis mine): 

On March 26, 2021, Janssen notified FDA that they had detected AZ COVID-19 Vaccine virus in the Janssen COVID-19 Vaccine DS batch 21003600 (GMP8). This batch was produced during a period when Emergent implemented measures to handle increased waste production.

FDA subsequently engaged actively with Emergent and Janssen to facilitate the investigation of the root cause of this contamination event. It was concluded that most probable contributing root cause was that the bioreactor media prepared for use in the cell expansion process at that time was contaminated in the common weigh and dispense area through contact with the waste path for materials from Area 3 (AZ manufacturing area).

One of the weirder books I have seen in my life (not that weird really) is about GMP design of manufacturing facilities, and when I flipped through the book, there was a section about how you want products to flow in a specific direction, and for there not to be any cross-contamination. Now I guess we know why. 

Friday, October 23, 2020

FDA: Lilly plant making COVID-19 antibody treatment has numerous findings

Via Bloomberg, this unfortunate news: 

U.S. drug-safety inspectors have found continuing quality-control problems problems at a New Jersey plant Eli Lilly & Co. is using to help produce its Covid-19 antibody therapy, posing a potential obstacle to the company meeting its goal of producing 1 million doses by year-end.

In an Oct. 2 memo, Food and Drug Administration compliance officers wrote that findings from an inspection of the facility in July and August “support a major failure of quality assurance.” They noted that Lilly planned to make its antibody therapy at the plant and said the inspection group “feels it is still imperative that FDA take action.”

The assessment was based on a four-week site inspection that ended on Aug. 21, the details of which haven’t previously been reported. The compliance officers recommended that the company receive a warning letter, one of the agency’s strongest enforcement measures, according to documents reviewed by Bloomberg News. Agency inspectors found that in some cases Lilly employees didn’t investigate potential quality problems and routinely overrode testing systems, according to the documents.

...At that time, inspectors found the company’s system for tracking manufacturing quality wasn’t secure and could be accessed and modified by anyone, according to the documents reviewed by Bloomberg...

...In one case described by FDA inspectors, a Lilly employee allegedly used the wrong material in a critical purification step. In another, after routine checks revealed a potential impurity in a drug product, an employee retested it to get a passing result, according to the documents, instead of attempting to figure out why there were signs of an impurity in the sample.Lilly managers downplayed quality missteps in a data-management system FDA has access to during inspections called TrackWise, according to inspection documents. Drugmakers use such workflow tracking systems to record the outcomes of quality checks during the manufacturing process.

A confidential informant told the FDA that Lilly managers documented more details of quality concerns that required personnel action in the company’s human-resources system, according to the Oct. 2 memo. Agency inspectors said in their report that they repeatedly asked to review the human-resources records, but said Lilly refused to grant them access.

It's very surprising to me that there was a computer system without an audit trail in a facility that manufactures a biological. I'd really like to understand the context around the mis-charge of material - I would presume there were about 7 deviations to get there, but I dunno...

I'm looking forward to more context from the inevitable warning letter.

Wednesday, August 5, 2020

Warning Letter of the Week: dancing festival edition

Via a comment at In the Pipeline, this funny missive from the Center for Drug Evaluation and Research to the director of Centurion Laboratories Private Limited (emphasis mine):
3. Your firm failed to follow written procedures for cleaning and maintenance of equipment (21 CFR 211.67(b)). 
During the inspection, our investigator observed that equipment used to manufacture more than one product was inadequately maintained and cleaned. 
For example, our investigator observed in the [redacted] room a [redacted] identified as “cleaned.” However, this [redacted] was found to have visible product build-up inside the [redacted] and [redacted] of the [redacted]. Furthermore, the air filter of the equipment was damaged with multiple holes. This equipment was used to manufacture finished drug products shipped to the United States such as [redacted] tablets, [redacted] tablets, [redacted] tablets, and [redacted] tablets. Additionally, a memo provided during the inspection stated these cleaning and equipment maintenance deficiencies were because of a shortage in manpower related to a nine-day dancing festival and government holiday. Inadequately cleaned and maintained equipment can lead to cross-contamination and variability of drug products.
Must have been a good time. 

Wednesday, March 11, 2020

Warning Letter of the Week: dead legs and rusty pipes edition

From a letter from the Center for Drug Evaluation and Research to the Chairman of the Board of Guangzhou Tinci Materials Technology Co., Ltd.:
Your [redacted] and distribution systems appear to have multiple dead-legs, which can foster the development of biofilms. The piping and installation diagrams for your [redacted] system in your response lack adequate information regarding the slope of the piping. 
Moreover, your [redacted] system lacks proper maintenance. For example, there were visible corrosion on pipes, brackets, fittings, valves, and tanks in the utilities area, which is covered but not completely enclosed from outside elements. During the inspection, you stated that some poorly maintained equipment and piping in the [redacted] utility area is not currently in use. However, during the inspection it appeared that the poorly maintained equipment and piping was still connected to the [redacted] system you use to make components of drugs.
I genuinely didn't know the FDA disapproves of dead legs, although biofilms are a perfectly good reason why. 

Wednesday, February 26, 2020

Warning Letter of the Week: unorganized office edition

From a note from the Center for Drug Evaluation and Research to the owner and general Manager of Yibin Lihao Bio-technical Co., Ltd. in Sichuan, China: 
2. Failure to establish, document, and implement an effective system for managing quality that involves the active participation of management and appropriate manufacturing personnel. 
During the inspection, the investigator observed your firm did not adequately control critical documentation pertinent to the traceability of crude heparin manufactured at your facility. During the walkthrough on July 31, 2019, our investigator observed numerous records on the floor, desks, and cabinets of the Quality Assurance (QA) Office on the third floor of the office building. Some of these records included batch production records for heparin. 
During the inspection, one of your employees stated that these records were generated to support an application for government funding, but the crude heparin batches specified in the records had not actually been manufactured. However, later during the inspection, on August 2, 2019, your firm stated that all the records in the QA Office were in fact associated with genuine crude heparin batches. 
Additionally, even though your Crude Heparin Sodium Inventory and Distribution Record indicated your firm manufactured [redacted] batches of crude heparin (CU190601 to CU190730) from June 1, 2019, to July 30, 2019, your firm was only able to provide complete batch records for two batches, CU190728 and CU190730. 
Traceability of crude heparin is a critical part of managing quality. You must ensure that a complete contemporaneous record of each batch of drug manufactured is retained for CGMP purposes. Your system for managing quality is inadequate and calls into question the traceability of all drugs, including crude heparin. manufactured at your facility.
It's a good thing the FDA hasn't seen my desk...

Wednesday, February 5, 2020

Warning Letter of the Week: scraps of paper edition

In a letter to the general manager of Sunstar Guangzhou Ltd. in Guangdong, Guangzhou, China from the Center for Drug Evaluation and Research, this amusing tidbit:
4. Failure to establish an adequate quality control unit and the responsibilities and procedures applicable to the quality control unit are not in writing and fully followed. (21 CFR 211.22(a) and 211.22(d)). 
Your quality unit (QU) failed to ensure that you have adequate procedures and did not provide adequate oversight of your manufacturing activities. For example: ·
  • You lack adequate control over the issuance, use, and reconciliation of manufacturing batch records and equipment maintenance sheets. Uncontrolled copies of manufacturing batch records and in-process control forms were pre-printed and kept in a room with unrestricted access.
  • Several test reports of your drug product assay were reviewed and the raw data for the standard curve could not be located. It was noted that scrap pieces of paper were used to record data which was later entered to calculate the [redacted] concentration for the assay test.
  • Your firm failed to establish and follow procedures for calculating production yields.
In your response, you stated" ... starting July 2019, relevant personnel will be handed just enough blank forms on a [redacted] basis and they must account for the whereabouts of all blank forms at the [redacted]." You stated that all documents will be archived and procedures will be drafted and/or updated to meet CGMP requirements.
"Scraps of paper" may have described some of my grad school jotted notes, but definitely not my experience in a QC lab...

Wednesday, November 27, 2019

Warning Letter of the Week: Dollar Tree edition

From an epistle from the Center for Drug Evaluation and Research to the President and CEO of Greenbrier International, Inc dba Dollar Tree (emphases mine):
The U.S. Food and Drug Administration (FDA) inspected your corporate headquarters, Greenbrier International, Inc. (Greenbrier) (FEI 3005269673) at 500 Volvo Parkway, Chesapeake, Virginia, from January 14 to 18, 2019 after FDA inspections revealed violative conditions at multiple foreign drug manufacturers that supplied drugs to your distribution network. Firms inspected by FDA included contract manufacturers used to manufacture Dollar Tree's Assured Brand drugs…. 
...Our inspection and review of import data revealed the following: 
2. lmport records reviewed indicated that your firm received various [redacted] and [redacted] drug products from Hangzhou Zhongbo Industrial Company, Ltd., FEI 3008229416, from October through December of 2018. An inspection of Hangzhou Zhongbo Industrial Company, Ltd. in April of 2018 revealed significant CGMP violations, including the failure to test each batch of drug for conformance with specifications prior to release (21 CFR 211.165(a)). As a result of this and other violations, Hangzhou Zhongbo lndustiial Company, Ltd. was placed on Import Alert 66-40 on September 28, 2018 and was issued a warning letter on November 27, 2018. FDA copied your COO on the outgoing warning letter.... 
...We also note that Greenbrier has, at various points in time, used contract manufacturers and suppliers with histories of significant drug CGMP violations. For example, our inspections revealed that beyond the facilities detailed above, your firm has used the following contract manufacturers and suppliers: 
2. Bicooya Cosmetics Limited, FEI 3010671652, which was issued a warning letter on August 11, 2017. This firm was also placed on Import Alert 66-40 on June 29, 2017, for, among other things, not testing finished drug products prior to distribution and for rodent feces found throughout the manufacturing facility. FDA copied your COO on the warning letter.
What’s a little rodent feces between friends? 

Wednesday, November 13, 2019

Warning Letter of the Week: lost in the move edition

A missive from the Center for Drug Evaluation and Research to the president of Bingbing Pharmaceutical Co., Ltd (emphasis mine):
1.    Your firm failed to maintain written production, control, or distribution records specifically associated with a batch of a drug product for at least one year after the expiration date of the batch (21 CFR 211.180(a)). 
You manufactured drugs at your Wuhan facility at Building [redacted], No. 5, Kangda Street, Longyang Avenue, Hanyang District, Wuhan, and then transferred drug production to your Hubei facility and closed the Wuhan facility. Your firm failed to maintain manufacturing records, raw material and finished product testing records, retain samples, stability samples, and other CGMP records for your over-the-counter (OTC) [redacted] drug products manufactured at your Wuhan facility. During the inspection at the Hubei facility, you stated that you lost CGMP manufacturing documentation and drug product samples during the transfer of your manufacturing facility from Wuhan to Hubei in May 2018.
Yep, happens all the time in moves. You put your batch records in the box, the box gets loaded onto a truck, stuff gets moved around, it gets lost! 

Wednesday, October 16, 2019

Warning Letter of the Week: gritty cracking edition

A missive from the Center for Drug Evaluation and Research to the Chairman & Managing Director of Glenmark Pharmaceuticals Limited in Mumbai, India: 
Your 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 the batch has already been distributed (21 CFR 211.192). Your firm failed to ensure your investigations identify appropriate root causes and you failed to implement sustainable corrective action and preventive action (CAPA). 
a. You failed to thoroughly investigate multiple complaints of grittiness for your topical [redacted] cream USP, [redacted]%. Since November 2017, you rejected 20 batches and received at least 38 complaints about product grittiness. Product grittiness has been an ongoing formulation issue since 2010 and was a deficiency cited in the previous inspection of your facility. You proposed specific remediation for this formulation issue in your response at that time. In your response to the most recent inspection, you stated that the product grittiness issue was remediated during product reformulation in November 2018. Your response is inadequate. You did not provide sufficient data to demonstrate the robustness of the new formulation... 
d. You failed to adequately investigate more than 70 consumer complaints associated with punctures, cracks, and holes in [redacted] for various drug products including, but not limited to, [redacted] ointment USP, [redacted]%, [redacted] cream USP, and [redacted] ointment USP, [redacted]%. Your investigations failed to adequately address the scope and cause of these serious container/closure system defects and evaluate other drug products that have similar manufacturing quality signals such as complaints, or that use the same supplier. 
In your response, you stated that the root cause for the complaints was improper “handling by folding and refolding of the [redacted]” by consumers. In addition, you stated that because the complaint rate is insignificant, there is no risk to marketed batches. However, you closed more than 50 of the complaints, without CAPA to prevent recurrence of similar quality defects.
I like the "blame the root cause on the customer" approach - that's a new one.  

Wednesday, September 11, 2019

Warning Letter of the Week: pre-approved batch records

A missive from the Center for Drug Evaluation and Research to the President of Enprani Co., Ltd. in Seoul, South Korea (emphasis mine) 
2. Your firm failed to establish an adequate quality control unit with the responsibility and authority to approve or reject all components, drug product containers, closures, in-process materials, packaging materials, labeling, and drug products (21 CFR 211.22(a)). 
During the inspection, our investigator observed that your quality unit (QU) lacks adequate oversight for the manufacture of your OTC [redacted] drug products. For example:
  • Your QU failed to review entire batch records, including raw data and calculations for accuracy, before making appropriate release determination.
  • Your batch records were pre-printed as “approved” indicating the assay results were in specification, even before these values are recorded.
  • Label review and line clearance were not performed and documented in batch production and control records.
Pre-printing approvals - how come I never thought of that? 

Wednesday, August 28, 2019

Warning Letter of the Week: naughty sonicator edition

From a letter to the Director of CTX Lifesciences Private Ltd. from the Center for Drug Evaluation and Research: 
2.    Failure to adequately investigate out-of-specification results and implement appropriate corrective actions. 
You invalidated an out-of-specification (OOS) related substances test result for API [redacted] batch [redacted], listed in a pending drug application, without scientific justification. 
In your response, you stated that you performed an investigational hypothesis study to evaluate the effect of sonication on API [redacted] batch [redacted]. You concluded that [redacted] generated an unknown impurity at the same relative retention time (RRT) and similar percentage peak area as the OOS result. 
Your response is inadequate because you did not adequately investigate all potential causes of the unknown impurity. You attributed the OOS result to degradation caused by [redacted], a sample preparation step performed during your test procedure. You also did not provide adequate scientific justification for your OOS result root cause. We note that three other batches of API [redacted] followed this [redacted] preparation and analysis procedure during the same sequence with no OOS results for these [redacted] batches.
Blaming the sonicator is a new one on me! 

Wednesday, August 7, 2019

FDA: Novartis “mismanaged” or “manipulated" approval data for gene therapy

The drug maker Novartis concealed manipulated data from the Food and Drug Administration while applying for approval of an extremely expensive gene therapy treatment and then delayed reporting the issue, the agency said on Tuesday. Officials said the inaccurate data, which involved testing in mice of two different strengths of the treatment, did not affect the safety or efficacy of the therapy, Zolgensma, used to treat a rare, often fatal genetic disease called spinal muscular atrophy. 
Approved in May, the treatment’s price — set at $2.1 million — stoked concerns about the astronomical costs of potential cures for rare diseases and upset parents who initially could not get insurance coverage for the breakthrough treatment. The F.D.A. said patients were not at risk, and that the treatment could still be sold.... 
...The F.D.A. said it was notified of the data manipulation issue on June 28, more than one month after Zolgensma was approved, even though officials at AveXis, the Novartis unit developing the product, learned of the problem in March. 
The problems involved experiments on mice used in early phases of the research. An F.D.A. inspection report dated July 24 to Aug. 2, 2019 noted lapses and discrepancies in record-keeping by the company, and improper procedures in quality control in gathering data on the mice. In some instances, the report said, records stating how long the mice lived “were different from the actual value,” and in four cases “discrepancies of greater than one day were noted (ranging from 2 to 19 days).” 
The F.D.A. said the data were “mismanaged” or “manipulated,” and declined to say whether the information was deliberately falsified. “It’s unclear to us, at this point, exactly why this occurred,” Dr. Marks said. In data manipulation cases, he added, the motive is not always clear. “Many times people do things for stupid reasons, because if they would have left well enough alone, everything would have been O.K.”
I wonder how difficult it was to discuss the data manipulation episode within the company? I can't imagine the meetings about that were easy, and I could imagine heads rolling as a result. Here's hoping that there is an innocent answer, for the sake of the relevant people...

Wednesday, July 24, 2019

Warning Letter of the Week: tell-tale PLC edition

1.  Your firm failed to prepare batch production and control records with complete information relating to the production and control of each batch of drug product produced (21 CFR 211.188). 
Compression machine process control values were not adequately reported in your batch production records during the manufacture of [redacted]mg tablets intended for the U.S. market. Your quality unit used these deficient records to release batches of this drug product. 
While multiple batch records of [redacted]mg tablet included handwritten values routinely within process parameters, the values recorded by the programmable logic controller (PLC) of your compression machine were frequently outside your established process parameters. For example, [redacted]mg batch [redacted]had compression force values handwritten [redacted]in the batch record ranging from [redacted](your limit was (b)(4)). 
However, the PLC data recorded individual values ranging from [redacted]for the same time period. In addition to compression force values, handwritten values for filling depth and automatic weight control (AWC) did not accurately reflect the values within the PLC data. 
An inspection conducted by the [redacted]in March 2018 found similar discrepancies between the compression force values in batch records and PLC data.
I feel like the last few letters have shown a fair bit of detective work by the inspector - looking up PLC values couldn't have been super easy....

Wednesday, July 17, 2019

Warning Letter of the Week: inadvertent scrap yard edition

In a missive from the Center for Drug Evaluation and Research to the Managing Director of Strides Pharma Science Limited in Bangalore, India: 
1.  Your firm failed to establish an adequate quality control unit with the responsibility and authority to approve or reject all components, drug product containers, closures, in-process materials, packaging materials, labeling, and drug products (21 CFR 211.22(a)). 
Your quality unit (QU) lacks appropriate responsibility and control over your drug manufacturing operations. 
During the inspection, our investigator observed discarded CGMP documents and evidence of uncontrolled shredding of documents. For example, multiple bags of uncontrolled CGMP documents with color coding indicating they were from drug production, quality, and laboratory operations were awaiting shredding. Our investigator also found a blue binder containing CGMP records, including batch records for U.S. drug products, discarded with other records in a 55-gallon drum in your scrap yard. CGMP documents in the binder were dated as recently as January 21, 2019: seven days before our inspection. Your QU did not review or check these documents prior to disposal. 
...The uncontrolled destruction of CGMP records, and your lack of adequate documentation practices, raise questions about the effectiveness of your QU and the integrity and accuracy of your CGMP records. 
In your response you state the binder of CGMP documents in your scrap yard was “inadvertently come [sic] to scrap yard” and that you were investigating the issue....
You hate it when controlled documents end up in a 55-gallon drum in a scrap yard... 

Wednesday, July 3, 2019

Warning Letter of the Week: short attention span edition

In a note to the Managing Director of Aurobindo, this amusing comment from the Center for Drug Evaluation and Research (emphasis mine):
1.  Changes to methods or controls were not reported to FDA through a supplement to an approved [redacted]. (21 CFR 314.97(a) and 314.70(c)(6)(i)) 
...Investigators observed, in your [redacted] API, non-carcinogenic impurities of [redacted] and [redacted] at levels up to [redacted]% and [redacted]%, respectively, in residual solvent testing for [redacted] API batches. These impurities are present in drug substances at levels exceeding the [redacted] USP specification limit for Any other individual impurity (i.e. NMT [redacted]%). These impurity levels are also above the ICH Q3A(R2) reporting threshold for drug substance impurities. 
Your Quality Unit failed to report to FDA these impurities, which were also above your internal reporting threshold limit of no more than [redacted]%. You updated the information in your Drug Master File (DMF) only after FDA investigators communicated during the inspection that you should be reporting all observed impurities above the reporting threshold.  
In your response, you explained a “scheduled regulatory update skipped our attention.” In addition, you stated you would undertake an additional CAPA for controls of residual solvents. Your response is inadequate, as you did not commit to conduct a full review of all impurities observed in all your APIs above the reporting threshold and ensure that your DMFs and [redacted] are updated accordingly...
I hate it when things skip my attention. 

Wednesday, June 19, 2019

Warning Letter of the Week: casual batch record edition

Via an epistle from the Center for Drug Evaluation and Research to the Plant Manager of Vida International, Inc. in Taipei City, Taiwan:
The batch production record for lot [redacted] of [redacted] is deficient because it does not represent the formula and ingredients that the product purports on its label. Specifically, the batch record does not list all inactive ingredients included on the product label. The batch record also lacked the actual amounts of each active and inactive ingredient used during manufacturing, a calculation of theoretical or actual yields, documentation of the equipment used, and critical manufacturing parameters such as [redacted] speeds and [redacted] times.
Eh, just throw the stuff in there, let it stir around for a while, take it out.