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    1. Warning Letter: Failure to have laboratory control records that include complete data (ucm516163)

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      Our inspection found that analysts performed multiple gas chromatography (GC) analyses of [redacted] samples for residual solvents. Analysts performed these unofficial analyses and recorded them in separate “R&D” folders before conducting the officially reported sample analyses. The original, unofficial analyses stored in separate R&D folders were not part of the official quality control records for your API, and your firm did not consider the results of these unofficial analyses to evaluate the quality of your API or make batch release decisions for numerous batches of API.

      Our investigator reviewed chromatograms found in the R&D folders and noted that some displayed large unknown peaks that were not reported in the official records for the same samples. The presence of such peaks in the chromatograms may indicate the presence of unknown and uncharacterized impurities (including potential contaminants) in your drugs.

      View the original warning letter.


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    2. Warning Letter: Failure to validate computer software for its intended use (ucm515340)

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      Failure to ensure that when computers or automated data processing systems are used as part of production or the quality system, the manufacturer shall validate computer software for its intended use according to an established protocol, as required by 21 CFR 820.70(i).

      View the original warning letter.


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    3. Warning Letter: Failure to exercise sufficient controls (ucm502347)

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      Failure to exercise sufficient controls over computerized systems to prevent unauthorized access or changes to data, and to provide adequate controls to prevent omission of data.

      Our investigator found that your [redacted] system used for [redacted] and [redacted] testing lacked access controls and audit trail capabilities. For example, all employees had administrator privileges and shared one user name, so actions could not be attributed or traced to specific individuals. This exposed your electronic data to manipulation and/or deletion without traceability.

      Our investigator also noted that your firm copied raw data to a CD [redacted], and then deleted the data from the [redacted] system to free space on the hard drive. Files copied to the CD were selected manually; the selection process was not supervised. Without audit trail capabilities or supervised file selection, there was no assurance that all raw data files were copied to the CD before they were permanently deleted from the system.

      View the original warning letter.


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    4. Warning Letter: Failure to prevent unauthorized access or prevent omission of data (ucm501282)

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      Failure to prevent unauthorized access or changes to data, and to provide adequate controls to prevent manipulation and omission of data.

      During the inspection, an FDA investigator discovered a lack of basic laboratory controls to prevent changes to your firm’s electronically stored data and paper records. Your firm relied on incomplete records to evaluate the quality of your drugs and to determine whether your drugs conformed with established specifications and standards.

      …..Specifically, your Quality Control (QC) analysts used administrator privileges and passwords to manipulate your high performance liquid chromatography (HPLC) computer clock to alter the recorded chronology of laboratory testing events.

       

      View the original warning letter.


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    5. Warning Letter: Failure to validate computer software for its intended use (ucm515403)

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      Your firm has not performed software validation [redacted]. These programs are used in the Starlight laser product family.

      b. The software validation for [redacted] is inadequate, in that the [redacted]. This message occurs when either the maximum voltage (6V) is exceeded, or the actual voltage is higher than the reference voltage associated with the intensity selected by the operator.

      Failure to validate computer software for its intended use according to an established protocol, when computers or automated data processing systems are used as part of production or the quality system, as required by 21 CFR 820.70(i). For example, your firm has not validated the following software used in its quality system:

      View the original warning letter.


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    6. Warning Letter: Data Integrity Issues (ucm495778)

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      Notification to Pharmaceutical Companies: Clinical and Bioanalytical Studies Conducted by Semler Research Are Unacceptable

      “FDA is notifying sponsors of New Drug Applications (NDAs) and Abbreviated New Drug Applications (ANDAs) that clinical and bioanalytical studies conducted by Semler Research Private Limited (Semler) located in Bangalore, India, are not acceptable as a result of data integrity concerns, and need to be repeated… The inspection found significant instances of misconduct and violations of federal regulations, including the substitution and manipulation of study subject samples.

      “Specifically, the WHO examined company computer servers and found a spreadsheet file containing detailed instructions for manipulating drug samples that were used in clinical trials for its clients.”

      View the original warning letter.


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    7. Warning Letter: Unauthorized Access (ucm496623)

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      Failure of computerized systems to have sufficient controls to prevent unauthorized access or changes to data.

      Your firm’s computer system for entering test results and storing certificates of analysis (CoA), which document whether a drug meets specifications, does not have sufficient controls to prevent unauthorized changes to a CoA after quality unit approval.

      During the inspection, our investigator reviewed [redacted] CoA stored on computer #16, all of which were approved by the quality unit. A manager demonstrated for our investigator how results on an already finalized CoA could be manipulated after the formal quality unit approval. Also, the quality unit’s electronic signatures on these CoA were uncontrolled images of signatures rather than certificate-based electronic signatures.

      View the original warning letter.


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    8. Warning Letter: Data falsification and manipulation (ucm489735)

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      Your firm failed to ensure that laboratory records included complete data derived from all tests necessary to assure compliance with established specifications and standards (21 CFR 211.194(a)).

      During our inspection, we observed multiple examples of incomplete, inaccurate, or falsified laboratory records.

      View the original warning letter.


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    9. Warning Letter: Validation not documented (ucm489358)

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      There is no change control procedure or documentation for moving from Computer Numeric Control process.

      Failure to establish and maintain procedures for changes to a specification, process, or procedures, as required by 21 CFR 820.70(b). Specifically,

      On or about 5/12/2014, you had your contract manufacturer change from using Computer Numeric Control process to a hydroforming process to manufacture the ONE TRAY. You have not established process change procedures nor has this change been documented and verified/validated.

      Your November 10, 2015 response cannot be assessed at this time. Your response states that you will fully document the validation activities performed to support the new manufacturing process; and will update your agreement with the contract manufacturer to address process changes. Please provide an update on the progress of these corrective actions.

      View the original warning letter.


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    10. Warning Letter: Failure to establish and maintain adequate procedures (ucm515974)

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      Failure to establish and maintain adequate procedures for implementing corrective and preventive action (CAPA), as required by 21 CFR 820.100(a). For example:

      a. Your firm’s CAPA procedure, [redacted], only requires that nonconformances will be reviewed every [redacted]. However, the procedure does not require analysis of quality data, including quality records, complaints and returned products, for potential CAPA.

      View the original warning letter.


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