In addition to the above listed violations, our Investigator noted that the laboratory is using an electronic record system for processing and storage of data from the atomic absorption and HPLC instruments that is not set up to control the security and data integrity in that the system is not password controlled, there is no systematic back-up provision, and there is no audit trail of the system capabilities. The system does not appear to be designed and controlled in compliance with the requirements of 21 CFR, Part 11, Electronic Records.
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Failure to maintain complete data from all laboratory tests as required by 21 CFR 211.94 (a). There is no back-up file for laboratory UV spectrophotometer test results for some tests. The spectrophotometer does not automatically back-up data and the analyst is required to assign an identification number to each individual chromatogram in order for it to be saved. In some cases, original data was lost and the tests had to be performed again to determine final distribution of the lots.
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Your firm failed to implement appropriate controls over your High Performance Liquid Chromatography (HPLC) to assure that only authorized changes can be made. It was noted during the inspection that there is an option on the HPLC that allows analysts to delete results after they are processed.
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