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    1. Warning Letter: Failure to control security (ucm145034)

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      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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    2. Warning Letter: Computer security (g1148d)

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      References
      computer security
      , using another person's login - "During the inspection, FDA investigators documented violations of Section 501 (a) (2)(B) of the Federal Food. Drug and Cosmetic Act (the Act) and deviations from the applicable
      standards and requirements
      of Title 21, Code of Federal Regulations, Parts 211 and 600-680, Subchapter F, (21 CFI? 211 and 600- 680)..."

      View the original warning letter.


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    3. Warning Letter: Lack of system controls (g1113d)

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      References electronic records (custom database, global action plan) - "The inspection revealed that the
      device is adulterated
      within the meaning of section 501(h) of the Act, in that the methods used in, or the facilities or
      controls used for the manufacture
      , processing, packing, storage or distribution are not in conformance with the requirements of the Quality System Regulation..."

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    4. Warning Letter: Uncontrolled database (m4116n)

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      "...It is also noted in the inspection report that you do not have adequate control over the receipt of study data and its subsequent input into the database. There are no records to show when study data is received and when it is entered into the database. There is also no
      audit trail for changes made to the database
      . No data queries or clarifications have ever been generated and sent to the sites to verify missing information or to clarify discrepancies...
      Electronic records, the subject of SOP-100-720
      , Electronic Database Maintenance, are subject to 21 CFR Part 11- Electronic Records; Electronic Signatures, as well as to the record keeping regulations found in 21 CFR 812.140. A guidance document regarding this regulation, Computerized Systems Used in Clinical Trials, dated April 1999. www.fda.gov/ora/compliance ref/bimo/ffinalcct.htm"

      View the original warning letter.


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    5. Warning Letter: Failure to have appropriate controls (m3955n)

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      "
      Failure to have appropriate controls
      over computer or related systems to assure that
      changes in records
      are instituted only by authorized personnel, as required by 21 CFR 211.68(b). For example, see FDA-483 observation 12."

      View the original warning letter.


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    6. Warning Letter: Failure to maintain original data (m3847n)

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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.

      View the original warning letter.


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    7. Warning Letter: Failure to implement controls (m3488n)

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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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    8. Warning Letter: Deviations from Part 11 (m2811n)

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      "our inspection disclosed numerous and
      significant deviations from part 11
      . Examples include: The system does not generate an
      audit trail
      , and there is no way to determine if values have been changed on batch production records. This is important because an audit trail can be the only
      evidence that an electronic record has been altered
      . We note, for instance, that your system only records the last value entered by an operator and that values, such as Oxygen potency levels that my have been entered earlier and that may indicate potentially serious quality problems, are not recorded. The system prompts an operator when equipment detects that an Oxygen potency value is non-conforming, and permits the operator to record a value that is within specification, but does not record the original out of specification value."

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    9. Warning Letter: Improper maintenance of electronic records (m2819n)

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      "Failure to
      maintain laboratory records
      to include complete data derived from all tests necessary to
      assure compliance with established specifications
      and standards [2 1 CFR 211. 194]. Specifically, your firm failed to properly maintain electronic files containing data secured in the course of tests from 20 HPLCS and 3 GLCS. Additionally, no investigation was conducted by your company to determine the cause of missing data and no corrective measures were implemented to prevent the recurrence of this event."

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