Your firm failed to maintain complete and accurate records from which unsuitable donors could be identified so that products from such individuals would not be distributed [21 CFR 606.160(e)] and records to identify the person performing the work so to provide a complete history of the work performed [21 CFR 606.160(a)(1)]. Specifically, when the investigators requested a search of some of the various donor permanent deferral codes in your [redacted] database, 72 donors had various permanent deferral codes entered into the “Comment” field but these donors did not have a permanent deferral status entered into the “Deferral Code” field of the [redacted] database. The “Comment” field is not referenced for identification of deferred donors. Out of 72 donors, 10 were verified to meet the criteria for permanent deferral.
Failure to validate computer software for its intended use according to an established protocol, as required by 21 CFR 820-70(i). For example:
[redacted]software validation has not been completed.
[redacted] software validation plan does not address the user requirements of inputting data into the [redacted] spreadsheet used as a tool for trending.
[redacted] software used for trending has not been validated for its intended uses.
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.
- "...Our inspection disclosed that these devices are adulterated within the meaning of Section 510(h) of the Act, in that the methods used in, or the facilities or controls used for manufacturing, packing and storage are not in conformance with the Good Manufacturing Practice (GMP) requirements for the Quality System Regulation as specified in Title 21, Code of Federal Regulation (CFR), Part 820, as follows..."
References validation and lab documentation - "...requires that all drugs be manufactured, processed, packed, and held according to current good manufacturing practice. No distinction is made between active pharmaceutical ingredients and finished pharmaceuticals, and failure of either to comply with CGMP constitutes a failure to
, 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)..."
The computer software your firm uses to determine metals analysis is deficient. It has no security measures to prevent unauthorized access of the software, no audit trails, and data can be copied or changed at will, with no documentation of the copying or changes. Your procedures do not require the documentation of calculation or entry errors. There is no documentation to indicate that analysts are trained in the software and its applications.
that uses Coordinate Measuring Machines (CMMs) to perform the only full-dimensional verification performed on the implant products fabricated in-house using Computer Numerical Control (CNC) machining equipment, for which there is also no
established validation process
. Your firm’s management confirmed that they do not conduct full verification of CMM measurements.
Your firm’s response to this observation appears to be adequate. Your firm provided a
validation protocol
and reports for the measurement of ASDM products using the CMM. The results in these reports validate the repeatability and accuracy of the CMM in verifying
design specification
for all products fabricated in-house using the CNC machining equipment."
used in an automated process for its intended use according to an established protocol, as required by 21 CFR 820.70(i).
For example, no person from your firm reviewed or approved the third party approval test resultsfor the original " [redacted]