Inadequate/Missing Procedures


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Warning Letter: Failure to establish procedures (ucm165301)

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Failure to establish procedures for quality audits and conduct such audits to assure that the quality system is in compliance with the established quality system requirements and to determine the effectiveness of the quality system, as required by 21 CFR 820.22.

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Warning Letter: Failure to maintain quality system requirements (ucm152423)

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Failure to establish and maintain an adequate organizational structure to assure that quality system requirements are fully met, as required by 21 C.F.R. § 820.20(b). For example, your Quality Assurance Department consists of one individual, the Quality Manager, who is responsible for implementation of your CAPA system, quality audits, document control, training, developing procedures, conducting process validations, and all other aspects of your quality system for both medical and non-medical products. During the inspection your quality manager stated that he lacked sufficient time and resources to complete many of the Quality System requirements. Additionally, you stated that your quality system has not kept pace with the growth of your firm’s business.

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Warning Letter: No documentation of employee training (s6597c)

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Failure to ensure that all personnel are trained to adequately perform their assigned responsibilities; and failure to implement your training procedure, as required by 21 CFR §820.25(b). For example, there is no documentation of any training of any current employees with regard to their assigned responsibilities, although your training procedures require documentation of training. … Failure to conduct quality audits; and failure to implement audit procedures to assure that the quality system is in compliance with the established quality systems requirements and to determine the effectiveness of the Quality Systems, as required by 21 CFR § 820.22.

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Warning Letter: Lack of procedures and instructions (g6173d)

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  • Failure to have production and process controls for automated processes, as required by 21 CFR 820.70(i). when computers or automated data processing systems are used as part of production or the quality system. A manufacturer is required to validate computer software for its intended use according to an established protocol. For example, databases that are maintained for data analysis and other tracking and trending functions, including complaint and services access databases, have riot [sic] been validated for their intended use.
  • Failure to establish and maintain instructions and procedures for performing and verifying that servicing meets the specified requirements, as required by 21 CFR 820.200(b). Each manufacturer must analyze service reports with appropriate: statistical methodology in accordance with Section 820. 100. For example, your quality group reviews narrative summaries of service reports every two weeks, but the data is not tracked and trended according to a statistical method.

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Warning Letter: Failure to indicate reason for change (ucm075728 )

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Failure to indicate the reason for change in automated data entries [21 CFR 58.130(e)]. In several instances, entries in the [redacted] collection/notes and audit trails failed to provide the reason for changing raw data. For example, audit trail entries for study [redacted]demonstrate that observations of “normal” were removed without an explanation.

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Warning Letter: Failure to follow 21 CFR 11 compliance (g5276d)

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Our review of the inspection results also noted that you use an electronic medical record (EMR) system to maintain medical and other clinical data for your patients, including study subjects . You told Mr.  [redacted] that data obtained during study visits are entered directly into the EMR, and no paper records are used. A follow-up letter from you to Mr. [redacted], dated January 31, 2005, detailed the name of the EMR system and the means by which study subject information is entered. Please note that Title 21, Code of Federal Regulations, Part 11, “Electronic Records; Electronic Signatures ” outlines specific requirements that must be met for any system that is being used to maintain required records. In addition to the information requested above, please submit the following:

  • Documentation of the validation of your EMR system to ensure accuracy, reliability, and the ability to detect invalid or altered records;
  • Documentation of the ability to generate accurate and complete copies of records suitable for inspection, review, and copying by the agency;
  • Documentation of a secure, computer-generated, time-stamped audit trail that can independently record the date and time of operator entries and actions that create, modify, or delete electronic records, and to verify that record changes do not obscure previously recorded information.

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Warning Letter: Incomplete requirements (ucm075276)

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Your firm failed to address design input requirements that are incomplete, as required by 21 CFR 820.30(c) [FDA-483, Item 31. Specifically,

  • Functional requirements for the DBSS are in some cases very high level. For example, the requirements for Donor Reporting merely state that the application must enable the user to identify, from a list of persons, the donor on whom the report should be based, and to print an Autologous Unit Status Report, a Donor History Report, a Person Audit Trail Report, a Deferral Audit Trail Report, and an Individual Donor Orders Report for a specific donor. The requirements do not address the files to be accessed, the fields to be printed, or the format of the ave been written for problems with these reports. [redacted] have been written for problems with these reports. For example, [redacted] concerns the military personnel’s SSN appearing where the donor’s SSN should appear on the Donor Audit Trail Report.”

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Warning Letter: Failure to maintain accurate records (ucm147820)

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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.

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Warning Letter: Failure to comply(g1120d)

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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
comply with the requirements
of the Act...."s."

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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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