22 October 2020
GMP News No. 432
1 July 2004
FDA Warning Letter Report
If one counts the citations of the individual paragraphs of 21 CFR(Code of Federal Regulations) Part 211 in the FDA warning letters, one getsan overview of the principal deficiencies found by FDA representativesduring inspections.
For the Fiscal Year 2003 (Oct. 2002 till Sept. 2003) we have finalisedthe analysis of all 42 warning letters citing the paragraphs of Part 211.Sorted by frequency, the deviations can be represented by the followinggraph:
The following table shows the exact titles of the paragraphs as well astheir assignment to the individual systems observed by FDA according toits system-based inspection approach, which became official in February2002 (see our GMPNews of 21 July 2003).
From this compilation, it becomes clear that deficiencies in thequality system were the most frequent ones. As in the past year, the listis headed by § 211.100, which refers to the creation, approval andhandling of written procedures in the production area and to the handlingof deviations (see our GMPNews of 2 April 2004; the analysis given in that news relates to thecalendar year 2002, not to the fiscal year). The findings referred to thefact that there were no written procedures or that the existing procedureswere not followed - failures ascribed to the Quality Unit, just as in thefields "Testing and Release for Distribution"(211.165) and "Production Record Review" (211.192). Anotherthing often criticised by the FDA was the QU's failure to carry out itsresponsibilities and duties in an appropriate way.
As it was to be expected, the image of the higher positions of the topten deficiencies found in FY 2003 does not differ much from that of FY2002. According to the system-based inspection approach, the FDA takes anespecially critical look at the quality system in every inspection.
In contrast, there was a great increase in findings concerning thefacilities and equipment system with regard to the qualification,validation and calibration of production equipment (211.68) - as well asin the packaging and labeling system with regard to the handling andcontrol of labels (211.125).
The number of observations concerning "Equipment Cleaning andMaintenance" (211.67) and "Stability Testing" (211.166) hasfallen significantly; however, even if less frequent, these topics arestill to be found among the top ten.
Generally, the analysis of warning letters provides valuable clues tothe preparation of FDA inspections. One of the most important tasks to befulfilled prior to an FDA visit is to check the quality system forpossible gaps and to close them. As the other systems intersect with thequality system in several points, this approach should prove to be veryefficient.
Our analyses result in data collections containing the precisedescriptions of the findings in question. From now on, we will publishextracts of this very comprehensive data collection, which will deal withindividual deviations from the top-ten list.
Forthe members of the European Compliance Academy, we have made available thetables for the top 3 deviations in the members area (see item in the topmenu).
Dr Gerhard Becker