6/7 October 2020
The Warning Letters are official deficiency letters from the FDA, which are sent to the companies concerned as a consequence of an unsuccessful inspection by the investigators of the agency. Before a Warning Letter is issued, the agency requests the company to comment on the deficiencies listed in Form 483 that were found during the inspection. If the FDA judges this response to be unacceptable, a Warning Letter will be issued.
The GMP Warning Letters are usually formalised. They provide a structural framework through some standard formulations and are based on the following scheme:
2. Description of the GMP violations observed:
3. Short description of the company's response to Form 483 regarding the GMP violation in question - "Your response stated that...".
4. Justification of the FDA why the response is considered "inadequate" - "Your response is inadequate...".
5. Request for additional documents - "In response to this letter, provide ...".
The detailed description of the inspection procedure (point 2) usually provides a lot of information about the approach of the inspectors, their questions and the answers or reactions of the interviewed employees of the company (sometimes the descriptions of individual situations even offer a certain entertainment value). The list of evidence requested by the authorities (point 5.) ideally complements this information. With this information, the FDA practically defines a catalog consisting of documents that the inspectors had expected during their visit to the site. This is almost always the same documentation for the individual areas.
Example: GMP violation of §211.100 Written procedures; deviations. (Subpart F-Production and Process Controls):
General description of the GMP deficiency
"Your firm failed to establish adequate written procedures for production and process control designed to assure that the drug products you manufacture have the identity, strength, quality, and purity they purport or are represented to possess."
Request for documents ("In response to this letter, provide ...")
As part of the preparation for an FDA inspection, such a systematic analysis of FDA Warning Letters provides a useful "lessons learnt" effect, particularly with regard to the documents that must be made available upon request by the inspectors.
Note: In the next issue of the GMP Journal, you will find a detailed article on the systematics of FDA Warning Letters, including the most frequent GMP violations in the last few months. Please also see the latest issues of the GMP Journal.