Warning letters are the FDA’s second level of enforcement actions after issuance of a form 483. The FDA determined that either the firm’s response to the form 483 was inadequate or the observations were serious enough to support issuance of a warning letter. Often it is possible to determine the corrective actions necessary and the impact that the warning letter will have on the business. To determine a letter’s impact on the business, I ask these questions:
A form-483 is the document that FDA issues at the close of an inspection where they identify observations made during the inspection. If no observations have been made, no form 483 is issued. Based on the response submitted by the firm, FDA classifies the inspection as: No Action Indicated (NAI) when no form 483 is issued, Voluntary Action Indicated (VAI) or Official Action Indicated (OAI). In general, where FDA issues a form-483 with observations and the firm’s response is satisfactory, the inspection is classified VAI.
The FR announced availability of the long awaited 10-page FDA draft Guidanceon Data Integrity and Compliance with CGMP for comment. I include links to the MHRA guidance HERE and the draft WHO guidance HERE for comparison. The guidance is structured in a Q&A format with a total of 18 questions. This guidance focuses heavily on identifying and citing the predicate rules as they apply to electronic records and data integrity, and for this it is an excellent reference. In my opinion, though, the excessive citation of regulations detracts from the content and provides little insight into FDA’s intent and actual expectations in this area.
As we’ve written extensively about the infamous Form FDA 483 here at FDAzilla, we’ve decided to make it easier for you. Here, we’ve created a centralized list of the 7 best resources to go from Joe to Pro on understanding Form FDA 483s. Continue reading →
Now, we go deep into a serious issue that has received a lot of attention and press – data integrity. I’d venture to guess that billions of market capital has been lost because of this one issue. The crazy part is this – it’s not even close to being a new issue. As you’ll see, the data integrity story began at least 15 years ago. Continue reading →
I was intrigued by a recent conversation I had with Barbara Unger, the editor-in-chief for GMP Regulatory Intelligence. It’s becoming increasingly clear that the FDA wants to make sure you have a rigorous process to stay updated about the latest regulations and guidelines. Here’s what she had to say:Continue reading →
I hope you read our recent post about the backstory of our company, FDAzilla. We’ve come a long way in 5 years. As we plan for the next 5 years, we’ve been preparing for our annual executive team meeting in April. As such, our team researches and synthesizes the most important trends to which we must respond and adapt. Continue reading →
Yesterday was Part I. Today, we get to hear a little more from Barb on her background.
What publicly available information do you depend on for your job? How do you use that information?
I focus primarily on the US, EU, ICH and PIC/S. For laws, regulations and guidance the regulator specific websites publish information quickly. The ICH and PIC/S websites also publish their guidance in an organized way. Compliance actions taken by FDA and EMA are also published. I also read publications in the major newspapers and several blogs. Sometimes the best information can come from an unanticipated source. Continue reading →