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    1. FDA Warning Letter: There is no assurance that you maintain complete electronic raw data for laboratory instruments and data acquisition software (ucm455345)

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      “Failure to record activities at the time they are performed and destruction of original records.

      Specifically, your employees completed batch production records entries days after operations had ended, released lots before the proper approvals, and failed to maintain original manufacturing data for critical steps in the batch production records.  For example,

      a) Our investigators found that some of your operators used “rough notes” (unbound, uncontrolled loose paper) to capture critical manufacturing data and then destroyed these original records after transcription into the batch production records. For example, the [redacted] chemist recorded original manufacturing data as rough notes and left these rough notes for the [redacted] chemist to transcribe into the batch production records.  The next morning, the [redacted] chemist signed the batch production records and destroyed the original rough notes.  We interviewed employees during the inspection who confirmed your firm’s practice of transcribing data to batch records and destroying original records

      b) Additionally, our investigators found backdated batch production records dated February 10 to February 25, 2014, signed by your Production Manager and Technical Director in the “Batch Manufacturing Record Reviwed [sic] by” section. The Technical Director stated that he was not in the facility on these dates and was “countersigning” for another person who allegedly performed these review activities.  However, these records did not contain signatures (contemporaneous or otherwise) of the alternate reviewer who purportedly conducted the review. Furthermore, the Technical Director backdated his own signature to the date the quality unit (QU) reviewed and released your drug product.  His backdated signatures are on [redacted] batch records for lots [redacted]; and [redacted] batch records for lots [redacted].  You released these batches before the Technical Director returned to the facility and backdated his signatures.  The batch records, therefore, do not demonstrate that you completed your required review before releasing your products…

      Failure to prevent unauthorized access or changes to data, and to provide adequate controls to prevent omission of data.

      Your laboratory systems lacked access controls to prevent raw data from being deleted or altered. For example,

      a) There is no assurance that you maintain complete electronic raw data for your Gas Chromatography (GC) instrument. FDA investigators observed multiple copies of raw data files in the recycle bin connected to the GC instrument QC-04 even in the presence of “Do Not Delete Any Data” notes posted on two laboratory workstation computer monitors.

      b) Employees were allowed uncontrolled access to operating systems and data acquisition software tracking residual solvent, and test and moisture content. Our investigators noted that there was no password functionality to log into the operating system or the data acquisition software for the GC, the High Performance Liquid Chromatography (HPLC) instrument QC-17, or the Karl Fischer (KF) Titrator QC-13.

      c) HPLC SpinChrome and GC Lab Station data acquisition software lacked active audit trail functions to record changes in data, including original results, who made changes, and when.

      In your response, you state that your laboratory GC, HPLC and KF systems are now password-protected and that you have begun drafting analytical software password procedures for the GC, HPLC and KF laboratory instruments.  However, your response does not state whether every analyst will have their own user identification and password.  You also mention plans to install a validated computer system.  However, you did not provide a detailed corrective action and preventive action (CAPA) plan or conduct a review of the reliability of your historical data to ensure the quality of your products distributed to the U.S. market.

      Inadequate controls of your computerized analytical systems raise questions about the authenticity and reliability of your data and the quality of your APIs.  It is essential that your firm implements controls to prevent data omissions or alterations.  It is critical that these controls record changes to existing data, such as the individuals making changes, the dates, and the reason for changes.

      In response to this letter, provide your comprehensive CAPA plan for ensuring that electronic data generated in your manufacturing operations, including laboratory testing, cannot be deleted or altered.  Also identify your quality control laboratory equipment and any other manufacturing-related equipment that may be affected by inadequate controls to prevent data manipulation.

      View the original warning letter.


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    2. FDA Warning Letter: It is unclear how adding a “clinical trials link” to your site’s electronic medical record (EMR) to provide access to study information for study staff will ensure that protocol requirements will be met (ucm455217)

       
      “In your January 28, 2015, written response to the violations noted in Items 1.c., 1.d., and 1.e. above, you confirmed that protocol-required laboratory tests were missed for subjects enrolled in the clinical investigations for Protocols [redacted] and [redacted]. You indicated that as a part of your corrective action plan, you have added a “clinical trials link” to your site’s electronic medical record (EMR) to provide access to study information for study staff. You further indicated that you will review with study staff the process of accessing study information and the importance of following the study calendar.

      Your response is inadequate because you did not provide sufficient information to enable us to evaluate the adequacy of your corrective action plan for use in any future clinical research that you may conduct. It is unclear how adding a “clinical trials link” to your site’s EMR will ensure that protocol requirements will be met for studies conducted at your site. You did not provide any details of a corrective action plan to prevent similar violations from occurring in the future, nor have you provided sufficient details regarding your plan to implement additional measures and procedures to address the inspection findings. Without these details, we are unable to determine whether your corrective action plan appears sufficient to prevent similar violations in the future.”

      View the original warning letter.


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    3. FDA Warning Letter: Multiple instances of delayed monitoring reports and approvals with electronic tracking system (ucm453979)

       
      “In the October 10, 2014 written response to the Form FDA 483, you acknowledged this observation. You stated that prior to January 2013, there was no electronic system to track reporting timelines. You indicated that an electronic tracking system was implemented in January 2013 to track monitoring visits and monitoring report reviews. You noted that CRAs receive automatic e-mail reminders and reconciliation is done once per month by the CPM and AB Science management team.

      Your written response is inadequate because there are still multiple instances of delayed written reports by the CRAs and delayed approval by the CPM after January 2013.

      You proposed a corrective action plan for implementation in the fourth quarter of 2014 where local labs will be captured and queried immediately at the site in the eCRF, and you will continue to use the central lab in phase III trials in addition to local labs for managing safety information.

      Your written response is inadequate because your proposed corrective actions make no provisions for assessing the effectiveness of and ensuring sustained compliance with your monitoring practices.”

      View the original warning letter.


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    4. Warning Letter: Failure to provide adequate controls for audit trail, backup, common log-in and password, validation, procedures, and training (ucm448433)

      Tags: |

      “Failure to prevent unauthorized access or changes to data and to provide adequate controls preventing data omissions.

      Our inspection noted that your firm did not retain complete raw data from testing performed to assure the quality of
      [redacted], API. Specifically, our inspection revealed your firm did not properly maintain a back-up of HPLC chromatograms that form the basis of your product release decisions. Our inspection revealed discrepancies between the printed chromatograms and the operational qualification protocol for the High Performance Liquid Chromatography (HPLC) system, which is intended to demonstrate correct operation of the HPLC. These discrepancies included injection sequences and values to calculate relative standard deviation (RSD).

      While investigating these discrepancies, our investigator requested the original electronic raw data. Your quality unit, after consulting with the Information Technology (IT) department, stated they were unable to retrieve the original electronic raw data because back-up discs were unreadable. Your quality unit then stated that back-up disks have been unreadable since at least 2013. Your HPLC system is used to test
      [redacted], API for batch release. However, without complete, accurate, reliable, or retrievable raw data about the HPLC system’s qualification, you lacked complete assurance that the system was operating as intended.

      You also failed to have proper controls in place to prevent unauthorized manipulation of your laboratory’s raw electronic data. Our inspection revealed your HPLC system did not have access controls to prevent alteration or deletion of data. Your HPLC software lacked an audit trail recording any changes to the data, including: previous entries, who made changes, and when changes were made. During the inspection, we also noted that all laboratory employees shared a common log-in and password to access the system.

      This lack of control over the integrity of your data raises questions about your analytical data’s authenticity and reliability, and about the quality of your APIs. We note that the September 2008 FDA inspection uncovered concerns over your handling of raw analytical data, including discrepancies between laboratory notebooks and printed chromatograms.”

      View the original warning letter.


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    5. Warning Letter: Lack of testing of software interfaces (ucm448655)

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      “An analysis to determine if other software products manufactured have had similar failure modes due to lack of testing of software interfaces.”

      View the original warning letter.


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    6. Warning Letter: No procedures on how to enter data in the electronic system (ucm444827)

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      “Your procedure has not been updated to reflect the change that was made in 2011 to document all complaints on a form in your electronic system, and not on the hard copy “Product Inquiry/Complaint form” as required by section 6.3 of your complaint procedure. Additionally, there are no procedures on how to enter data in this electronic system.”

      View the original warning letter.


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    7. Warning Letter: Procedures not defined (ucm443561)

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      “Your firm states that service call logs were reviewed and “Calls were searched for Key Words to filter for obvious complaint language;” however, your firm did not define what constitutes “obvious complaint language” and did not define a procedure for implementing this filter.”

      View the original warning letter.


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    8. Warning Letter: Procedures not implemented (ucm442205)

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      ” Failure to establish and maintain adequate procedures for implementing corrective and preventive actions, as required by 21 CFR 820.100(a). Specifically,

      a. Your “Corrective and Preventive Action” procedure, SOP 019, Rev. 16, is not being implemented in that:

      1. The Engineering Change Orders being initiated to change the designs of the printed circuit boards due to solder ball nonconformances identified during the validation of surface mount technology process (SMT) are not being managed as a corrective action.

      2. Nonconformances, such as missing components, solder balls, shifted/tombstoned components, and bad solder joints on the printed circuit boards, which occur during the surface mount technology process, are not being captured as sources of quality data that are analyzed to identify existing and potential causes of nonconforming product.”

      Failure to document validation activities, as required by 21 CFR 820.75(a). Specifically,

      The setting (temperature and line speed) used during the validation studies for the reflow oven, which is part of the SMT (Surface Mount Technology) line, to determine the optimum settings were not documented. Therefore, it is unknown if you are currently operating the reflow oven within your validated parameters.

      View the original warning letter.


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    9. Warning Letter: No evidence of validation (ucm442129)

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      “Additionally, your firm has made 21 software upgrades since the release of the system, 17 of which were not evaluated for potential correction and removals. All of these software upgrades have been upgraded to all field systems. These software upgrades included fixes for identified hazards such as fluid deficit issues in software revisions G”, “L”, “N” and “S” all with an assigned severity level of “10”.

      Your firm does not have evidence of review or acceptance of validated processes used by critical suppliers to manufacture components for your fluid management device.”

      View the original warning letter.


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    10. Warning Letter: No active audit trail (ucm443247)

      Tags: | | |

      “Failure to prevent unauthorized access or changes to data and to provide adequate controls to prevent omission of data.

      You lacked controls to prevent the unauthorized manipulation of your laboratory’s electronic raw data. Specifically, your infrared (IR) spectrometer did not have access controls to prevent deletion or alteration of raw data. Furthermore, the computer software for this equipment lacked active audit trail functions to record changes to data, including information on original results, the identity of the person making the change, and the date of the change. Audit trails that capture such critical data about the quality of your batch production should be reviewed as part of the batch review and release process.”

      View the original warning letter.


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