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    1. Warning Letter: Failure to validate computer software (ucm377116)

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      Failure to validate computer software for its intended use according to an established protocol, as required by 21 CFR 820.70(i). For example, your firm uses [redacted] to generate, store, and disseminate standard operating procedures, forms, and other records. [redacted] is also used by your firm to generate and store Device History Records (DHRs) and other quality system data. During the inspection, your firm indicated that the procedure titled, “Validacion del software utilizado en el sistema de calidad, GC-E-07-49, Rev. 00,” dated March 14, 2011, states that validation is concentrated on software and documents used in the quality system since there is no software used in your firm’s manufacturing equipment. However, your firm could not produce any evidence to demonstrate that the software programs were validated for their intended use.

      View the original warning letter.


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    2. Warning Letter: Failure to validate computer software (ucm377097)

       
      “Failure to validate computer software for its intended use according to an established protocol when computers or automated data processing systems are used as part of production or the quality system, as required by 21 CFR 820.70(i). For example: Document No. IN-26_01_002, No. 1, dated March 25, 2013, Validierungsmasterplan [Validation Master Plan] developed as part of CAPA 2335, states that [redacted], [redacted], and [redacted], are software programs that are considered critical, which requires software validation. These programs have not been validated by your firm.”

      View the original warning letter.


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    3. Warning Letter: Uncontrolled Excel spreadsheets (ucm369409)

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      For example, your firm failed to have adequate procedures for the use of computerized systems used in the QC laboratory. At the time of the inspections, your QC laboratory personnel shared the same username and password for the operating systems and analytical software on each workstation in the QC laboratory. In addition, no computer lock mechanism had been configured to prevent unauthorized access to the operating system. The investigator noticed that the current QC computer users are able to delete data acquired. In addition, the investigator found that there is no audit trail or trace in the operating system to document deletions.

      Additionally, at the Aarti Drug Limited facility (FEI 3009688205), the investigator noticed that the use of the Excel® spreadsheets in analytical calculations are neither controlled nor protected from modifications or deletion. The investigator noticed that the calculation for residual solvent for [redacted] uses an Excel spreadsheet that has not been qualified. We are concerned about the data generated by your QC laboratory from non-qualified and uncontrolled Excel spreadsheets.

      View the original warning letter.


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    4. Warning Letter: Failure to Establish Validation Program (ucm366715)

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      "your firm failed to establish a
      validation program
      for the computer software Microsoft Dynamics used for production, inventory, lot number generation, and laboratory test methods used for raw material, bulk, and finished product test release.  Your firm also uses the Microsoft Dynamics program to assist your quality unit for product, document and component control.

      View the original warning letter.


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    5. Warning Letter: No CAPA Procedure (ucm 360143)

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      These violations include, but are not limited to, the following:

      Failure to establish and maintain adequate procedures for implementing corrective and preventive action and failure to document all activities under 21 CFR 820.100 and their results, as required by 21 CFR 820.100(a).

      For example: Your Quality System Manual, dated 10/09/2012, Rev. A, Section 8.4 states that your firm has established procedures to document and analyze quality data from complaints, internal audits, supplier performance and non-conforming materials. Section 8.5 states that your firm has implemented a corrective and preventive action (CAPA) program to eliminate the cause of nonconformities in order to prevent recurrence. However, your firm does not have any written CAPA procedures. In addition, you have no records of analyzing quality system data obtained through sources such as complaints, internal audits, supplier performance and non-conforming materials, to determine if a CAPA action is required.

      View the original warning letter.


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    6. Warning Letter: Medical device company failed to validate computer software (ucm 355751)

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      Failure to ensure that all inspection, measuring, and test equipment, including mechanical, automated, or electronic inspection and test equipment, is suitable for its intended purposes and is capable of producing valid results, as required by 21 CFR 820.72(a). For example, your firm’s design verification procedure does not require that test equipment and software are fully validated, as needed, and prior to use in design verification activities.

      View the original warning letter.


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    7. Warning Letter: Missing Validation Testing (ucm 359625)

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      Your firm does not have a design history file (DHF) for the Meridian DR 200 single panel X-ray system. The system is comprised of a workstation, flat panel detectors, acquisition software and X-ray hardware. Missing elements of the DHF include:
      • A design plan for the project
      • Established or approved design inputs/outputs for the system
      • Verification or Validation testing for the system
      • Design Transfer
      • Risk Management for the system
      • Design Reviews.
      Your firm does not have procedures to describe the content of your Device History Records (DHR’s). In addition, eleven of eleven DHR files reviewed showed that all were incomplete as the only record in the files was your testing of the flat panel detectors, which is only one part of the X-ray system. The DHRs do not include installation records; records of any non-conformities; records regarding the X-ray hardware, workstation or acquisition software; or records of final product testing and quality release of your systems.

      View the original warning letter.


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    8. Warning Letter: Firm not reporting all electronic results obtained (ucm 361553)

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      We observed and documented practices during the inspection that kept some samples, data and results outside of the local systems for assessing quality. This raises serious concerns regarding the integrity and reliability of the data generated at your Kalyani plant. For example,

      a. Our review of the Chromeleon and Empower II software found that your firm was testing samples unofficially, and not reporting all results obtained. Specifically, “test,” “trial” and “demo” injections of intermediate and final API samples were performed, prior to performing the tests that would be reported as the final QC results.

      b. Out-of-specification or undesirable results were ignored and not investigated.

      c. Samples were retested without a record of the reason for the retest or an investigation. Only passing results were considered valid, and were used to release batches of APIs intended for US distribution.

      d. Unacceptable practices in the management of electronic data were also noted. The management of electronic data permitted unauthorized changes, as digital computer folders and files could be easily altered or deleted.

      View the original warning letter.


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    9. Warning Letter: Failure to follow Protocol (ucm 366762)

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      Protocol [redacted] required that you dispense a handheld electronic device (LogPad) to subjects at Visit 2, prior to surgery, and that the subjects record their pain assessments in the LogPad during the study. You did not dispense a LogPad to Subject 09-006 at Visit 2 on March 4, 2011, because the subject was sedated and on a ventilator. In addition, five pain assessments for Subject 09-006 were entered into the LogPad by the study coordinator, rather than by the subject. During the inspection, your study coordinator indicated that she used the subject’s login code and entered the subject’s pain-assessment scores into the LogPad when the subject was unable to provide a pain score. In your October 3, 2012, written response, you acknowledged that the LogPad was not dispensed to Subject 09-006 prior to surgery. You noted that after surgery, the subject was put on a “vent” (ventilator), was sedated, and was unable to participate in the evaluation of pain, via the LogPad or otherwise….

      …By failing to ensure that pain-assessment data were entered only by the subjects, as required by the protocol, you compromised the validity and integrity of data collected at your site. Protocol [redacted] required that the subjects record their pain assessments in the LogPad during the study. For Subject 09-006, the LogPad contained assessments purportedly made and entered by the subject; however, five pain assessments were entered by the study coordinator and reflect the study coordinator’s or nursing staff’s assessments, rather than the subject’s assessments.

      View the original warning letter.


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    10. Warning Letter: Hospital stretcher manufacturer failed to validate computer software (ucm 355751)

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      Failure to validate computer software for its intended use according to an established protocol when computers or automated data processing systems are used as part of production or the quality system, as required by 21 CFR 820.70(i). Specifically, [redacted], developed by [redacted], is used to transfer and make changes to drawings used to manufacture devices. There is no protocol or documentation demonstrating that this software has been validated for its intended use.

      View the original warning letter.


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