Pharmaceutical Manufacturer


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Warning Letter: Lack of user level security (g5973d)

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Appropriate controls are not exercised over computers or related systems to assure that changes in analytical methods or other control records are instituted only by authorized personnel [21 CFR § 211.68(b)]. Specifically:

a) Laboratory managers (QC and R&D) gained access to the [redacted] computer system through a common password. Analysts were not required to use individual passwords; they operated the system following the login by the laboratory managers.

b) Due to the common password and lack of varying security levels, any analyst or manager has access to, and can modify any HPLC analytical method or record. Furthermore, review of audit trails is not required.

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Warning Letter: Failure to indicate reason for change (ucm075728 )

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Failure to indicate the reason for change in automated data entries [21 CFR 58.130(e)]. In several instances, entries in the [redacted] collection/notes and audit trails failed to provide the reason for changing raw data. For example, audit trail entries for study [redacted]demonstrate that observations of “normal” were removed without an explanation.

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Warning Letter: Failure to comply(g1120d)

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References validation and lab documentation - "...requires that all drugs be manufactured, processed, packed, and held according to current good manufacturing practice. No distinction is made between active pharmaceutical ingredients and finished pharmaceuticals, and failure of either to comply with CGMP constitutes a failure to
comply with the requirements
of the Act...."s."

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Warning Letter: Nonconformance with 21 CFR Part 11 (m4105n)

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  • In addition, we further request details regarding steps your firm is taking to bring your electronic CGMP records into conformance with the requirements of 21 CFR Part 11; Electronic Records; Electronic Signatures.
  • This inspection disclosed deficient controls in the laboratory electronic record keeping system, which is used for maintaining chromatography and audit trails.

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Warning Letter: Failure to have appropriate controls (m3955n)

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"
Failure to have appropriate controls
over computer or related systems to assure that
changes in records
are instituted only by authorized personnel, as required by 21 CFR 211.68(b). For example, see FDA-483 observation 12."

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Warning Letter: Deficient computer software (m3844n)

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The computer software your firm uses to determine metals analysis is deficient. It has no security measures to prevent unauthorized access of the software, no audit trails, and data can be copied or changed at will, with no documentation of the copying or changes. Your procedures do not require the documentation of calculation or entry errors. There is no documentation to indicate that analysts are trained in the software and its applications.

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Warning Letter: Spreadsheets not Validated (g5699d)

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There are no data to demonstrate that the quality control/quality assurance spreadsheets used for tracking and trending various quality metrics have been properly validated (installation qualification, operational qualification, and performance qualification) and are performing as intended.

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Warning Letter: Failure to maintain original data (m3847n)

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Failure to maintain complete data from all laboratory tests as required by 21 CFR 211.94 (a). There is no back-up file for laboratory UV spectrophotometer test results for some tests. The spectrophotometer does not automatically back-up data and the analyst is required to assign an identification number to each individual chromatogram in order for it to be saved. In some cases, original data was lost and the tests had to be performed again to determine final distribution of the lots.

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Warning Letter: Failure to implement controls (m3488n)

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Your firm failed to implement appropriate controls over your High Performance Liquid Chromatography (HPLC) to assure that only authorized changes can be made. It was noted during the inspection that there is an option on the HPLC that allows analysts to delete results after they are processed.

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Warning Letter: Lack of security in database (m3450n)

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Failure to maintain the integrity and adequacy of the laboratory’s computer systems used by the Quality Control Unit in the analysis and processing of test data. For example a) There was a lack of a secure system to prevent unauthorized entry in restricted data systems. Data edit authorization rights were available to all unauthorized user not only the system administrator.

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