• (919) 844 2494
  • FDA Warning Letters


    1. Warning Letter: Lack of security for electronic data (ucm197966)

      Tags: | |

      Your firm has not exercised appropriate controls over computer or related systems to assure that changes in master production and control records or other records are instituted only by authorized personnel [21 CFR 211.68(b)].

      For example, your firm lacks systems to ensure that all electronic data generated in your Quality Control laboratory is secure and remains unaltered. All analysts have system administrator privileges that allow them to modify, overwrite, and delete original raw data files on the [redacted] used [redacted] in the High Performance Liquid Chromatography (HPLC) units. There are no procedures that address the security measures in place for generation and modification of electronic data files for these instruments used for raw material, in-process, finished product and stability testing. In addition, your firm’s review of laboratory data does not include a review of an audit trail or revision history to determine if unapproved changes have been made.
      View the original warning letter.


      Recommended Solutions

      Compliance Training >>

      Recommended Solutions

      ExcelSafe >>

      Recommended Solutions

      Ofni Clinical >>

      Recommended Solutions

      Part 11 Toolkit >>

      Recommended Solutions

      Part 11 Advisor >>

      Recommended Solutions

      MedWatch Reporter >>

      Recommended Solutions

      Computer Validation >>

      Recommended Solutions

      Custom Programming >>

      Recommended Solutions

      Validating MS Excel Spreadsheets >>

      Recommended Solutions

      Access Databases >>

    2. Warning Letter: Failure to Automate Data Processing Systems (ucm190816)

      Tags: | |

      You have failed 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 the production or the quality system, as required by 21 CFR 820.70(i). Specifically, there is no record of validation for software in the [redacted] which is used to make components for the aspirating dental injection syringes.

      View the original warning letter.


      Recommended Solutions

      Compliance Training >>

      Recommended Solutions

      ExcelSafe >>

      Recommended Solutions

      Ofni Clinical >>

      Recommended Solutions

      Part 11 Toolkit >>

      Recommended Solutions

      Part 11 Advisor >>

      Recommended Solutions

      MedWatch Reporter >>

      Recommended Solutions

      Computer Validation >>

      Recommended Solutions

      Custom Programming >>

      Recommended Solutions

      Validating MS Excel Spreadsheets >>

      Recommended Solutions

      Access Databases >>

    3. Warning Letter: Failure to Validate Spreadsheets (ucm185865)

      Tags: | |

      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, when requested, no validation information or protocols were provided for the [redacted] software which is used for product complaints, CAPA requests/actions, preventive action request/actions, and creating quality logs.

      View the original warning letter.


      Recommended Solutions

      Compliance Training >>

      Recommended Solutions

      ExcelSafe >>

      Recommended Solutions

      Ofni Clinical >>

      Recommended Solutions

      Part 11 Toolkit >>

      Recommended Solutions

      Part 11 Advisor >>

      Recommended Solutions

      MedWatch Reporter >>

      Recommended Solutions

      Computer Validation >>

      Recommended Solutions

      Custom Programming >>

      Recommended Solutions

      Validating MS Excel Spreadsheets >>

      Recommended Solutions

      Access Databases >>

    4. Warning Letter: Failure to validate off-the-shelf software (ucm185181)

      Tags: | |

      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 off-the-shelf software that generates the labels for the dental alloys. The off-the-shelf software has not been validated for this use.

      View the original warning letter.


      Recommended Solutions

      Compliance Training >>

      Recommended Solutions

      ExcelSafe >>

      Recommended Solutions

      Ofni Clinical >>

      Recommended Solutions

      Part 11 Toolkit >>

      Recommended Solutions

      Part 11 Advisor >>

      Recommended Solutions

      MedWatch Reporter >>

      Recommended Solutions

      Computer Validation >>

      Recommended Solutions

      Custom Programming >>

      Recommended Solutions

      Validating MS Excel Spreadsheets >>

      Recommended Solutions

      Access Databases >>

    5. Warning Letter: Failure to validate software (ucm185261)

      Tags: | |

      Failure to validate software used as part of production and quality system for its intended use according to an established protocol, and failure to document the results of the software validation, as required by 21 CFR § 820.70(i). For example, the [redacted] and [redacted] software used to generate instruction manuals, clinician’s manuals and prescription device labels for the [redacted] devices has not been validated.

      View the original warning letter.


      Recommended Solutions

      Compliance Training >>

      Recommended Solutions

      ExcelSafe >>

      Recommended Solutions

      Ofni Clinical >>

      Recommended Solutions

      Part 11 Toolkit >>

      Recommended Solutions

      Part 11 Advisor >>

      Recommended Solutions

      MedWatch Reporter >>

      Recommended Solutions

      Computer Validation >>

      Recommended Solutions

      Custom Programming >>

      Recommended Solutions

      Validating MS Excel Spreadsheets >>

      Recommended Solutions

      Access Databases >>

    6. Warning Letter: Faliure of validation process (ucm170224)

      Tags: | |

      Your company did not ensure that its design verification and validation process detected design discrepancies with [redacted] the [redacted] printed circuit board (PCB) of the MTS trial stimulators using the [redacted] components that later caused loss of stimulation, and therefore, failure to complete trial implants.

      View the original warning letter.


      Recommended Solutions

      Compliance Training >>

      Recommended Solutions

      ExcelSafe >>

      Recommended Solutions

      Ofni Clinical >>

      Recommended Solutions

      Part 11 Toolkit >>

      Recommended Solutions

      Part 11 Advisor >>

      Recommended Solutions

      MedWatch Reporter >>

      Recommended Solutions

      Computer Validation >>

      Recommended Solutions

      Custom Programming >>

      Recommended Solutions

      Validating MS Excel Spreadsheets >>

      Recommended Solutions

      Access Databases >>

    7. Warning Letter: Failure to test input/output (ucm173977)

      Tags: | |

      Failure to check input to and output from the computer or related systems of formulas or other records or data for accuracy as required by 21 CFR 211.68 (b). Specifically, duplicate donor records were created when your firm changed from [redacted] Computer System to [redacted] Computer System on December 2, 2008. The duplicate donor records do not always agree regarding donor eligibility status. For example,  The donor cited in Item 1 is assigned a [redacted] donor identification number of [redacted] and has an eligibility status of “indefinitely deferred”. The same donor has a [redacted] identification number of [redacted] and has an eligibility status of “eligible”.

      •  The final disposition of the leukocytes reduced red blood cells and recovered plasma components processed from this unit were not documented in your firm’s computer system and on the Blood Donation Record as required by SOP.
      •  You received confirmatory positive Recombinant Immuno Blot Assay (RIBA) and positive HCV-Nucleic Acid Testing (NAT) results for this donor on June 10, 2008. However during the current FDA inspection, this donor’s eligibility status was listed as “eligible” in your [redacted] Computer System.

      View the original warning letter.


      Recommended Solutions

      Compliance Training >>

      Recommended Solutions

      ExcelSafe >>

      Recommended Solutions

      Ofni Clinical >>

      Recommended Solutions

      Part 11 Toolkit >>

      Recommended Solutions

      Part 11 Advisor >>

      Recommended Solutions

      MedWatch Reporter >>

      Recommended Solutions

      Computer Validation >>

      Recommended Solutions

      Custom Programming >>

      Recommended Solutions

      Validating MS Excel Spreadsheets >>

      Recommended Solutions

      Access Databases >>

    8. Warning Letter: Failure to validate software (ucm173977)

      Tags: | |

      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). This was a repeat violation from a previous FDA-483 that was issued to your firm. For example: A) Your firm uses off-the-shelf software (HEAT Help Desk) to manage customer support service calls and to maintain customer site configuration information; however, your firm failed to adequately validate this software in order to ensure that it will perform as intended in its chosen application. Specifically. your firm’s validation did not ensure that the details screen was functioning properly as intended. The details screen is used to capture complaint details and complaint follow-up information which would include corrective and preventative actions performed by your firm when service calls are determined to be CAPA issues. B) Off-the-shelf software (Microsoft SharePoint) is being used by your firm to manage your quality system documents for document control and approval. However, your firm has failed to adequately validate this software to ensure that it meets your needs and intended uses. Specifically. at the time of this inspection there were two different versions of your CAPA & Customer Complaint procedure, SOP-200-104; however, no revision history was provided on the SharePoint document history. Your firm has failed to validate the SharePoint software to meet your needs for maintaining document control and versioning.

      View the original warning letter.


      Recommended Solutions

      Compliance Training >>

      Recommended Solutions

      ExcelSafe >>

      Recommended Solutions

      Ofni Clinical >>

      Recommended Solutions

      Part 11 Toolkit >>

      Recommended Solutions

      Part 11 Advisor >>

      Recommended Solutions

      MedWatch Reporter >>

      Recommended Solutions

      Computer Validation >>

      Recommended Solutions

      Custom Programming >>

      Recommended Solutions

      Validating MS Excel Spreadsheets >>

      Recommended Solutions

      Access Databases >>

    9. Warning Letter: Software not validated (ucm165771)

      Tags: | |

      Some system components on the part lists were not depicted on the [redacted] drawings of the water purification systems installed at the [redacted] dialysis sites. Your computer software used to perform the [redacted] calculations has not been validated.

      View the original warning letter.


      Recommended Solutions

      Compliance Training >>

      Recommended Solutions

      ExcelSafe >>

      Recommended Solutions

      Ofni Clinical >>

      Recommended Solutions

      Part 11 Toolkit >>

      Recommended Solutions

      Part 11 Advisor >>

      Recommended Solutions

      MedWatch Reporter >>

      Recommended Solutions

      Computer Validation >>

      Recommended Solutions

      Custom Programming >>

      Recommended Solutions

      Validating MS Excel Spreadsheets >>

      Recommended Solutions

      Access Databases >>

    10. Warning Letter: Inadequate validation (ucm164129)

      Tags: | |

      Failure to observe, standardize, and maintain equipment and failure of equipment to perform in the manner for which it was designed so as to assure compliance with the official requirements for blood and blood components [21 CFR 606.60(a)]. Specifically, the following observations were made during review of your firm’s validation of the interface between the automated blood testing instrument [redacted] and the database system, [redacted]

      • Validation sample testing and data collection was conducted on December 9, 2008, prior to approval of the validation test plan on. December 19, 2008;
      • The validation pass/fail criteria was not met;
      • The validation test plan was not followed; and
      • The validation data was incomplete.

      View the original warning letter.


      Recommended Solutions

      Compliance Training >>

      Recommended Solutions

      ExcelSafe >>

      Recommended Solutions

      Ofni Clinical >>

      Recommended Solutions

      Part 11 Toolkit >>

      Recommended Solutions

      Part 11 Advisor >>

      Recommended Solutions

      MedWatch Reporter >>

      Recommended Solutions

      Computer Validation >>

      Recommended Solutions

      Custom Programming >>

      Recommended Solutions

      Validating MS Excel Spreadsheets >>

      Recommended Solutions

      Access Databases >>