The Top 10 Reasons Why Drug, Device, Biologic, Research and Veterinary Facilities Fail FDA Inspections

But as data released by the FDA shows some problems are far more common than others, illustrating areas where the industry can make outside improvements.  Data taken from FDA’s inspectional database between 1 October 2012 and 30 September 2013 showed a total of 5,211 FDA Form 483s, the form FDA uses to note deficiencies at a manufacturing facility.

Center Name483s issued
Foods (CFSAN)2386
Devices (CDRH)1099
Drugs (CDER)690
Veterinary Medicine (CVM)328
Bioresearch monitoring273
Biologics (CBER)191
Human tissue for transplantation121
Parts 1240 and 125091
Radiological Health (CDRH)32
Total5211

But as we said before, some violations tend to pop up more than others, in some cases hundreds of times each year.  In the medical device sector, for example, 378 inspections showed that corrective and preventive action (CAPA) procedures had not been put into place, raising FDA’s concerns that problems might occur over and over again.

Below are the top 10 inspection violations found during inspections of medical device, pharmaceutical, biologic, veterinary and bioresearch facilities.

Medical Device:  Top 10 Inspection Violations

Regulatory ReferenceFrequencyShort DescriptionLong Description
21 CFR 820.100(a)378Lack of or inadequate proceduresProcedures for corrective and preventive action have not been adequately established.
21 CFR 820.198(a)245Lack of or inadequate complaint proceduresProcedures for receiving, reviewing, and evaluating complaints by a formally designated unit have not been adequately established.  Specifically, ***
21 CFR 820.100(b)133DocumentationCorrective and preventive action activities and/or results have not been adequately documented. 
21 CFR 820.75(a)127Lack of or inadequate process validationA process whose results cannot be fully verified by subsequent inspection and test has not been adequately validated according to established procedures. 
21 CFR 803.17124Lack of Written MDR ProceduresWritten MDR procedures have not been developed maintained implemented. 
21 CFR 820.50110Purchasing controls, Lack of or inadequate proceduresProcedures to ensure that all purchased or otherwise received product and services conform to specified requirements have not been adequately established. 
21 CFR 820.90(a)98Nonconforming product,  Lack of or inadequate proceduresProcedures have not been adequately established to control product that does not conform to specified requirements. 
21 CFR 820.30(i)93Design changes – Lack of or Inadequate ProceduresProcedures for design change have not been adequately established.  Specifically,***
21 CFR 820.18177DMR – not or inadequately maintainedA device master record has not been adequately maintained. 
21 CFR 820.2273Quality audits – Lack of or inadequate proceduresProcedures for quality audits have not been adequately established.

 

Drugs: Top 10 Inspection Violations

Regulatory ReferenceFrequencyShort DescriptionLong Description

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