11 Observations on Zhejiang Huahai FDA-483

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FDA has released the FDA-483 issued after a 7/23-7/28 and 7/30-8/3 agency inspection at Zhejiang Huahai Pharmaceutical Co., Linhai, Zhejiang Province, China. The 11 observations on the form were: 

  •          failing to have an adequate change control system to evaluate all changes that may affect the production and control of intermediates or active pharmaceutical ingredients (API);
  •          failing to have adequate validation of production processes, cleaning procedures, analytical methods, and in-process control test procedures;
  •          failing to have an adequate system for managing quality to ensure confidence that API will meet intended specifications for quality and purity since the quality unit lacks written procedures and the authority and responsibility to ensure all critical deviations are thoroughly investigated;
  •          failure of the quality unit to always fulfill its responsibility to release or reject all APIs;
  •          failing of cleaning procedures to contain sufficient details to enable operators to clean each type of equipment in a reproducible and effective manner;
  •          failing to have equipment used in the manufacture of intermediates and API that is of appropriate design and adequate size and suitably located for its intended use, cleaning, and maintenance;
  •          schedules and procedures for preventive maintenance of equipment are not adequate or do not exist;
  •          substances associated with the operation of equipment, such as lubricants, heating fluids, or coolants, are not always food grade lubricants and oils;
  •          sampling plans and test procedures are not always scientifically sound and appropriate to ensure raw materials, intermediates, and APIs conform to established standards of quality;
  •          failing to have an adequate on-going testing program to monitor the stability characteristics of APIs to confirm appropriate storage conditions and retest dates; and
  •          production deviations are not always reported and evaluated and critical deviations are not always investigated and the conclusions recorded.

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