8 Observations in Novo Nordisk FDA-483

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FDA has released the form FDA-483 issued following a 3/15-3/25 inspection at a Novo Nordisk drug substance manufacturing site in Kalundborg Sjalland, Denmark. The eight inspection observations were:

  • the routine sample volume that is used to test for appropriate standards of quality and purity of the redacted water for drug substance manufacturing is insufficient to be representative of the water system capacity;
  • insufficient information has been provided to demonstrate that the water used for drug substance purification is adequately controlled for total microbial counts and objectionable organisms in water systems;
  • drug substance manufacturing and processing unit operations that have been observed to be performed for drug substances at the company drug substance manufacturing facility are not included in the submission to the agency for review;
  • master production and control records lack complete manufacturing and control instructions;
  • the validation of the drug substance manufacturing process, including a full description of the validation data for critical process parameters and in-process controls in support of routine production, has not been appropriately documented;
  • written procedures used in the manufacturing, processing, or packing that are designed to assure identity, strength, quality, and purity of the drug substance are inadequate;
  • the responsibilities and procedures applicable to the quality control unit are not fully followed; and
  • laboratory controls do not include the establishment of scientifically sound and appropriate sampling plans designed to assure that production cultures conform to appropriate standards of identity, strength, quality, and purity.

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