CGMP Violations in Health Specialty Inspection
An FDA 11/27-11/30/2023 inspection at Cohere Beauty’s Health Specialty drug manufacturing facility in Santa Fe Springs, CA, found significant violations of current good manufacturing practice (CGMP) regulations for finished drugs. A just-released 4/15 Warning Letter says the specific violations were:
- failure to establish adequate written procedures for production and process control designed to assure that the drug products manufactured have the identity, strength, quality, and purity they purport or are represented to possess; and
- failure of the firm’s quality control unit to exercise its responsibilities to ensure drug products manufactured comply with CGMP and meet established specifications for identity, strength, quality, and purity.
“Your inspectional history and significant findings in this letter indicate that your quality unit is not fully exercising its authorities and/or responsibilities,” the letter says. It notes that similar violations were cited in a 12/2022 inspection and the company proposed specific remediation for the observations in its response and a regulatory meeting with the agency. “Repeated failures demonstrate that executive management oversight and control over the manufacture of drugs is inadequate,” FDA says.
The agency acknowledges the company’s commitment to cease production of drugs at this facility. If Cohere Beauty decides to resume production of drugs, it says, it should engage a qualified consultant to evaluate its operations and assist it in meeting CGMP requirements.
Cohere was told to correct any violations promptly and to respond with a list of specific actions it has taken to address the violations and prevent their recurrence, with a schedule for completing the corrections.