Cosmetic Solutions CGMP, Unapproved Drug Violations
A 9/12-9/21/2023 FDA inspection at the Cosmetic Solutions drug manufacturing facility in Boca Raton, FL, identified current good manufacturing practice (CGMP) regulation and unapproved new drug violations in the firm’s manufacturing of finished drugs. A just-released 5/31 Warning Letter says specific CGMP violations were:
- failure to establish adequate written responsibilities and procedures applicable to the quality control unit and to follow such procedures; and
- failure to establish adequate written procedures for production and process control designed to assure that drug products the firm manufactures have the identity, strength, quality, and purity they purport or are represented to possess, and to follow all of the written production and process control procedures.
The firm’s responses to the CGMP observations were inadequate, FDA says. The letter says its review of labeling and the Web site for redacted products indicates that they are legally considered to be drugs and are not generally recognized as safe and effective for their use in the diagnosis, cure, mitigation, treatment, or prevention of disease. Thus, it says, the products require FDA approval and there is no approved application in effect for them.
FDA recommends that Cosmetic Solutions engage a qualified consultant to assist it in meeting CGMP requirements. The company was told to correct violations promptly and to respond with a list of specific actions it has taken to address violations and prevent their recurrence, with a schedule for completing the corrections.