FDA: Multiple Violations at O3UV
An 8/23-8/31/2023 FDA inspection at the O3UV facility in Grand Ledge, MI, documented multiple violations in the firm’s illegal manufacturing of autohemotherapy devices. A 7/7 Warning Letter says the firm’s products are adulterated because the company does not have an approved PMA or IDE for them. The products are misbranded, it says, because O3UV did not notify FDA of its intent to introduce the products into interstate commerce or commercial distribution, did not comply with the Unique Device Identification regulations, and did not register with FDA as a medical device establishment.
The letter also identifies these current good manufacturing practice (CGMP) violations:
- failure to establish and maintain procedures to control the design of the device to ensure that specified design requirements are met;
- failure to establish and maintain procedures for receiving, reviewing, and evaluating complaints by a formally designated unit;
- failure to establish and maintain procedures to ensure that all purchased or otherwise received products and services conform to specified requirements;
- failure to establish and maintain procedures for implementing corrective and preventive action;
- failure to establish and maintain procedures for acceptance activities;
- failure to establish and maintain procedures to ensure that Device History Records for each batch, lot, or unit are maintained;
- failure to establish procedures for quality audits and to conduct such audits to assure that the quality system is in compliance; and
- failure of the management with executive responsibility to review the suitability and effectiveness of the quality system at defined intervals and with sufficient frequency according to established procedures.
FDA says the firm’s response to the form FDA-483 observations was inadequate. O3UV was told to respond with a list of specific steps it has taken to address violations and prevent their recurrence, with documentation of each step and a schedule for completing the corrections.