FDA Releases 2 Galaxy Surfactants FDA-483s

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FDA has released the FDA-483s issued following an agency 3/26-3/30 inspection at one Galaxy Surfactants manufacturing facility in Tarapur, India, and a 3/19-3/23 inspection at a second manufacturing facility in the same city. Observations from the first report were: 

  •          responsibilities and procedures applicable to the quality control unit are not in writing and fully followed;
  •          failing to adequately validate the analytical method for stability studies of an active pharmaceutical ingredient to support the intended commercialization period and expiry;
  •          failing to place on stability at least one batch per year of manufactured active pharmaceutical ingredients and to test at least annually to confirm the stability characteristics of the ingredients, appropriate storage conditions, and confirm the expiry dates;
  •          failing to provide good manufacturing practice training to employees at the particular operations that the employee performs and good manufacturing practice as it relates to the employees’ functions;
  •          failing to establish an appropriate equipment cleaning procedure to assure an adequate cleaning of equipment and its subsequent release for use in the manufacture of intermediates and active pharmaceutical ingredients;
  • ·        failing to conduct appropriate qualification of critical equipment;
  •          failing to use water that is suitable for manufacturing active pharmaceutical ingredients;
  •          failing to ensure product quality uniformity from batch to batch such that the batch manufacturing records do not conform to the master formula record; and
  •          the APQR (annual product quality review) procedure is deficient.

 Inspection observations from the second report were: 

  •          failing to provide appropriate good manufacturing practice and position specific training to personnel for the particular operations that each employee performs as it relates to the employee’s function; and
  •          failing to validate the analytical methods required for the trace analysis of active pharmaceutical ingredient residue as part of the cleaning validation program.

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