Inspections, Compliance, Enforcement, and Criminal Investigations
|
|
- Myron Watts
- 5 years ago
- Views:
Transcription
1 Page 1 of 6 Home Inspections, Compliance, Enforcement, and Criminal Investigations Enforcement Actions Warning Letters Inspections, Compliance, Enforcement, and Criminal Investigations A Nelson & Co., Ltd. 7/26/12 Department of Health and Human Services Public Health Service Food and Drug Administration Silver Spring MD Warning Letter VIA UPS MAIL WL: July 26, 2012 Mr. Najib Fayad Chief Operations Officer A Nelson & Co., Ltd 5-9 Endeavour Way Wimbledon, London SW19 8UH United Kingdom Dear Mr. Fayad: During our November 14 to 17, 2011, inspection of your pharmaceutical manufacturing facility, A Nelson & Co., Ltd., located at 5-9 Endeavour Way, Wimbledon, London, United Kingdom, investigators from the Food and Drug Administration (FDA) identified significant violations of Current Good Manufacturing Practice (CGMP) regulations for Finished Pharmaceuticals, Title 21, Code of Federal Regulations, Parts 210 and 211. These violations cause your drug products to be adulterated within the meaning of section 501(a)(2)(B) of the Federal Food, Drug, and Cosmetic Act (the Act) [21 U.S.C. 351(a)(2)(B)] in that the methods used in, or the facilities or controls used for, their manufacture, processing, packing, or holding do not conform to, or are not operated or administered in conformity with, CGMP. These drugs are also misbranded under Sections 503 and 301 of the Act. We have reviewed your firm s response of December 07, 2011, and note that it lacks sufficient corrective actions. The following are examples of violations that our investigators observed during the inspection: CGMP VIOLATIONS 1. Your firm does not have adequate written procedures for production and process controls designed to assure that the drug products you manufacture have the identity, strength, quality, and purity they purport or are represented to possess [21 C.F.R (a)]. Three examples of violations of (a) are as follows:
2 Page 2 of 6 a. During the inspection, the investigator observed glass fragments present during the manufacture of Kali Phos 30 c Clikpak, Batch # Specifically, glass fragments were observed in the Clikpak Assembly (b)(4) enclosed area where open glass vials are inserted into the outer plastic Clikpak sheaths and move uncovered on the conveyance mechanism. Your firm failed to implement adequate measures to prevent glass contamination and had no documentation to demonstrate that appropriate line clearance and cleaning is conducted following occurrences of glass breakage, which has been a recurring problem. Your response indicates that a planned process deviation was put in place until a failure mode effect analysis risk assessment could be completed, which was to occur by March The objective of this risk assessment was to determine the required engineering upgrades to help keep glass out of the drug product. Your response also mentioned that no complaints were received for glass found in the product. Your response is found unacceptable as quality can not be added to a product that has been already manufactured and released for distribution. We are concerned that you may have released product for distribution without fully investigating the root cause of the presence of glass fragments, implementing a corrective and preventive action plan, and evaluating impact on all products manufactured using this line. Please note that the lack of current customer complaints alone is neither a verification of a robust quality system nor that you have appropriate process controls in place to conclude that glass fragments may not be present in your products. In your response to this letter, you should provide a risk assessment for all products in the U.S. market that are within expiry. Please also include supporting data that any engineering upgrades you have undertaken to improve the processing line are effective in preventing glass particles from entering your products. b. The investigator also observed for Batch #36659 that one out of every six bottles did not receive the dose of active homeopathic drug solution due to the wobbling and vibration of the bottle assembly during filling of the active ingredient. The active ingredient was instead seen dripping down the outside of the vial assembly. Your firm lacked controls to ensure that the active ingredient is delivered to every bottle. Your response indicates that the line speed was unusually high, and you state that you have corrected the problem to prevent recurrence. However, your response is inadequate because it does not provide a risk assessment for the U.S.-distributed products previously manufactured on the faulty line. Please provide a risk assessment for all products within expiry, distributed to the U.S., manufactured on the line at high speed. Additionally, provide evidence that the line has been successfully validated to ensure each bottle contains the appropriate dose of active homeopathic drug solution. c. The dosing process has not been validated appropriately. Specifically, your surrogate validation study, Medication of un-medicated pillules with (b)(4), visually demonstrates the variability of the amount of (b)(4) for the pillules in one vial. Your firm lacks control of the variation for the amount of the active ingredient in the pillules. The validation study demonstrated that pillules at the top of the bottle contain more active ingredient than pillules at the bottom. There are no controls in place to ensure that the dosing procedure is homogenous and reproducible. Please provide evidence that the dosing process is uniform, as well as a risk assessment for all Clikpak products, distributed to the U.S., dosed with an inconsistent or excessive amount of active ingredient, regarding their safety for consumers.
3 Page 3 of 6 2. Your firm does not have laboratory records that include complete data derived from all tests necessary to assure compliance with established specifications and standards [21 C.F.R (a)]. For example, in some cases, the analytical testing documentation for raw materials did not include sample solution preparations, sample weight, the method number used, the initials of the analyst who performed the test, and the date of the analysis. Your response indicates that the laboratory will stop using notebooks and replace them with analytical test forms and that a project team will prioritize the new analytical forms and plan for full implementation by the end of Your response is inadequate because it does not include an interim plan to ensure adequate documentation in the notebooks prior to the implementation of the new forms. Please provide evidence that laboratory analyses will be documented adequately prior to the implementation of the new analytical forms. Your response should also include a list of the specific SOPs and laboratory records that you plan to revise to ensure all records of test data are complete. 3. Your firm has failed to calibrate instruments and recording devices at suitable intervals in accordance with an established written program containing specific directions, schedules, limits for accuracy and precision, and provisions for remedial action in the event accuracy and/or precision limits are not met [21 C.F.R (b)(4)]. Two examples of violations of (b)(4) are as follows: a. Your firm does not have an established written program to calibrate/qualify the Perkin Elmer Clarus gas chromatograph (GC) at suitable intervals. b. Your firm did not calibrate and qualify the Jasco high performance liquid chromatography (HPLC) instrumentation adequately, in that there is no periodic qualification or evaluation of the pump, oven, injector, or detector. The Use and Calibration of HPLC procedure does not include criteria to define adequate calibration of the instrument. Your response indicates that a use, maintenance, and qualification procedure for the GC will be separated from the procedure for the Determination of (b)(4) and (b)(4) by Gas Chromatography by March Additionally, your response indicates that the HPLC procedure will be revised to include operational performance and acceptance criteria by March Please provide an analysis of your analytical data used to release raw materials for production of products in U.S. distribution and provide evidence that you are in compliance with 21 C.F.R We remind you that you are responsible for ensuring that your firm s drug manufacturing operations comply with applicable requirements, including CGMP regulations. FDA expects A Nelson & Co., Ltd. to undertake a comprehensive and global assessment of your manufacturing operations to ensure that your processes, and ultimately, the drug products you manufacture, conform to FDA requirements. MISBRANDING VIOLATIONS FDA reviewed your firm s labeling information for products including, but not limited to: Arnica and Arnileve. Based on our review of the labeling for these products at and these products are misbranded
4 Page 4 of 6 under Sections 503 and 301 of the Federal Food, Drug, and Cosmetic Act (the Act) (21 U.S.C. 353 and 331). Misbranding [ 503(b)(4) and 301(a)] According to the labeling on your website, the above listed products are intended to cure, mitigate, treat, or prevent diseases, or to affect the structure or function of the body. Your product labeling documents the intended uses of your products including, but not limited to the following: Arnica: Homeopathy, such as the homeopathic remedy Rhus tox and Arnica, has been traditionally used to help relieve the symptoms of rheumatoid and osteoarthritis. Arnileve: Apply Arnileve Arnica Cream liberally to the affected area in order to reduce inflammation and hasten recovery time. Based on the above labeling and claims, these products are drugs under section 201(g)(1)(B) of the Act (21 U.S.C. 321(g)(1)(B)), because they are intended for use in the diagnosis, cure, mitigation, treatment, or prevention of disease in man, and under section 201(g)(1)(C) of the Act (21 U.S.C. 321(g)(1)(C)), because they are intended to affect the structure or any function of the body. Section 503(b)(1) of the Act (21 U.S.C. 353(b)(1)) identifies criteria for determining the prescription status of a product. The products listed above are prescription drugs within the meaning of section 503(b)(1) of the Act because they are intended to treat diseases that require diagnosis and treatment by a physician or are intended to provide treatment for symptoms usually caused by an underlying disease process that requires diagnosis and treatment by a physician. Because they may be dispensed only by prescription of a licensed practitioner, these products are misbranded under Section 503(b)(4) of the Act (21 U.S.C. 353(b)(4)) in that their labels fail to bear the symbol, "Rx only."1 Your marketing of these misbranded products violates Sections 301(a) and (k) of the Act (21 U.S.C. 331(a) and (k)). We recognize that these products are labeled as homeopathic drugs with active ingredients measured in homeopathic strengths. The definition of "drug" in section 201(g)(1) of the Act (21 U.S.C. 321(g)(1)) includes articles recognized in the official Homeopathic Pharmacopeia of the United States (HPUS), or any supplement to it. Homeopathic drugs are subject to the same regulatory requirements as other drugs; nothing in the Act exempts homeopathic drugs from any of the requirements related to adulteration, labeling, misbranding, or approval. We acknowledge that many homeopathic drugs are manufactured and distributed without FDA approval under enforcement policies set out in the Agency s Compliance Policy Guide entitled, Conditions Under Which Homeopathic Drugs May be Marketed (CPG ) (the CPG). As its title suggests, the CPG identifies specific conditions under which homeopathic drugs may ordinarily be marketed; thus, in order to fall under the enforcement policies set forth in the CPG, a homeopathic product must meet the conditions set forth in the CPG. One of those conditions is compliance with Section 503(b) of the Act. Under the CPG, only homeopathic products intended solely for self-limiting disease conditions amenable to self-diagnosis (of symptoms) and treatment may be marketed OTC. Homeopathic products offered for conditions not amenable to OTC use must be marketed as prescription products.2 The violations cited in this letter are not intended to be an all-inclusive statement of violations that exist at your facility. You are responsible for investigating and determining the causes of the violations identified above and for preventing their recurrence and the occurrence of other violations. If you wish to continue to ship your products to the United States, it is the responsibility of your firm to ensure compliance with all U.S. standards for CGMP and all applicable U.S. laws and regulations. Until all corrections have been completed and FDA has confirmed corrections of the violations
5 Page 5 of 6 and your firm s compliance with CGMP, FDA may withhold approval of any new applications or supplements listing your firm as a drug product manufacturer. In addition, failure to correct these violations may result in FDA refusing admission of articles manufactured at A Nelson & Co., Ltd., located at 5-9 Endeavour Way, Wimbledon, London, United Kingdom, into the United States. The articles are subject to refusal of admission pursuant to section 801(a)(3) of the Act [21 U.S.C. 381(a)(3)], in that, the methods and controls used in their manufacture do not appear to conform to Current Good Manufacturing Practice within the meaning of section 501(a) (2)(B) of the Act [21 U.S.C. 351(a)(2)(B)]. Within fifteen working days of receipt of this letter, please notify this office in writing of the specific steps that you have taken to correct violations. Include an explanation of each step being taken to prevent the recurrence of violations and copies of supporting documentation. If you cannot complete corrective action within fifteen working days, state the reason for the delay and the date by which you will have completed the correction. Additionally, your response should state if you no longer manufacture or distribute the drug products manufactured at this facility, and provide the dates and reasons you ceased production. Please identify your response with FEI # If you have questions or concerns regarding this letter, contact Allison A. Aldridge, Ph.D., Compliance Officer, at the below address and telephone number. U.S. Food and Drug Administration Center for Drug Evaluation and Research Office of Manufacturing and Product Quality Division of International Drug Quality White Oak, Building 51, Room New Hampshire Ave Silver Spring, MD Tel: (301) Fax: (301) Sincerely, /Steven Lynn/ Steven Lynn Director Office of Manufacturing and Product Quality Office of Compliance Center for Drug Evaluation and Research 1 The Agency s guidance, Conditions Under Which Homeopathic Drugs May be Marketed (CPG ), states that, in accordance with 503(b)(1) of the Act, homeopathic drug products offered for conditions that require diagnosis or treatment by a licensed practitioner must bear the prescription legend, "Caution: Federal law prohibits dispensing without prescription. This guidance was issued by the agency in In 1997, Congress enacted the Food and Drug Administration Modernization Act (FDAMA); section 126 of FDAMA amended 503(b)(4) of the Act to require that the label of a prescription drug must bear the symbol Rx only. 2 We note that the CPG also states that, if the HPUS specifies a distinction between nonprescription (OTC) and prescription status of a product based on strength (e.g., 30X), and that distinction is more restrictive than section 503(b) of the Act, the more stringent criteria (i.e., the HPUS criteria) will apply. It follows from this that, if the HPUS specifies a distinction between OTC and prescription status based on strength, and that distinction is less restrictive than section 503(b) of the Act, the section 503(b) criteria will apply regardless of the HPUS distinction. Page Last Updated: 08/07/2012
6 Page 6 of 6 Note: If you need help accessing information in different file formats, see Instructions for Downloading Viewers and Players. Accessibility Contact FDA Careers FDA Basics FOIA No Fear Act Site Map Transparency Website Policies U.S. Food and Drug Administration New Hampshire Avenue Silver Spring, MD Ph INFO-FDA ( ) FDA For Government For Press Combination Products Advisory Committees Science & Research Regulatory Information Safety Emergency Preparedness International Programs News & Events Training and Continuing Education Inspections/Compliance State & Local Officials Consumers Industry Health Professionals Links on this page:
Inspections, Compliance, Enforcement, and Criminal Investigations
Page 1 of 6 Home Inspections, Compliance, Enforcement, and Criminal Investigations Enforcement Actions Warning Letters Inspections, Compliance, Enforcement, and Criminal Investigations P.A. Benjamin Manufacturing
More informationTSDR Pharmacy Inc. dba brandmd Skin Care 11/9/17
TSDR Pharmacy Inc. dba brandmd Skin Care 11/9/17 Division of Pharmaceutical Quality Operations IV 19701 Fairchild, Irvine, CA 92612-2506 Telephone: 949-608-2900 Fax: 949-608-4417 WARNING LETTER VIA SIGNATURE
More informationRaritan Pharmaceuticals, Inc. 6/20/17
Raritan Pharmaceuticals, Inc. 6/20/17 U.S. Food & Drug Administration Division of Pharmaceutical Quality Operations I New Jersey District 10 Waterview Boulevard, 3rd Floor Parsippany, NJ 07054 June 20,
More informationTown and Country Compounding and Consultation Services, LLC 10/17/17
Town and Country Compounding and Consultation Services, LLC 10/17/17 Division of Pharmaceutical Quality Operations I 10 Waterview Blvd, 3rd FL Parsippany, NJ 07054 Telephone: (973) 331-4900 FAX: (973)
More informationSan Diego Compounding Pharmacy 9/25/17
San Diego Compounding Pharmacy 9/25/17 Division of Pharmaceutical Quality Operations IV 19701 Fairchild Road Los Angeles, CA 92612 WARNING LETTER VIA UNITED PARCEL SERVICE SIGNATURE REQUIRED September
More informationInspections, Compliance, Enforcement, and Criminal Investigations
Page 1 of 5 Home Inspections, Compliance, Enforcement, and Criminal Investigations Enforcement Actions Warning Letters Inspections, Compliance, Enforcement, and Criminal Investigations V-SAB Medical Labs,
More informationTheoriginalhcgdrops.com 11/28/11
Theoriginalhcgdrops.com 11/28/11 UNITED STATES OF AMERICA FEDERAL TRADE COMMISSION BUREAU OF CONSUMER PROTECTION WASHINGTON, D.C. 20580 DEPARTMENT OF HEALTH AND HUMAN SERVICES FOOD AND DRUG ADMINISTRATION
More informationStonegate Pharmacy LP 11/10/16
Stonegate Pharmacy LP 11/10/16 November 10, 2016 2017 DAL WL 03 WARNING LETTER UPS Overnight Rene F. Garza, Pharm.D., Chief Executive Officer Stonegate Pharmacy, LP 2501 W. William Cannon Drive, Suite
More informationHieber's Pharmacy 12/5/17
Hieber's Pharmacy 12/5/17 Division of Pharmaceutical Quality Operations I 10 Waterview Blvd, 3rd FL Parsippany, NJ 07054 Telephone: (973) 331-4900 FAX: (973) 331-4969 CERTIFIED MAIL RETURN RECEIPT REQUESTED
More informationTalon Compounding Pharmacy 10/3/17
Talon Compounding Pharmacy 10/3/17 Office of Pharmaceutical Quality Operations, Division II 4040 N. Central Expressway, Suite 300 Dallas, Texas 75204 October 3, 2017 CMS Case # 522630 VIA UPS EXPRESS WARNING
More informationInspections, Compliance, Enforcement, and Criminal Investigations
Page 1 of 8 Home Inspections, Compliance, Enforcement, and Criminal Investigations Compliance Actions and Activities Warning Letters 2014 Inspections, Compliance, Enforcement, and Criminal Investigations
More informationSandoz Inc. 12-Aug-08
Sandoz Inc. 12-Aug-08 Department of Health and Human Services Public Health Service Food and Drug Administration Atlanta District Office 60 8th Street, N.E. Atlanta, Georgia 30309 August 12, 2008 VIA FEDERAL
More informationInspections, Compliance, Enforcement, and Criminal Investigations
Home Inspections, Compliance, Enforcement, and Criminal Investigations Enforcement Actions Warning Letters Inspections, Compliance, Enforcement, and Criminal Investigations Burzynski Research Institute
More informationPublic Health Service Food and Drug Administration San Francisco District 1431 Harbor Bay Parkway Alameda, CA Telephone: 510/
Department of Health and Human Services Public Health Service Food and Drug Administration San Francisco District 1431 Harbor Bay Parkway Alameda, CA 94502-7070 Telephone: 510/337-6700 WARNING LETTER December
More informationInspections, Compliance, Enforcement, and Criminal Investigations
Home Inspections, Compliance, Enforcement, and Criminal Investigations Enforcement Actions Warning Letters Inspections, Compliance, Enforcement, and Criminal Investigations Dimitri Sirakoff 9/12/13 Department
More informationInspections, Compliance, Enforcement, and Criminal Investigations
Page 1 of 9 Inspections, Compliance, Enforcement, and Criminal Investigations Phoenix Medical Devices, LLC 9/29/2009 Department of Health and Human Services Public Health Service Food and Drug Administration
More informationUse of Standards in Substantial Equivalence Determinations
Guidance for Industry and for FDA Staff Use of Standards in Substantial Equivalence Determinations Document issued on: March 12, 2000 U.S. Department Of Health And Human Services Food and Drug Administration
More informationGuidance for Industry DRAFT GUIDANCE. This guidance document is being distributed for comment purposes only.
Compounded Drug Products That Are Essentially Copies of a Commercially Available Drug Product Under Section 503A of the Federal Food, Drug, and Cosmetic Act Guidance for Industry DRAFT GUIDANCE This guidance
More informationReishi D. International, Inc. 2/6/18
Reishi D. International, Inc. 2/6/18 San Francisco District Office 1431 Harbor Bay Parkway Alameda, CA 94502-7070 Via UPS Overnight February 7, 2018 Mr. Zheng Xiong Li, CEO Reishi D. International, Inc.
More informationPublic Health Service Food and Drug Administration Dallas District 4040 North Central Expressway Dallas, Texas
Department of Health and Human Services Public Health Service Food and Drug Administration Dallas District 4040 North Central Expressway Dallas, Texas 75204-3128 March 30, 2010 2010-DAL-WL-08 CERTIFIED
More informationRock Solid Nutrition, LLC 12/22/16
Rock Solid Nutrition, LLC 12/22/16 December 22, 2016 WARNING LETTER Kansas City District Office 8050 Marshall Drive - Suite 205 Lenexa, Kansas 66214-1524 913-495-5100 VIA UNITED PARCEL SERVICE OVERNIGHT
More informationInspections, Compliance, Enforcement, and Criminal Investigations
Home Inspections, Compliance, Enforcement, and Criminal Investigations Enforcement Actions Warning Letters Inspections, Compliance, Enforcement, and Criminal Investigations Stanislaw R Burzynski, MD 12/3/13
More informationBetter Health Lab, Inc 2/18/15
U.S. Food and Drug Administration Protecting and Promoting Your Health Better Health Lab, Inc 2/18/15 Department of Health and Human Services Public Health Service Food and Drug Administration New Jersey
More informationDEPARTMENT OF HEALTH & HUMAN SERVICES Food and Drug Apini$r$iy -tq 5-f
DEPARTMENT OF HEALTH & HUMAN SERVICES Food and Drug Apini$r$iy -tq 5-f J Dallas District 4040 North Central Expressway Dallas, Texas 75204-3145 Ref: 2004-DAL-WL-03 WARNING LETTER CERTIFIED MAIL RETURN
More informationcgmp (21 CFR 111) Regulation and Compliance Overview
cgmp (21 CFR 111) Regulation and Compliance Overview Neogen Effective Compliance Seminar September 23, 2014 Michael McGuffin President, American Herbal Products Association mmcguffin@ahpa.org Regulation
More informationTeva Pharmaceuticals USA Attention: Scott D. Tomsky Vice President, US Generics Regulatory Affairs 425 Privet Road Horsham, PA 19044
DEPARTMENT OF HEALTH & HUMAN SERVICES ANDA 090783 Food and Drug Administration Silver Spring, MD 20993 Teva Pharmaceuticals USA Attention: Scott D. Tomsky Vice President, US Generics Regulatory Affairs
More informationOverview of Dietary Supplement GMP Inspection Trends Quality Session 6
Overview of Dietary Supplement GMP Inspection Trends Quality Session 6 Presented by: Dean R. Cirotta, MBA President & Chief Operating Officer EAS Consulting Group, LLC 1700 Diagonal Road, Suite 750 Alexandria,
More informationOptimum Bioenergy International Corp. 12/21/17
Optimum Bioenergy International Corp. 12/21/17 Office of Human and Animal Food Division 5 West 1431 Harbor Bay Parkway Alameda, CA 94502-7070 Sent Via UPS Signature Required WARNING LETTER December 21,
More informationOver-the-Counter Pediatric Liquid Drug Products Containing Acetaminophen
Reprinted from FDA s website by EAS Consulting Group, LLC Over-the-Counter Pediatric Liquid Drug Products Containing Acetaminophen Guidance for Industry DRAFT GUIDANCE This guidance document is being distributed
More informationEden s Answers Inc. and Sprigs Life Inc. 12/14/17
Eden s Answers Inc. and Sprigs Life Inc. 12/14/17 Cincinnati District Office 6751 Steger Drive Cincinnati, OH 45237 Telephone: (513) 679-2700 FAX: (513) 679-2772 December 14, 2017 VIA UPS Overnight Delivery
More informationTaylor C. Wallace, PhD, CFS, FACN, March 22, 2018
Food Ingredients Taylor C. Wallace, PhD, CFS, FACN, March 22, 2018 Disclosures Think Healthy Group, Inc. George Mason University, Department of Nutrition and Food Studies Journal of the American College
More information4/26/2013. Libia Lugo Drug Specialist San Juan District Office Investigations Branch
Libia Lugo Drug Specialist San Juan District Office Investigations Branch The Food and Drug Administration (FDA) responsibilities extend to the 50 United States, the District of Columbia, Puerto Rico,
More informationNew England Compounding Center 04-Dec-06
New England Compounding Center 04-Dec-06 Department of Health and Human Services Public Health Service Food and Drug Administration New England District One Montvale Avenue Stoneham, Massachusetts 02180
More informationOpiate Freedom Center 1/11/18
Opiate Freedom Center 1/11/18 UNITED STATES OF AMERICA DEPARTMENT OF HEALTH FEDERAL TRADE COMMISSION AND HUMAN SERVICES BUREAU OF CONSUMER FOOD AND DRUG ADMINISTRATION PROTECTION SILVER SPRING, MD 20993
More informationAs Introduced. 132nd General Assembly Regular Session H. B. No
132nd General Assembly Regular Session H. B. No. 560 2017-2018 Representative Lanese A B I L L To amend sections 923.41, 923.48, and 923.51 of the Revised Code to prohibit pet food from containing remains
More informationResidual Solvents: FDA/ Regulatory Perspective
Rosa Motta Compliance Officer Residual Solvents: FDA/ Regulatory Perspective PDA/USP Residual Solvents Conference January 18-19, 2007 1 Outline Laws and regulations governing the compliance requirements
More informationNOTICE OF INITIATION OF DISQUALIFICATION PROCEEDINGS AND OPPORTUNITY TO EXPLAIN (NIDPOE)
DEPARTMENT OF HEALTH & HUMAN SERVICES Public Health Service Food and Drug Administration Silver Spring, MD 20993 NOTICE OF INITIATION OF DISQUALIFICATION PROCEEDINGS AND OPPORTUNITY TO EXPLAIN (NIDPOE)
More informationAgency Information Collection Activities; Submission for Office of Management and Budget
This document is scheduled to be published in the Federal Register on 01/28/2016 and available online at http://federalregister.gov/a/2016-01690, and on FDsys.gov 4164-01-P DEPARTMENT OF HEALTH AND HUMAN
More informationCOMPETENT AUTHORITY (UK) MEDICAL DEVICES DIRECTIVES GUIDANCE NOTES FOR MANUFACTURERS OF DENTAL APPLIANCES
COMPETENT AUTHORITY (UK) 10 EC MEDICAL DEVICES DIRECTIVES GUIDANCE NOTES FOR MANUFACTURERS OF DENTAL APPLIANCES (CUSTOM MADE DEVICES) Updated March 2008 CONTENTS PAGE Introduction 3 Definition of dental
More informationCERTIFIED MAIL RETURN RECEIPT REQUESTED. Esther Hernandez President United States Blood Bank, Inc NW 95th Avenue Miami, Florida
DEPARTMENT OF HEALTH AND HUMAN SERVICES Food and Drug Administration Silver Spring MD 20993 CERTIFIED MAIL RETURN RECEIPT REQUESTED Esther Hernandez President United States Blood Bank, Inc. 2400 NW 95th
More informationInspections, Compliance, Enforcement, and Criminal Investigations
Home > Inspections, Compliance, Enforcement, and Criminal Investigations > Enforcement Actions > Warning Letters Inspections, Compliance, Enforcement, and Criminal Investigations Punjwani, Sohail S., M.D.
More informationNOTICE OF INITIATION OF DISQUALIFICATION PROCEEDINGS AND OPPORTUNITY TO EXPLAIN (NIDPOE)
DEPARTMENT OF HEALTH & HUMAN SERVICES Public Health Service Food and Drug Administration Silver Spring, MD 20993 NOTICE OF INITIATION OF DISQUALIFICATION PROCEEDINGS AND OPPORTUNITY TO EXPLAIN (NIDPOE)
More informationPick and Pay Inc dba Cili Minerals 5/8/15
U.S. Food and Drug Administration Protecting and Promoting Your Health Pick and Pay Inc dba Cili Minerals 5/8/15 Department of Health and Human Services Public Health Service Food and Drug Administration
More informationperpetuate -- and perhaps even intensify -- that controversy. 1 On July 18th, the Fifth Circuit affirmed FDA s longstanding position that
Food & Drug July 29, 2008 Fifth Circuit Rules that FDA May Regulate Compounded Drugs as New Drugs Update on Medical Center Pharmacy v. Mukasey For decades, the pharmacy compounding industry has disputed
More informationRecall Guidelines. for Chinese Medicine Products
Recall Guidelines for Chinese Medicine Products April 2018 Recall Guidelines for Chinese Medicine Products Chinese Medicines Board Chinese Medicine Council of Hong Kong Compiled in September 2005 1 st
More informationInspections, Compliance, Enforcement, and Criminal Investigations
Home > Inspections, Compliance, Enforcement, and Criminal Investigations > Enforcement Actions > Warning Letters Inspections, Compliance, Enforcement, and Criminal Investigations Chawla, Sant P., M.D.
More informationCompare Results. 153 Replacements 26 Insertions 344 Deletions. Total Changes. Styling and. Content. 0 Annotations. Old File: New File:
3/1/2019 4:12:31 PM Compare Results Old File: Draft Guidance.pdf 20 pages (438 KB) 3/21/2018 3:55:17 PM versus New File: Final Guidance.pdf 21 pages (323 KB) 2/28/2019 11:42:05 AM Total Changes 523 Text
More informationRE: Permits under the Arizona Pharmacy Act should not be required for dietary supplements
Board Members Arizona State Board of Pharmacy 1616 W. Adams St., Suite 120 Phoenix, AZ 85007 c/o Kam Gandhi, PharmD Executive Director Arizona State Board of Pharmacy Via email: kgandhi@azpharmacy.gov
More informationGuidance for Industry
Guidance for Industry Dosage Delivery Devices for OTC Liquid Drug Products DRAFT GUIDANCE This guidance document is being distributed for comment purposes only. Comments and suggestions regarding this
More informationOVERVIEW OF THE 2017 VFD PROGRAM
OVERVIEW OF THE 2017 VFD PROGRAM Iowa Department of Agriculture and Land Stewardship Jeff Verzal, Compliance Investigator BACKGROUND In 1996 Congress passed Federal Law stating that medicated feeds which
More informationLopez Gonzalez Santana Corporation dba Domel and dba Dermixx 8/28/17
Lopez Gonzalez Santana Corporation dba Domel and dba Dermixx 8/28/17 Office of Human and Animal Food Operations East Division IV Compliance Branch 466 Avenida Fernández Juncos San Juan, Puerto Rico 00901-3223
More informationNOTICE OF INITIATION OF DISQUALIFICATION PROCEEDINGS AND OPPORTUNITY TO EXPLAIN
DEPARTMENT OF HEALTH & HUMAN SERVICES Public Health Service Food and Drug Administration 1401 Rockville Pike Rockville, MD 20852-1448 September 26, 2011 By Overnight Delivery Michael Dean Berger, M.D.
More informationANDA Submissions Refuse to Receive for Lack of Proper Justification of Impurity Limits Guidance for Industry
ANDA Submissions Refuse to Receive for Lack of Proper Justification of Impurity Limits Guidance for Industry DRAFT GUIDANCE This guidance document is being distributed for comment purposes only. Comments
More informationOverview of FDA Oversight and Enforcement on Drug Compounding
Overview of FDA Oversight and Enforcement on Drug Compounding Ruey Ju, Pharm.D., J.D. Senior Advisor for Compounding Compliance and Enforcement (Acting) Center for Drug Evaluation and Research Today s
More informationGuidance - IDE Early/Expanded Access for Devices
Guidance - IDE Early/Expanded Access for Devices An unapproved medical device may normally only be used on human subjects through an approved clinical study in which the subjects meet certain criteria
More informationFinal Rule for Preventive Controls for Animal Food
Final Rule for Preventive Controls for Animal Food http://www.fda.gov/fsma THE FUTURE IS NOW 1 Background Current Good Manufacturing Practice, Hazard Analysis, and Risk-Based Preventive Controls for Food
More informationIN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW MEXICO ) ) ) ) ) ) ) ) ) INFORMATION. General Allegations. A. Introduction and Background
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW MEXICO UNITED STATES OF AMERICA, Plaintiff, vs. MOHAMED BASEL ASWAD, M.D., Defendant. CRIMINAL NO. 21 U.S.C. 331(a and 333(a(1: Introduction
More informationFood Fortification Regulations, 2016 (Gazetted on 24 October, 2016) ARRANGEMENT OF SECTIONS PART I PRELIMINARY
Statutory Instrument 120 of 2016 Food Fortification Regulations, 2016 (Gazetted on 24 October, 2016) [Cap 15:05 Section 1 Title 2 Interpretation ARRANGEMENT OF SECTIONS PART I PRELIMINARY 3 Inspection
More informationUSP Perspective on Atypical Actives November 29, 2017
USP Perspective on Atypical Actives November 29, 2017 USP Excipients Stakeholder Forum USP Perspective on Atypical Actives Catherine Sheehan, M.S., M.S. Senior Director, Science Excipients Outline Role
More informationTHE NON PENICILLIN BETA LACTAM DRUG CROSS CONTAMINATION PREVENTION; USFDA PERSPECTIVE
THE NON PENICILLIN BETA LACTAM DRUG CROSS CONTAMINATION PREVENTION; USFDA PERSPECTIVE An overview by Sarah Vugigi, M. Pharm, Elys Chemical Industries Ltd, Nairobi, Kenya INTRODUCTION This guidance describes
More informationEnforcement Policy Statement on Marketing Claims for OTC Homeopathic Drugs
This document is scheduled to be published in the Federal Register on 12/13/2016 and available online at https://federalregister.gov/d/2016-29770, and on FDsys.gov [BILLING CODE: 6750-01S] FEDERAL TRADE
More informationCENTER FOR DRUG EVALUATION AND RESEARCH. APPLICATION NUMBER: Orig1s000 APPROVAL LETTER
CENTER FOR DRUG EVALUATION AND RESEARCH APPLICATION NUMBER: 202107Orig1s000 APPROVAL LETTER DEPARTMENT OF HEALTH AND HUMAN SERVICES Food and Drug Administration Silver Spring MD 20993 NDA 202107 NDA APPROVAL
More informationSUMMARY: The Food and Drug Administration (FDA) is requesting public input on updated
This document is scheduled to be published in the Federal Register on 11/22/2017 and available online at https://federalregister.gov/d/2017-25245, and on FDsys.gov 4164-01-P DEPARTMENT OF HEALTH AND HUMAN
More informationRULES OF THE TENNESSEE BOARD OF PHARMACY CHAPTER DRUG DONATION REPOSITORY PROGRAM TABLE OF CONTENTS
RULES OF THE TENNESSEE BOARD OF PHARMACY CHAPTER 1140-17 DRUG DONATION REPOSITORY PROGRAM TABLE OF CONTENTS 1140-17-.01 Definitions 1140-17-.02 Purpose 1140-17-.03 Eligibility Criteria for Program Participation
More informationJanuary 7, Dear Ms. Chung:
DEPARTMENT OF HEALTH & HUMAN SERVICES Public Health Service Food and Drug Administration 10903 New Hampshire Avenue Document Control Center WO66-G609 Silver Spring, MD 20993-0002 January 7, 2015 Jeisys
More informationSanapac Co., Inc. 3/24/17
Sanapac Co., Inc. 3/24/17 WARNING LETTER 17 PHI 07 PHILADELPHIA DISTRICT U.S. CUSTOMHOUSE 2ND AND CHESTNUT STREETS ROOM 900 PHILADELPHIA, PA 19106 TELEPHONE: 215 597 4390 VIA UNITED PARCEL SERVICE OVERNIGHT
More informationAFDO Conference June 9, Mercedes Mota, Director Medical Device, Surgical Care Johnson & Johnson Quality & Compliance Worldwide
AFDO Conference June 9, 2009 Mercedes Mota, Director Medical Device, Surgical Care Johnson & Johnson Quality & Compliance Worldwide Government Agencies 483 observations A violation of the FD&C Act involving
More informationH 7816 S T A T E O F R H O D E I S L A N D
LC00 01 -- H 1 S T A T E O F R H O D E I S L A N D IN GENERAL ASSEMBLY JANUARY SESSION, A.D. 01 A N A C T RELATING TO BUSINESSES AND PROFESSIONS - PHARMACIES Introduced By: Representatives Serpa, Canario,
More informationPlanning For The FDA s 'Deeming Rule' For E- Cigarettes
Law360, New York (September 21, 2015, 3:39 PM ET) -- The 2009 Family Smoking Prevention and Tobacco Control Act (TCA)[1] gave the U.S. Food and Drug Administration the authority to oversee the manufacture,
More informationCase 2:18-cv JTF-dkv Document 1 Filed 09/25/18 Page 1 of 17 PageID 1 IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TENNESSEE
Case 2:18-cv-02656-JTF-dkv Document 1 Filed 09/25/18 Page 1 of 17 PageID 1 IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TENNESSEE ) UNITED STATES OF AMERICA, ) ) Civil No: 18-2656 Plaintiff,
More informationApril 30, By Electronic Mail
April 30, 2018 By Electronic Mail Dr. Scott Gottlieb, Commissioner Office of the Commissioner Food and Drug Administration 10903 New Hampshire Avenue Silver Spring, MD 20993 CommissionerFDA@fda.hhs.gov
More informationTOBACCO PRODUCT OR MEDICAL PRODUCT?
TOBACCO PRODUCT OR MEDICAL PRODUCT? Priscilla Callahan-Lyon, MD Deputy Director Division of Individual Health Science Office of Science, CTP Grail Sipes, JD Director Office of Regulatory Policy, CDER Disclaimer:
More informationThe proposed rule is significant, and the requirements and exceptions are complex. Key provisions of the proposal are described below.
ADVISORY Food & Drug FDA ISSUES PROPOSED RULE TO ESTABLISH A UNIQUE DEVICE IDENTIFICATION SYSTEM FOR MEDICAL DEVICES July 16, 2012 On July 11, 2012, the Food and Drug Administration (FDA) published in
More informationFDA Laws & Pharmacy Practice
Objectives FDA Laws & Pharmacy Practice Tom Hazlet Pharmacy 543 October 6, 2004 Be able to discuss the evolution of food and drug law in the United States Be able to discuss the ways in which pharmacists
More informationDraft Guidance for Industry and FDA Staff
Draft Guidance for Industry and FDA Staff Submission and Review of Sterility Information in Premarket Notification (510(k)) Submissions for Devices Labeled as Sterile DRAFT GUIDANCE This guidance document
More informationQuality. Guaranteeing High Quality. Outsourced Pharmacy Services. Disclosure 3/18/2013
Disclosure Outsourced Pharmacy Services By: Eddie Bostic, RPh For: South Carolina Society of Health System Pharmacist Annual Meeting, March 24 th 2013 Charleston, SC The views and opinions expressed in
More informationTobin's Royal Stag, Inc. dba Tobin Farms Velvet Antler 4/19/17
Tobin's Royal Stag, Inc. dba Tobin Farms Velvet Antler 4/19/17 UNITED PARCEL SERVICE OVERNIGHT DELIVERY April 19, 2017 Darrell Tobin Owner Tobin's Royal Stag, Inc. P.O. Box 108 Alna, ME 04535 0108 Dear
More informationInspections, Compliance, Enforcement, and Criminal Investigations
Home > Inspections, Compliance, Enforcement, and Criminal Investigations > Enforcement Actions > Warning Letters Inspections, Compliance, Enforcement, and Criminal Investigations Ratzan, Judith M.D. 2/16/11
More informationPreparing a US FDA Medical Device 510(K) Submission
Preparing a US FDA Medical Device 510(K) Submission If you want to introduce your medical device to the US market, you need to obtain clearance from the FDA. This clearance is obtained from the FDA via
More informationNestle Infant Nutrition 10/31/14
U.S. Food and Drug Administration Protecting and Promoting Your Health Nestle Infant Nutrition 10/31/14 OCT 31, 2014 Department of Health and Human Services Public Health Service Food and Drug Administration
More informationInternational Pharmaceutical Aerosol Consortium on Regulation and Science
International Pharmaceutical Aerosol Consortium on Regulation and Science 1500 K Street NW Washington DC 20005 Telephone +1 202 230 5607 Fax +1 202 842 8465 Email info@ipacrs.org Web www.ipacrs.org Submitted
More informationQuestions or comments regarding the content of the NHPD Monthly Communiqué may be addressed to
The NHPD Monthly Communiqué is a publication of Health Canada s Natural Health Products Directorate (NHPD), the federal department responsible for the regulation of natural health products sold in Canada.
More informationGenetic Edge Compounds LLC 4/14/17
Genetic Edge Compounds LLC 4/14/17 April 14, 2017 2017 DAL WL 15 UPS Overnight Bradley N. Howard, Owner and CEO Genetic Edge Compounds, LLC (b)(6), (b)(7)(c) McKinney, Texas 75070 Mr. Howard: WARNING LETTER
More informationARKANSAS STATE UNIVERSITY GOVERNING PRINCIPLES FOR THE USE OF CONTROLLED SUBSTANCES IN RESEARCH
ARKANSAS STATE UNIVERSITY GOVERNING PRINCIPLES FOR THE USE OF CONTROLLED SUBSTANCES IN RESEARCH 1.0 INTRODUCTION Arkansas State University (ASU) is committed to enhancing the growth of research and other
More informationCommercial Feed Mill Verification Task Procedures
Introduction The Canadian Food Inspection Agency (CFIA) is dedicated to safeguarding food, animals and plants, which enhances the health and well-being of Canada s people, environment and economy. As part
More informationWHITE PAPER ACCESS TO GOOD QUALITY DIETARY SUPPLEMENTS
WHITE PAPER ACCESS TO GOOD QUALITY DIETARY SUPPLEMENTS SEPTEMBER 23, 2009 COUNCIL OF THE CONVENTION SECTION ON THE QUALITY OF FOOD INGREDIENTS AND DIETARY SUPPLEMENTS INTRODUCTION The 1994 Dietary Supplement
More informationPutting the Nutritional Supplement Industry to the Test: Looking for Transparency
Putting the Nutritional Supplement Industry to the Test: Looking for Transparency Frederick H. Fern @RickFern_HB ffern@harrisbeach.com Marina Plotkin @MarinaPlotkin_HB mplotkin@harrisbeach.com Putting
More informationFDA Basics FDA s Import Operations: How FDA Regulates Imported Products
FDA Basics FDA s Import Operations: How FDA Regulates Imported Products Carlos W. Hernandez Compliance Officer U.S. Food and Drug Administration Global Regulatory Operations and Policy Office of Regulatory
More informationINTRODUCTION TO DRUG LAW AND REGULATION: REGULATION OF DRUG MANUFACTURING
Food and Drug Law Institute's Workshop on INTRODUCTION TO DRUG LAW AND REGULATION: REGULATION OF DRUG MANUFACTURING November 8-9, 2010 Park Hyatt Hotel Washington, D.C. 1 REGULATION OF DRUG MANUFACTURING
More informationCDER Compliance Update
CDER Compliance Update Donald D. Ashley, JD 22 nd Annual GMP by the Sea August 30, 2017 www.fda.gov www.fda.gov 2 Office of Compliance Structure Office of Compliance Office of Drug Security, Integrity
More informationOverview of the Legal Framework for Medical Device Regulation in the United States
1 Overview of the Legal Framework for Medical Device Regulation in the United States Ellen J. Flannery This chapter provides an overview of the legal framework for medical device regulation in the United
More informationInspections, Compliance, Enforcement, and Criminal Investigations. Central Texas Regional Blood & Tissue Center 07-Nov-03
1 of 7 6/10/2009 2:20 PM Inspections, Compliance, Enforcement, and Criminal Investigations Department of Health and Human Services Public Health Service Food and Drug Administration Dallas District 4040
More informationSECTION PRESCRIPTIONS
SECTION.1800 - PRESCRIPTIONS 21 NCAC 46.1801 EXERCISE OF PROFESSIONAL JUDGMENT IN FILLING PRESCRIPTIONS (a) A pharmacist or device and medical equipment dispenser shall have a right to refuse to fill or
More informationDietary Supplement Health and Education Act of 1994 Public Law rd Congress
Dietary Supplement Health and Education Act of 1994 Public Law 103-417 103rd Congress An Act To amend the Federal Food, Drug, and Cosmetic Act to establish standards with respect to dietary supplements,
More informationAKA Good Manufacturing Practice (GMP) Certification Program
AKA Good Manufacturing Practice (GMP) Certification Program Preamble The American Kratom Association (AKA) is establishing this program to assure the safety and integrity of kratom dietary supplements
More information51ST LEGISLATURE - STATE OF NEW MEXICO - FIRST SESSION, 2013
SENATE BILL ST LEGISLATURE - STATE OF NEW MEXICO - FIRST SESSION, 0 INTRODUCED BY Peter Wirth 0 AN ACT RELATING TO COMMERCE; AMENDING AND ENACTING SECTIONS OF THE NEW MEXICO FOOD ACT AND THE COMMERCIAL
More informationTruVision Health LLC 11/30/17
TruVision Health LLC 11/30/17 Denver District Office 6 th Ave & Kipling St, Bldg 20 DFC P.O. Box 25087 Denver, CO 80225 November 30, 2017 WARNING LETTER Via UPS Overnight Ref: # HAFW4(DEN)-18-02-WL David
More informationLong Life Unlimited 1/31/18
Long Life Unlimited 1/31/18 Cincinnati District Office 6751 Steger Drive Cincinnati, OH 45237 Telephone: (513) 679-2700 FAX: (513) 679-2772 WARNING LETTER 533282 January 31, 2018 VIA UPS Long Life Unlimited,
More information