How to succeed when you get a FDA 483 form letter. What to do and how to handle your FDA 483. For more information go to http://compliance-insight.com/fda-483-warning-letters/fda-483-observations/
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1. FDA 483 ObservationsResolving the IssuesCompliance Insight,
Inc. 513-860-3512 Copyrighted 2013
2. What to do now?If you are reading this now, you are probably
in the middle ofsome sort of FDA enforcement issue. Responding to
FDA 483observations can be one of the most important, and
mostchallenging, activities in your career and the
companyshistory.Failure to ensure a proper response and failing to
clearlyindicate to the FDA that you are in CONTROL can be fatal
toyour business.
3. Writing the Response 14 PointsThere are some basic rules
that can beestablished regarding writing a responseletter.Some or
all of these rules may applydepending upon the particular situation
ofthe firm e.g. lengthy list of observationsfrom a governmental
body, client audit,warning letter pending, etc.
4. 14 Points to Success1. Someone in a high level in the
Quality Department shouldwrite the response.2. Personnel copied on
the response should include high-level management. This shows that
management at thefirm is aware of the issues and the commitments
beingmade.3. Include a cover letter or opening statement. Thank
theauditor(s) for being professional, providing insight orother
appropriate remarks as warranted. State the siteaddress of the
audit and the dates.4. Always remember that you are writing the
response tothe auditors management governmental auditingbodies as
well as clients. Do not assume that the personreading the report
understands the context of theobservation or your reply.
5. 14 Points to Success5. Re-state the observation and
reference number in theresponse. Typically, the observation goes
directly abovethe response.6. If possible, indicate the related
compliant systems. Thisshows that you are in control and that some
operationswere functioning within acceptable GMP parameters.7. If
the action item is going to take some time toimplement, state what
will be done in the interim to becompliant with GMPs? Dont simply
indicate that actionswill be taken in six months to correct the
issue in whichyou are currently out of compliance without
addressingwhat you will do to be compliant from the current
dateuntil the corrections are implemented.
6. 14 Points to Success8. If corrective actions have already
taken place, indicate thefollowing: Dates implemented Training
performed (copies of training sign-upsheets included) Copies of
Purchase Orders, installation work,etc. Copies of updated SOPs
indicating what waschanged.9. Define how enhancements will prevent
recurrence of theissue observed. Dont assume that the reader
willunderstand this fact.10. Explain what will be done to expand,
enhance orstreamline the compliance system.
7. 14 Points to Success11. Dont forget about training. Allow
sufficient time toimplement changes to incorporate training that
mayinclude proficiency testing.12. Describe how the firm will
monitor the progress andeffectiveness of the corrective actions.13.
It may be helpful to explain that despite the issues noted,there
has never been an issue. It is not advisable to usethis response
tactic each time but it can be advantageousfor critical
observations to state something on the orderof the product has
always met predetermined qualityparameters14. Revise, revise,
revise. Allow other people not directlyinvolved with the audit to
review and comment on theresponse. They may have insight on
response wordingthat would assist in clarification or strengthening
ofpoints.
8. 7 Actions to AvoidAlthough the following information is not
an exhaustive list,there are some strategies taken by firms that
indicate to anauditor the firms unwillingness to change or
inability to makeappropriate corrective actions.If a firm does not
have the capability, time or experience torespond appropriately to
an audit (especially a governmentaudit), a prime directive should
be to seek outside assistance.AVOID At all costs!
9. Pathway to Disaster1. During the closeout or in the response
letter, argue everypoint in that they are not appropriate or we
havenever had an issue with this point from other auditors.This is
called a scorched earth policy and will ensurethat the auditor has
a strong message of non-complianceto the auditor body.2. State that
the corrective actions being requested will putthe firm out of
business or drive jobs to a foreigncountry. It is a scare tactic
that has been used for atleast 20 years and has not proven to be
the case.3. The rain forest or overwhelming response.
Includemassive amounts of data that is not warranted with thehopes
that the reviewer will be impressed with thework. This type of
response sends an immediate warningsignal to the auditor that
issues are being glossed over.
10. Pathway to Disaster4. Implement changes immediately. Either
duringthe closeout meeting or with a quick response,all changes
have been implemented for complexissues. If the issue is simple,
great noproblem. However, for complex observations, arapid response
indicates that the firm has takena knee-jerk reaction and
implementedcorrective actions without thinking of the rootcause.5.
Not responding to the audit. Actions may betaken but no formal
letter is sent indicatingwhat was performed. This approach
indicatesthat the firm does not take the audit seriously.
11. Pathway to Disaster6. The enigmatic response. The firm
indicates thatactions are going to be taken but does notaddress
what these actions include. Such anexample would include: Actions
Taken Records were updated. When? How were theyupdated?7. Promise
without substance. Similar to theenigmatic response, this approach
does notindicate any specifics. An example includes:Deficiency
Detailed investigation notperformed in a timely manner. Response
Investigations will be carried out in a timelymanner.
12. Assess SystemicallyResolve Issues or Plan to Resolve
Systemically, across all sitesFinish the Response If serious
enough,follow-up with your district officeVerify that the
resolutions workedThe FDA 483 Phases to ResolvePhase 4Phase 1Phase
2Phase 3
13. The Choice is Yours!Work diligently now or face serious
issuesin the future
14. Questions? More Information?Compliance Insight,
Inc.www.Compliance-Insight.com513-860-3512FDA483Team@Compliance-Insight.comWe
have a significant source of information to help you ondealing FDA
483s Contact us for a free consultation.