• Home
  • About
  • UPCOMING WEBINARS & SEMINARS
  • Consultation
  • USP 61/62 FAQ
  • Contact

Barry A. Friedman, PhD LLC

FDA Regulatory Compliance for the Pharmaceutical, Biotechnology and Medical Device Arenas

HEBEI YUXING BIO-ENGINEERING CO LTD RECEIVES FDA WARNING LETTER (09/06/2016)

September 23, 2016 By Barry Friedman Leave a Comment

Hebei Yuxing Bio-Engineering Co Ltd received a FDA Warning Letter (Click Here) on September 6, 2016.  This Warning Letter came as a result of an audit from August 17-21, 2015 and the issuing of a subsequent Import Alert in July 2016.

As has often been the situation, Hebei Yuxing Bio-Engineering was placed on the FDA’s Import Alert list on July 8, 2016.  Since no other regulatory action was observed simultaneously, the assumption was that the facilities in Hebei, China had been audited and the FDA found serious deficiencies.   In doing so it banned all of its products from entering the United States.

Several months later (September 8, 2016) the FDA posted a Warning Letter which included several serious deficiencies.  Among those deficiencies was Observation #3 which discussed 67 microbiological contamination non-conformances between January 1 and August 20, 2015.  The FDA investigation documented that “microbiological contamination has been a persistent and unresolved problem at your firm since 2013”.

The FDA indicated that Hebei “have not definitely identified the specific root cause(s) of your microbiological contamination problems, nor have you taken appropriate corrective action and preventive actions”.  The firm has, however, identified four potential causes which include:

  • Contaminated (b)(4) supply due to inadequate (b)(4) controls
  • Failing (b)(4) of the (b)(4) in the (b)(4) tank (b)(4) systems
  • Production operator errors
  • Inadequate sterilization of the supplement tanks used to store materials before they are discharged into the tanks

Observation #1 was written as a “failure to have laboratory control records that include complete data derived from all laboratory tests conducted to ensure compliance with established specifications and standards”.

The Quality Control laboratory failed to record and maintain complete data from analyses of (b)(4) API.  “Prior to conducting official analyses your Quality Control laboratory performed “experimental” analyses on product batches to assess whether your API met specifications, but failed to document these “experimental” test in official laboratory records or to justify their exclusion.  Investigator found the results of 2,404 high performance liquid chromatography (HPLC) injections in a folder titled “Experimental’ on instrument SZG-002-0061.  Your Quality Unit indicated the “experimental” injections were being conducted in all (b)(4) chromatographic units in your Quality Control laboratory.  Your management provided different explanations in an attempt to justify the practice, including “fear” that the sample results would not pass.”

Share this:

  • Click to share on Twitter (Opens in new window)
  • Click to share on Facebook (Opens in new window)

Related

Filed Under: FDA Compliance, Microbiological Issues, Regulatory Compliance, Warning Letters Tagged With: data integrity, HPLC experimental analyses, import alert, inadequate sterilization, laboratory control records, microbial non-conformances, Microbiological Contamination

Subscribe to Blog via Email

Enter your email address to subscribe to this blog and receive notifications of new posts by email.

Leave a Reply Cancel reply

Your email address will not be published. Required fields are marked *

New Reader? Learn More

Connect With Me:

  • Email
  • Facebook
  • LinkedIn
  • RSS
  • Twitter

Subscribe to Blog via Email

Enter your email address to subscribe to this blog and receive notifications of new posts by email.

Webinar Registration & Information

FREQUENTLY ASKED QUESTIONS:

FDA Form 483 Frequently Asked Questions

USP General Chapter

USP General Chapter 62, Part II

TOP OBSERVATIONS:

FDA’s CDER LISTING OF TOP NINETEEN OBSERVATIONS FOR 2014

FDA CDER Most Frequent Form FDA 483 Observations Fiscal Year 2012

CDER MOST FREQUENTLY CITED DRUG OBSERVATIONS – FISCAL YEAR 2010

Top Posts:

Top Posts for 2012

Top Posts for 2013

Top Posts Year To Date

Recent Posts

  • Upcoming Microbiological Webinars
  • Microbiological Webinars
  • Microbiological Webinars 2020 (Upcoming)
  • General Chapter (USP<60>) on B. cepacia Complex to Issue December 1, 2019
  • Les Produits Chimiques B.G.R., Inc. Receives FDA Warning Letter (07/24/2018) for Failure to Perform Laboratory Testing

Categories

follow us in feedly
  • Home
  • About
  • UPCOMING WEBINARS & SEMINARS
  • Consultation
  • USP 61/62 FAQ
  • Contact
  • Email
  • Facebook
  • LinkedIn
  • RSS
  • Twitter

Thank You For Visiting Barry A. Friedman, PhD LLC - 2015

Welcome To My Blog!
Please enter your name and email below to receive my newsletter.
Your information will *never* be shared or sold to a 3rd party.