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

Compounding Pharmacies’ Observations Correlate With Those From Large Pharma ISO 5 Facilities

March 9, 2016 By Barry Friedman Leave a Comment

Compounding pharmacies continue to receive citations from the FDA (both Form FDA 483s and Warning Letters) for a continuing failure to meet 21 CFR 210/211 requirements.  All one needs to do is visit FDA’s Electronic Reading Room to learn of the ORA audits and the subsequent citations.  Even after the New England Compounding Center … [Read more...]

FDA INSPECTION (Medisca) INITIATED FOR APIs FOLLOWING RECEIPT OF REPORTS FOR SERIOUS ADVERSE EVENTS (112515)

December 12, 2015 By Barry Friedman Leave a Comment

COMMENT:  Rarely does one observe such a flagrant number of mislabeled Active Pharmaceutical Ingredients (API) noted within a Warning Letter (Click Here).  In this Warning Letter, two of six samples of L-Citrulline repackaged for distribution to Pharmacies for use in compounding were tested by the FDA found to not be as labeled.  The firm … [Read more...]

CANCER CENTER RECEIVES FORM FDA 483 FOLLOWED BY WARNING LETTER A YEAR LATER FOR COMPROMISED ASEPTIC PROCESSING

November 22, 2015 By Barry Friedman Leave a Comment

Over the past several years, the FDA has cited a number of Compounding Centers for compromised aseptic processing. Often this has resulted in only a Form FDA 483. In other cases the actions have resulted in both a Form FDA 483 as well as a subsequent Warning Letter. The Johnson Memorial Cancer Center is one of those that has been cited for both through a 483  and a … [Read more...]

Microbial Limits / Specified Microorganisms Rationale

September 13, 2015 By Barry Friedman Leave a Comment

Microbial Limits / Specified Microorganisms Rationale. Find more at barryafriedman.com

As a “Frequently Asked Question”, the USP is often queried about the determination of microbial limits and specified microorganisms. The following, obtained from USP, provides a clarification for this commonly asked question. In determining the appropriate microbial limit, the USP Microbiology Expert Committee considers such matters as the … [Read more...]

TESTING LABORATORY RECEIVES STERILITY OBSERVATIONS

September 22, 2013 By Barry Friedman Leave a Comment

FDA FINDS LABORATORY CONDUCTING STERILITY AND ENDOTOXIN TESTING FOR COMPOUNDING CENTERS HAS SIGNIFICANT ISSUES WITH STERILITY ASSURANCE The FDA recently audited Front Range Laboratories, Loveland, CO from August 5 through August 30, 2013.  Their five investigators issued a five Observation, twelve page document.  Enclosed is Observation 1 which … [Read more...]

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