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The following are the Top Ten most frequently cited adverse observations from FDA: Top Ten All affect Sterility Assurance and are cited greater than 60% of the time in inspections: Inadequate facilities designs and controls, inadequate smoke studies Inadequate or lack of environmental monitoring of facility and people Inadequate laboratory procedures and controls (definition of a batch, sampling and testing controls) Lack of Standard Operating Procedures to prevent microbial contamination Inadequate deviation/variance controls and lack of adequate investigation Stability program nonexistent or does not support beyond use dating Validation of final sterilization (filter or terminal), media fill design Inadequate cleaning and disinfecting programs Batch release (most done at risk or with no testing for sterility, potency, identity, and pyrogens) Control of equipment (preventive maintenance and calibration program inadequate or nonexistent) The top ten are now followed by: Lack of validated analytical methods for stability and potency testing, lack of analytical methods for determining impurities and extraneous peaks in chromatography, personnel qualifications, training and skill maintenance, no segregation of beta lactams for other preparations, ineffective quality unit, labeling matters, personnel not trained in GMPS, change control, incoming supplies acquisition and approval, inadequate raw material controls, inadequate separation of operations, record keeping, and inadequate SOPs for operations, Why is the Industry struggling to meet FDA requirements and expectations
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