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Compounding This Week Newsletter from www.CompoundingToday.com
Our Compounding Knowledge, Your Peace of Mind
July 23, 2021  |  Volume 18  |  Issue 29
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Loyd V. Allen, Jr., Ph.d., R.Ph Letter from the Editor
The FDA and Pharmacy Compounding
FDA Form 483, Part 2

The '483 lists observations made by the FDA representative(s) during an inspection of a facility. These are inspectional observations and do not represent a final Agency determination regarding compliance.

A recipient of a 483 should:

  • respond to the FDA,
  • address each item,
    • indicating agreement and either
    • providing a timeline for correction or
    • requesting clarification of what the FDA requires.

This response (if prepared) must be submitted within 15 business days regardless of the number of observations. While a response is not required, a good response can usually help a company avoid

  • receiving a Warning Letter from the FDA,
  • withholding of product approval, or
  • a facility shut-down.

Most expert consultants warn that responses should be:

  • comprehensive,
  • well-reasoned,
  • well-documented,
  • timely, and that
  • each observation should be addressed individually.

The FDA encourages resolution of issues through informal mechanisms prior to the issuance of a 483. A formal two-tiered dispute resolution process is available and is described in the FDA document Guidance for Industry - Formal Dispute Resolution: Scientific and Technical Issues Related to Pharmaceutical CGMP, and 30 calendar days are allowed for this procedure.

Even though the U.S. FDA has jurisdiction only within the U.S., the supply chain for pharmaceuticals often extends far beyond the boundaries of the U.S., so the agency has an interest in assuring that the foreign operations part of the U.S. supply chain are in an appropriate state of control, even though they have no legal authority to do so. However, they can restrict importation into the U.S. The FDA does perform foreign inspections, and observations for these are also captured on a 483, written in English.

The "general contents" of the FDA 483 are as follows:

1. FDA Form 483 Content
    1.1 Header information
    1.2 Observations
          1.2.1 Annotation
    1.3 Signatures
    1.4 Reverse side
    1.5 Addenda/amendments
2. Public access to Form FDA 483s
3. Trends in Form FDA 483 observations
4. References
5. External links

Next week, the detailed explanation of the contents of the FDA 483 will be provided.


Loyd V. Allen, Jr., PhD, RPh
Editor-in-Chief

International Journal of Pharmaceutical Compounding
Remington: The Science and Practice of Pharmacy Twenty-second edition

 

Did You Know ...

...that during 47 years of intermittent government service, Herbert Hoover turned all of his federal salary checks over to charitable causes and institutions, including his $20,000 annual pension as a former President? He made his fortune as a mining engineer early in his career. He gave away all his governmental income, he once explained, to acknowledge "a great debt" to his country for the many advantages and opportunities that it had conferred upon him."

 

Thought of the Week (On "Debt")

At his wife's insistence, a man purchased a home on a hilltop in a very exclusive section of the community. "Ill bet there is quite a view from way up there," said his friend enviously.
"Yes," replied the homeowner, "on a clear day you can see the bank that holds the mortgage!"

A wholesaler wrote a threatening letter. This is the reply she received:

"Dear Sir: What do you mean by sending me a letter like that? Every month I place all my bills in a basket and then figure out how much money I have to pay them. Next, I draw as many bills out of the basket as I have money to pay. If you don't like my way of doing business, I won't even put your bill in the basket next month!"

"Have you forgotten that you owe me $50?" "Not yet, but give me time."

"Only Americans have mastered the art of being prosperous though broke!"

"Deficit is what you've got when you haven't as much as if you had nothing!"

Maybe our national leaders should remember what the Bible says:

"The rich rules over the poor, and the borrower is servant to the lender." (NKJV)
 

Join the CNL!

IJPC would like to invite all compounding pharmacists and technicians to join the Compounders' Network List (CNL) - an e-mail-based resource for sharing compounding information with your peers.

Go to the following website for more information and to join.

https://ijpc.com/cnl

 

Looking Back

The wife who keeps on
Being kissed,
Always heads her
Shopping list with
     Burma-Shave

 
 
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