Whether you’re a vaccine or drug manufacturer, facilities that conduct clinical trials, or a medical device company manufacturing Class II or Class III devices, you can expect random and routine inspections by the FDA. Preparing for an FDA inspection is a critical step, and ProPharma experts can guide you through the entire process.
Have You Received an FDA Form 483 Observation or Warning Letter?
Whether it’s an FDA Form 483 Observation or a Warning Letter, addressing the issue will require a lot of work, and can be very stressful. You should consider engaging the assistance of outside experts like ProPharma to help your team through the process.
Our experts can help you monitor your sites, provide independent auditing to prepare for an FDA inspection, and train your team to ensure everyone has a strong understanding of the regulations. We have extensive experience and can serve as an extension of your team, supporting you throughout the entire product lifecycle, or offering assistance with one particular area.
If you have received an FDA Form 483 Observation or Warning Letter, or you just want to take proactive steps to avoid one, contact us today to discuss how we can help.
What are FDA Form 483 Observations?
An FDA Form 483 Observation, also referred to as “inspectional observation” or “Form 483” is sent by the FDA to highlight any potential regulatory violations found during a routine inspection. An FDS Form 483 Observation can relate to the company’s facility, equipment, processes, controls, products, employee practices, or records.
While an FDA Form 483 is not a final determination on regulation violations, they are cause for concern and need to be addressed with urgency. The financial impact of an FDA Form 483 Observation can be catastrophic, sometimes costing companies several million dollars. If the issues are systemic, the FDA Form 483 Observation can trigger training, redesign, process implementation, and other measures.
What is an FDA Warning Letter?
An FDA Warning Letter is an official deficiency letter from the agency, which is sent by the investigators of the agency. Companies may receive this document in the mail, without prior notification from FDA. Before a Warning Letter is issued, the FDA requests the company to comment on the deficiencies listed in the Form 483 Observations found during the inspection. If the FDA judges this response to be unacceptable, a Warning Letter will be issued.
Typically, FDA Warning Letters are sent to ensure overnight delivery and receipt of delivery (e.g., return receipt requested, FedEx). As with an FDA 483 Observation, the company has 15 days maximum to respond in writing. However, if the cause of the Warning Letter is severe, the FDA may shorten the deadline.
FDA Form 483 Observations and Warning Letters are sometimes mistakenly identified as the same thing. Like FDA Form 483 Observations, Warning Letters can be very costly and can significantly delay time to market and consume capital in the process. However, FDA Warning Letters are more serious than Form 483 Observations because they represent an escalation of the process. As such, agency feedback from an FDA Warning Letter should be addressed immediately.
