FDA posted two drug-related Warning Letters and one untitled letter to a firm marketing a cell-based product. One of the drug Warning Letters concerned a compounding pharmacy.

Drug Warning and Untitled Letters


Young Foundational Health Center, LLC (Largo, FL) received an untitled letter from CBER based on content of their website and social media. The firm markets a cellular-based product advertised to treat a variety of diseases and medical conditions. The product is also determined to be an HTC/P that must be supported by an IND or a BLA.


Cosmax USA, Inc (Ridgefield Park, NJ) received a Warning Letter on October 15, 2020, based on the outcome of an inspection ending March 17, 2020.  The firm manufactures over the counter drug products; sunscreens are mentioned specifically as a product that they manufacture. FDA recommends that the firm hire a qualified consultant(s) to assist them in coming into GMP compliance. While this was not an observation they note that the company manufactures multiple products using glycerin and does not apparently test for the presence of diethylene glycol. They also note that the Quality Unit does not have the authority to exercise their responsibility. The deficiencies identified include but are not limited to:

  • Failure to investigate OOL microbiological results for water used as a raw material in their products. Other water drops were subsequently found to be out-of-limit (OOL) and in multiple instances did not identify the organism. FDA states the firm “...lacked control of the upstream part of your water system.” 
  • The firm did not have bulk hold time studies for multiple drug products that were held for as long as six months before filling.  
  • The firm failed to clean and sanitize non-dedicated production tanks according to the written procedure. The firm admitted that some employees “did not know how to adequately clean the tanks…” The cleaning process lacked documentation. For example, a bucket of cleaning solution was used without a label and its content and preparation were not supported by documentation. 

Device Warning and Untitled Letters

There were none this week.

BIMO, GCP and GLP Warning and Untitled Letters

There were none this week.

Compounding Pharmacy/Outsourcing Facilities


Surgery Pharmacy Services Inc (Chattanooga, TN) received a Warning Letter on October 9, 2020, based on the outcome of an inspection ending December 6, 2019. Note that the FDA does not cite violations of 21 CFR 211, but rather with the requirements of the FD&C Act.

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Quality Management Systems for Small Pharma and Biotech Firms

Webinar: QMS for Small Pharma and Biotech Firms

Presented on Tuesday, March 30, 2021
by Fenton Fong, Founder, Managing Director, & Principal at xCellarate

Download the slide deck and video of this informative 1-hour webinar on the common challenges small pharma firms face when developing a QMS.

What you will learn:

  • Common challenges small pharma firms face when developing a QMS
  • Recent enforcement trends involving the Quality Unit
  • Impact of the COVID-19 pandemic

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In this summary we identify:

GMP data from FY2017 to FY2020 for the Asia-Pacific region

Top 3 GMP primary and secondary citations

Top 3 483 observations

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An Analysis Of MHRA’s Latest Annual GMP Inspection Deficiencies Report

In this summary we identify:

  • Data from 2019 UK MHRA Inspections
  • Trends from 2015, 2016, 2018, and 2019 inspections
  • Conclusions drawn from an analysis of drug inspection data

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