FDA Form 483 – Inspectional Observations and Citation
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FDA Form 483 – Inspectional Observations and Citation
An FDA Form 483 is issued to firm management at the conclusion of an inspection when an investigator(s) has observed any conditions that in their judgment may constitute violations of the Food Drug and Cosmetic (FD&C) Act and related Acts. FDA investigators are trained to ensure that each observation noted on the FDA Form 483 is clear, specific and significant. Observations are made when in the investigator’s judgment, conditions or practices observed would indicate that any food, drug, device or cosmetic has been adulterated or is being prepared, packed, or held under conditions whereby it may become adulterated or rendered injurious to health.
Deviation from Law and Regulation in FDA Form 483
The FDA Form 483 is a report which does not include observations of questionable or unknown significance at the time of the inspection. There may be other objectionable conditions that exist at the firm that are not cited on the FDA Form 483. FDA investigators are instructed to note only what they saw during the course of the inspection. Companies are responsible to take corrective action to address the cited objectionable conditions and any related non-cited objectionable conditions that might exist.
FDA Form 483 sharing with the Company
FDA Form 483s are discussed with a company’s management at the conclusion of the inspection. Each observation is read and discussed so that there is a full understanding of what the observations are and what they mean.
How to respond to a Form 483 or Warning letter
You should respond to the 483 promptly and identify your action to correct the findings within the FDA’s specified time frame. A detailed response to each observation or violation is also required. The quality and promptness of your response to this letter are extremely important.
Implications of the FDA Form 483
The FDA Form 483 does not constitute a final Agency determination of whether any condition is in violation of the FD&C Act or any of its relevant regulations. The FDA will consider the Form 483, along with a written report called an Establishment Inspection Report and your response as it considers what further action, if any, is appropriate. The Agency considers all of this information and then determines what further action, if any, is appropriate to protect public health.
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