Lec 3a- FDA Sterile Drug Inspections

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Questions and Answers

Which dosage form is considered a variety that is tested during an FDA sterile drug inspection?

  • Topical creams
  • Oral tablets
  • Injectables (correct)
  • Transdermal patches

What is a key focus of FDA inspections regarding drug manufacturing?

  • Current Good Manufacturing Practices (CGMPs) (correct)
  • Reviewing employee satisfaction
  • Assessing market competition
  • Analyzing marketing strategies

What is one of the FDA's procedures during an inspection?

  • Sample collection (correct)
  • Offering consulting services
  • Conducting employee performance reviews
  • Negotiating drug pricing

Which of the following is a primary concern during FDA sterile drug inspections?

<p>Sterility (A)</p>
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Which of the following is an element of sterility controls?

<p>Testing (D)</p>
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During a facility tour, what should inspectors look for?

<p>Air flow patterns (C)</p>
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What documentation are manufacturers required to maintain and investigate?

<p>Complaints (A)</p>
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What is an area reviewed as part of trended data by the FDA?

<p>Environmental monitoring (D)</p>
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What is considered during general coverage of FDA sterile drug inspections?

<p>Quality systems (A)</p>
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What is an example of equipment that is commonly inspected?

<p>Isolators (A)</p>
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What aspect of 'materials' is typically assessed during an FDA inspection?

<p>Supplier qualification (B)</p>
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What is a factor evaluated during the 'production' portion of a sterile drug inspection?

<p>Gowning (A)</p>
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What aspect of packaging and labeling is evaluated during inspections?

<p>Label storage (B)</p>
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Which area does laboratory analysis cover during an FDA inspection?

<p>Microbiology (A)</p>
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What is observed during an FDA inspection?

<p>The manufacturing environment (D)</p>
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During interviews, what is a type of question asked?

<p>Open-ended questions (A)</p>
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What type of records are reviewed?

<p>Production records (D)</p>
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What is an example of evidence collected during an inspection?

<p>Photographs (C)</p>
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Who directs the inspection process?

<p>The FDA investigator (A)</p>
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What should justifications be supported by?

<p>Evidence (A)</p>
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What must data support when validating moist heat sterilization?

<p>Validation parameters (D)</p>
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For processes, what requires proof?

<p>Filter sterilization (A)</p>
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What requirements must the significant violations follow for an FDA-483?

<p>CGMP requirements (C)</p>
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What is a possible outcome after an FDA inspection?

<p>A regulatory meeting (A)</p>
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An FDA sterile drug inspection may include a review of:

<p>Aseptic techniques used in cleanroom behavior. (B)</p>
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The FDA conducts sterile drug inspections to assess a company's compliance with:

<p>Current Good Manufacturing Practices (CGMPs). (C)</p>
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The purpose of an FDA sterile drug inspection is to:

<p>Assess compliance with Current Good Manufacturing Practices (CGMPs). (D)</p>
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One reason the FDA would visit a manufacturing location is to:

<p>Follow-up on previous inspection, complaints and recalls. (A)</p>
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Common issues of concern during FDA sterile drug inspections include:

<p>Sterility and presence of pyrogens. (B)</p>
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To control for sterility concerns, companies should implement:

<p>Testing of raw materials (including water). (D)</p>
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During a facility tour, FDA inspectors are trained to:

<p>Look for critical control points and subtle issues like air flow. (D)</p>
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Manufacturers are required to document and investigate:

<p>Complaints, deviations, and failures. (D)</p>
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When reviewing environmental monitoring data, inspectors look for:

<p>Viable and non-viable particles. (D)</p>
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The 'General Coverage' portion of FDA sterile drug inspections often focuses on:

<p>The quality systems. (B)</p>
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Common equipment inspected as part of FDA sterile drug inspections includes:

<p>Container/closure washing and depyrogenation systems. (C)</p>
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In the "Materials" section, FDA inspections focus on:

<p>Components, containers, and closures. (C)</p>
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Critical parameters under process validation include:

<p>Filtering, filling, stoppering, and capping. (B)</p>
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The "packaging and labeling" review assesses:

<p>Review of labels upon receipt. (C)</p>
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Reference standards and controls are reviewed during inspections of a:

<p>Laboratory. (C)</p>
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Which dosage form is considered a variety?

<p>All of the above (D)</p>
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What is the main focus of FDA inspections?

<p>Current Good Manufacturing Practices (A)</p>
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Which of the following is a reason that would cause the FDA to visit a manufacturing location?

<p>All of the above (D)</p>
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What is looked into when learning about systems, processes, and procedures?

<p>Problems (A)</p>
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Under the FD&C Act, what is one of the ways a drug can be deemed illegal?

<p>If it is adulterated, misbranded, or an unapproved new drug. (B)</p>
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What is the primary focus of FDA inspections, as highlighted in the presentation?

<p>Assessing compliance with Current Good Manufacturing Practices (CGMPs). (D)</p>
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What is generally the first step the FDA takes when conducting an inspection?

<p>Presenting FDA-482 form and credentials. (D)</p>
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Besides sterility, what is another major concern during FDA sterile drug inspections?

<p>Pyrogens (including bioburden). (D)</p>
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During a facility tour, what subtle aspects do FDA inspectors pay attention to?

<p>Air flow and traffic patterns. (B)</p>
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What types of documentation are manufacturers required to maintain and investigate, according to the presentation?

<p>Complaints, deviations, and failures (OOS). (D)</p>
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When reviewing trended data, which of the following areas is commonly assessed by the FDA?

<p>Environmental monitoring for surfaces and air. (A)</p>
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What is the focus of the 'Facilities and Equipment' aspect of 'General Coverage' during FDA sterile drug inspections?

<p>Cleaning and disinfection procedures and contamination prevention. (B)</p>
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Which of the following pieces of equipment is commonly inspected during FDA sterile drug inspections?

<p>Container/closure washing and depyrogenation equipment. (C)</p>
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What is a critical factor evaluated during the 'production' portion of a sterile drug inspection?

<p>Master batch record approval and issuance. (C)</p>
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During observations, what is assessed by FDA inspectors?

<p>Manufacturing environment (cleanliness, equipment appropriateness, building controls). (D)</p>
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What type of records are typically reviewed during an FDA inspection?

<p>What was done (production, testing, investigations, calibrations). (A)</p>
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Who directs the inspection process during an FDA sterile drug inspection?

<p>The investigator from the FDA. (C)</p>
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Why must justifications be supported by evidence?

<p>Because the inability to justify how things are done is a CGMP violation. (A)</p>
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What type of data must support the validation of moist heat sterilization?

<p>Data must support validation parameters (e.g., Biological Indicator challenges). (D)</p>
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For processes like filter sterilization and aseptic filling, what is required?

<p>Such proof is required in many arenas. (A)</p>
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What is a key criterion for significant violations listed on an FDA-483 form?

<p>They must be pursuant to CGMP requirements. (C)</p>
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What is a potential outcome after an FDA inspection where significant violations are found?

<p>Significant enough violations are found that the FDA needs to do more to protect the public health. (C)</p>
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What might the FDA do if they find significant violations during an inspection?

<p>Preventing future approvals, government contracts, and export certificates. (A)</p>
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What is the purpose of an FDA sterile drug inspection?

<p>To assess a company's compliance with regulations and standards. (C)</p>
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What is one of the reasons the FDA would need to visit a manufacturing location?

<p>To address complaints and follow up on recalls. (C)</p>
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Which route of administration is considered part of injectable dosage?

<p>Intrathecal (A)</p>
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A critical aspect of aseptic filling is:

<p>All of the above (D)</p>
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One variety of dosage includes:

<p>PET/Radioactive (D)</p>
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Why do FDA inspections focus on "CGMPs"?

<p>Because violating CGMPs causes the drug to be legally adulterated (C)</p>
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During what process do inspectors look for critical control points?

<p>Tour (C)</p>
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What is one of the lists required during a problems and trends review?

<p>All of the above (D)</p>
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What might cause a failure during the problems and trends review process?

<p>Both A and B (C)</p>
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What factor is reviewed as a part of the water system?

<p>All of the above (D)</p>
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What is one of the five systems the FDA focuses on?

<p>All of the above (D)</p>
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What is considered in materials during general coverage by the FDA?

<p>All of the above (D)</p>
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What is the first step to produce?

<p>Master batch record approval and issuance (B)</p>
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When packaging and labeling, what steps are important to review?

<p>All of the above (D)</p>
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During laboratory coverage, what aspect should be reviewed?

<p>All of the above (D)</p>
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During interviews, the FDA wants to speak with whom?

<p>All of the above (D)</p>
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Considering the FDA's focus during sterile drug inspections, which of the following scenarios would MOST likely lead to a drug being deemed illegal under the Federal Food, Drug, and Cosmetic (FD&C) Act?

<p>A drug product is found to be misbranded due to inaccurate labeling that does not reflect potential side-effects. (C)</p>
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During an FDA inspection of a sterile drug manufacturing facility, the inspectors notice an accumulation of dust on the surfaces of equipment used in the production area. While this observation alone may not be conclusive, what broader concern related to CGMP could this indicate?

<p>The facility's air handling system might be improperly maintained, leading to inadequate control of airborne particulates. (B)</p>
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Aseptic processing requires multiple controls to ensure product sterility. How do environmental controls contribute to assuring sterility during aseptic processing:

<p>By continuously removing microorganisms from the air and surfaces within the aseptic processing area. (C)</p>
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Aseptic technique and cleanroom behavior are critical in sterile pharmaceutical manufacturing. Considering this, which activity would be of GREATEST concern to an FDA inspector during a facility tour?

<p>Operators occasionally leaning against equipment within the aseptic processing area during long production runs. (C)</p>
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To adhere to CGMP regulations, manufacturers must justify their processes and procedures. What action would BEST demonstrate a company's commitment to validating a moist heat sterilization?

<p>Maintaining comprehensive records documenting the biological indicator challenges and temperature mapping studies. (D)</p>
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Which of the following scenarios relating to aseptic processing would raise the MOST significant concern during an FDA sterile drug inspection, potentially leading to an FDA-483 observation?

<p>Personnel occasionally adjusting sleeves of their cleanroom suits during a filling operation. (B)</p>
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Why might an FDA investigator choose to examine a firm's historical data related to filter sterilization validation during a sterile drug inspection?

<p>To assess whether the firm has consistently justified and proven the effectiveness of its filter sterilization processes across different products, formulations, and conditions. (D)</p>
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A manufacturing firm is developing a novel sterile drug product using a blow-fill-seal process. What documentation would be MOST critical to have readily available during an FDA inspection to demonstrate adequate process control and CGMP compliance?

<p>Validation data demonstrating the consistent sterility and integrity of the containers produced by the blow-fill-seal equipment under various operational conditions. (C)</p>
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During which phase of an FDA sterile drug inspection would an investigator MOST likely scrutinize the calibration records of temperature probes used in autoclaves for moist heat sterilization?

<p>During the review of records related to equipment qualifications and process validation, to ensure data accuracy and reliability. (D)</p>
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How does the FDA use trended data related to personnel monitoring in sterile manufacturing facilities to assess compliance with Current Good Manufacturing Practice (CGMP) regulations?

<p>To track individual aseptic technique deviations by personnel over time, identifying patterns that may indicate training deficiencies or procedural inadequacies. (D)</p>
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A sterile drug manufacturing facility has received an FDA-483 observation citing inadequate justification for the cleaning and disinfection procedures in its ISO 5 aseptic filling area. Which remediation strategy would MOST comprehensively address the FDA's concern?

<p>Implementing a formal, documented cleaning validation program that demonstrates the consistent removal of residues and contaminants, along with routine monitoring to ensure ongoing effectiveness. (B)</p>
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Given that packaging and labeling issues account for a significant percentage of drug recalls, what proactive measure would be deemed MOST effective during an FDA sterile drug inspection to mitigate risks in this area?

<p>Implementing a robust label reconciliation process that includes secure storage, strict issuance controls, and thorough monitoring to prevent mix-ups or mislabeling throughout the production process. (A)</p>
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During an FDA inspection of a sterile drug manufacturing facility, the investigator identifies a pattern of unexplained deviations in batch records that were not thoroughly investigated. What is the MOST likely consequence of this finding regarding CGMP compliance?

<p>The FDA may issue a warning letter citing violations of CGMP regulations related to inadequate investigation of discrepancies and a failure to ensure product quality and safety. (C)</p>
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In an FDA sterile drug inspection, what is the primary importance of reviewing the 'state of affairs' within a manufacturing facility, specifically environmental monitoring and complaint trending?

<p>To evaluate if the manufacturer is aware of ongoing environmental issues, such as water system contamination, and to verify that appropriate corrective actions are being implemented effectively. (C)</p>
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An FDA investigator, while reviewing quality control laboratory records, discovers that certain reference standards used in drug product testing have not been properly qualified according to USP guidelines. What is the MOST immediate concern?

<p>The validity and reliability of all drug product testing results generated using those reference standards are now questionable, potentially impacting product quality and patient safety. (C)</p>
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An FDA investigator observes an operator in an aseptic filling suite repeatedly making adjustments to a piece of equipment without following proper procedures. What is the PRIMARY concern?

<p>The investigator is concerned that the batch of product being filled is at high risk of contamination compromising the sterility and safety of the product. (C)</p>
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During a tour of a sterile drug manufacturing facility, an FDA inspector notices that the facility's diagram does not accurately reflect the current layout of the production area. How could this discrepancy MOST significantly affect the inspection?

<p>Leads the FDA inspector to question the overall accuracy and reliability of the facility's documentation and change-control processes. (B)</p>
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A sterile drug product manufacturer uses contract testing laboratories for endotoxin testing of raw materials. What aspect of this arrangement would the FDA likely scrutinize MOST closely during an inspection?

<p>Whether the manufacturer has adequately qualified and oversees the contract testing laboratory, ensuring the reliability and integrity of the testing data. (D)</p>
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A sterile drug manufacturing company has implemented a new computerized system for monitoring environmental conditions in its cleanrooms. During an FDA inspection, what evidence would be MOST persuasive in demonstrating the system's reliability?

<p>A validation report showing that the system accurately collects, stores, and reports environmental data, and that access controls are in place to prevent unauthorized modifications. (C)</p>
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During an inspection of a sterile drug manufacturing facility, the investigator requests to speak with both high-level management and line operators. What is the purpose of these interviews?

<p>To determine if the line operators' understanding of procedures aligns with the procedures that management has in place. (D)</p>
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What is the MOST critical reason for an FDA investigator to meticulously document and photograph observations during a sterile drug inspection?

<p>To have clear and irrefutable evidence of violations or deficiencies that can support regulatory actions, such as warning letters or recalls. (B)</p>
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The FDA observes that a sterile drug manufacturer is using single-use disposable filters for product sterilization. What aspect is MOST critical for FDA inspectors to verify?

<p>Filter integrity is verified before use, as well as the filters meet product specifications and are properly qualified for their intended use. (D)</p>
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A company is preparing for an FDA inspection. They have identified several deviations related to temperature excursions during the storage of a temperature-sensitive drug. Considering FDA's focus on thorough investigations, what approach would be MOST effective?

<p>Present a comprehensive investigation report that includes a root cause analysis, identifies the impact on product quality, and details the corrective and preventative actions implemented to prevent recurrence. (D)</p>
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During an FDA inspection, an investigator discovers that several pieces of equipment used in the production of a sterile drug product have not been properly maintained or calibrated. What is the MOST likely outcome?

<p>The FDA may issue a warning letter, place the company on import alert, or take other regulatory actions to ensure that the company takes appropriate steps to correct the deficiencies. (B)</p>
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The FDA's primary goal in conducting sterile drug inspections is to ascertain whether a manufacturing facility:

<p>Strictly adheres to Current Good Manufacturing Practice (CGMP) regulations to safeguard the integrity, safety, and quality of sterile drug products. (A)</p>
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During a tour of a sterile drug manufacturing facility, an FDA inspector observes multiple instances of operators touching surfaces and then immediately manipulating sterile equipment without proper sanitization. What interpretation should be made?

<p>The operators may be unaware of proper aseptic techniques and that there is a heightened that product being processed is at risk of contamination and a CGMP violation. (A)</p>
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In the context of FDA sterile drug inspections, what does the term "Prove It!" MOST directly emphasize for pharmaceutical manufacturers?

<p>The firm's responsibility to provide scientific evidence and documented data to substantiate why things are done the way they are and demonstrate that processes consistently yield safe and effective products. (A)</p>
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Why is the review of batch records a pivotal component of an FDA sterile drug inspection?

<p>To assess whether the manufacturing process was conducted according to approved procedures, with all critical steps properly documented and deviations thoroughly investigated, thus ensuring product quality and consistency. (D)</p>
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A sterile drug manufacturer is planning to implement a new rapid microbial method for in-process bioburden testing. During an FDA inspection, what evidence would be MOST compelling to demonstrate the suitability of this method?

<p>A detailed comparison study demonstrating equivalency to compendial methods (e.g., USP), along with data showing its accuracy, precision, and robustness under routine operating conditions. (C)</p>
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An FDA inspector is reviewing the water system validation data for a sterile drug manufacturing facility. What area of control would be MOST concerning if found lacking or inconsistent?

<p>A validation report documenting the consistent production of water that meets USP specifications for purity and endotoxin levels, along with a robust monitoring program. (D)</p>
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Aseptic processing requires multiple controls that will ensure product sterility. How do environmental controls help in assuring sterility during aseptic processing?

<p>By maintaining the room in an ISO 5 or better status. (D)</p>
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During a facility tour, FDA inspectors will look for:

<p>Look for subtle items such as air flow. (D)</p>
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In trended environmental monitoring, which is reviewed by the FDA?

<p>Surface and air. (B)</p>
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What items are common to inspect by the FDA?

<p>Container and Closure washing. (B)</p>
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For significant violations listed on an FDA-483 during inspections, what must the violations follow?

<p>CGMP requirements. (C)</p>
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What are some options presented by the FDA after an inspection?

<p>Regulatory Meeting. (C)</p>
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An FDA sterile drug inspection will review

<p>Laboratory Analysis. (A)</p>
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During an FDA inspection, what would an investigator expect when reviewing a company's validation data for a moist heat sterilization cycle, especially regarding the data's integrity?

<p>Evidence that controls were in place to assure that the collected data had protections and could be traced back for review. (C)</p>
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If a sterile drug product manufacturer is performing filter sterilization, aseptic filling, stoppering/capping, packaging, and labeling, what must they provide?

<p>A detailed accounting for their proof. (D)</p>
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If an FDA inspection finds significant violations of CGMP related to sterile manufacturing, which immediate action might the FDA take to protect consumers?

<p>Issue a press release warning consumers. (D)</p>
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During an FDA inspection, what implication does an inadequately justified process have on CGMP compliance?

<p>It is a direct violation of CGMP regulations. (A)</p>
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Aseptic processing is a critical area during sterile drug inspections. Suppose a company uses an isolator for aseptic filling. Which finding would be MOST concerning to an FDA inspector?

<p>There is a lack of validated procedures for cleaning and disinfecting the isolator chamber. (C)</p>
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A sterile drug product requires a validated moist heat sterilization cycle. If a sterilizer load is insufficiently heated due to a loading error, what action must be taken?

<p>Provide proper justification for repeating the cycle. (C)</p>
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A company manufactures an ophthalmic solution using aseptic processing. The company validation data shows multiple batches that failed sterility testing, but were reprocessed, passed sterility, then released as good product. Based on this scenario, what is the MOST likely enforcement action the FDA might take?

<p>The FDA may move towards severe options that involve federal court such as seizure of products. (A)</p>
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During an FDA inspection of a sterile drug manufacturing facility, an investigator notes that trended data from environmental monitoring consistently shows higher microbial counts in certain locations within the cleanroom. The manufacturing facility claims that this is most likely due to lab error and should not be investigated. According to CGMP regulations, which course of action by the investigator should be taken?

<p>Classify this as a critical observation, and demand a thorough investigation and CAPA plan. (B)</p>
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Flashcards

Purpose of an FDA sterile drug inspection?

To verify a drug manufacturer is following Current Good Manufacturing Practices (CGMPs) and that their processes ensure drug sterility and quality.

Reasons for an FDA visit.

If there are signals that a manufacturer might not be adhering to quality standards, there has been a recall, or as part of routine surveillance.

FDA sterile drug inspection purpose

An FDA sterile drug inspection aims to assess a manufacturer's compliance with Current Good Manufacturing Practices (CGMPs) to ensure the sterility and quality of drug products.

Reasons for FDA Location Visit

The FDA might visit a manufacturing location due to signals of non-adherence to quality standards, following a recall, or for routine surveillance.

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FDA sterile drug inspection objective?

To assess compliance with Current Good Manufacturing Practices (CGMPs) and ensure sterility and quality of drug products.

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Triggers for FDA location visits?

To investigate possible issues, following recalls, or for routine monitoring of manufacturing operations.

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Study Notes

Objectives of FDA Sterile Drug Inspections

  • To understand the purpose of FDA sterile drug inspections
  • To learn the reasons the FDA might visit a location

Purpose

  • To find ways drugs can be illegal under the Food, Drug, and Cosmetic Act (FD&C Act)
  • A drug can be illegal if it is adulterated, misbranded, or an unapproved new drug
  • Inspections focus on Current Good Manufacturing Practices (CGMPs)
  • CGMPs include preventative controls for production and testing
  • Drugs can be legally adulterated by violating CGMPs

Reasons for FDA Visits

  • FDA-482 and credentials verification
  • Compliance Program adherence assessment
  • Follow-up on previous inspections, complaints, recalls, or Warning Letters
  • Special assignments
  • To collect samples, including environmental samples
  • FDA-483 issuance if violations are observed

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