Sunday, 28 July 2013

Difference Between FDA 483 & Warning Letter

FDA 483’s VS Warning Letter
Form 483 and Warning Letter’s are two serious documents issued by USFDA which are very different in regulatory and legal prospective. “FDA 483 lists observations made by the FDA representative during the inspection of a facility. They are inspectional observations, and do not represent a final Agency determination regarding firms compliance.” The FDA-483 can be amended after an inspection by the investigator who issued it and re-issued.
The Warning Letter is a document that usually originates from the FDA-483 observations that have been linked to citations by one or more legal reviews within the Compliance and legal branch of the FDA. A Warning Letter is informal and advisory. It communicates the agency's position on a matter, but it does not commit FDA to taking enforcement action. For these reasons, FDA does not consider Warning Letters to be final agency action on which it can be sued. The Warning Letter is issued by the agency and not the investigator.

FDA 483’s
Warning Letter
The Form 483 is issued for inspectional observations. It lists the alleged deficiencies or issues of non-compliance in the manufacturer’s quality system.
Warning letters are issued for violations of “regulatory significance”
(Significant violations are those violations that may lead to enforcement action if not promptly and adequately corrected).
The Form 483 is issued by the inspection team alone.
The warning letter is issued from a higher level FDA official or officials.
Bad inspections lead to Form 483s.
Warning letters usually result from multiple lacking responses to issued 483s, or other issues much more serious that require quick attention/escalation.