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ContentsSUBCHAPTER 590 - REPORTING590 - ESTABLISHMENT INSPECTION REPORT (EIR) 591 - ENDORSEMENT 591.01 - Compliance Achievement Reporting System (CARS) 592 - FACTS ESTABLISHMENT INSPECTION RECORD (EI Record) 593 - NARRATIVE REPORT 593.01 - Non-Violative Establishments 593.02 - Violative Establishments 593.03 - Individual Narrative Headings 594 - EXHIBITS 594.01 - Electronic information 595 - ADDENDUM TO EIR SUBCHAPTER 590 - REPORTING590 - ESTABLISHMENT INSPECTION REPORT (EIR)See IOM 100 English language requirement. The EIR consists of the following in this order: a printed copy of the FACTS Establishment Inspection Record (EI Record) including, at least, the endorsement with the EIR distribution printed at the bottom of the "endorsement" section of the EI Record; carbon or other copies of FDA forms issued during the inspection such as the FDA 482, FDA 483, and FDA 484; investigator's narrative report; copy of assignment if available; exhibits; and/or any additional material attached and referred to in the narrative report. Regarding the use of checklists (such as the BSE Checklist), the original raw data completed checklist should be submitted with the EIR. If you maintain the data in your diary, rather than entering directly on the form, then enter on the electronic copy. A printed copy from FACTS becomes the data to include with the EIR. No copies of inspection reports will be maintained other than in headquarters, district, and resident post files. The signed original report is maintained in the district office or in the case of foreign inspections in the appropriate Center HQ office. 591 - ENDORSEMENTThe endorsement of the establishment inspection is prepared by the supervisor. Some supervisors may have the investigator prepare proposed endorsements. Endorsements should fit in the available space provided in FACTS. If the endorsement exceeds the 2000 character space provided in FACTS, a separate endorsement should be prepared, fully identifying the firm with a Summary of the Endorsement included in FACTS. The FACTS EI Record will be printed and used as the endorsement and routing document to accompany the EIR. See also IOM 593.01. Normally the endorsement consists of:
The Compliance Status Information System (COMSTAT) was a separate Agency database summarizing Quality Systems regulation (QS/GMP) and current Good Manufacturing Practices (cGMP) regulations for facilities, which manipulate drug, device, and biological products. QS or GMP status of firms inspected is now entered into the FACTS database. The Profile Data is submitted electronically to the Division of Compliance Information and Quality Assurance (DCIQA), HFC-240, following an inspection. DCIQA should be notified via hardcopy, e-mail or FAX as soon as an inspection reveals a violative QS or GMP situation, which may result in regulatory action. Often this may occur before the inspection has concluded. See Exhibit 590-C. The COMSTAT Guidance to Field and Centers document replaced Chapter 15 of the GWQAP Manual and can be accessed from the DCIQA web site at http://web.ora.fda.gov. 591.01 - Compliance Achievement Reporting System (CARS)FACTS is used to report achieved and verified compliance actions, which are not the result of a legal action. A compliance achievement is the observed repair, modification, or adjustment of a violative condition, or the repair, modification, adjustment, relabeling, or destruction of a violative product when either the product or condition does not comply with the Acts enforced by the FDA. There are three criteria for reporting into the CARS system:
Only when the corrective action(s) has been verified should a CARS be reported. The data elements are those entered/coded in FACTS (See IOM Exhibit 590-B):
592 - FACTS ESTABLISHMENT INSPECTION RECORD (EI Record)Instructions for completion of the FACTS (Field Activities and Compliance Tracking System) EI Record will be included in future revisions. Until such time consult with your supervisor and District Lead FACTS user(s). See IOM Exhibits 590-A & 590-B. The FACTS Profile Data instructions and FACTS generated assignment are attached as IOM Exhibits 590-C & 590-D. Inspectional accountable time in FACTS consists of the hours devoted to file reviews (operational preparation), actual inspectional, investigational, audit, etc. time (onsite), document (exhibit) preparation and EIR (report) write-up. Accountable time does not include travel time. One occasional exception could be when more than one participant in an inspection/investigation travel together and discuss/prepare while in route. Other accountable time operations are listed in the FDA Data Codes Manual. 593 - NARRATIVE REPORTSee IOM 100 English language requirement. The narrative report is the written portion of the EIR, which accurately describes the investigator's inspectional findings. The narrative report may be prepared in two formats depending on the type of inspection, inspection classification, and program area. A Summary of Findings narrative report is used for non-violative, non-initial inspections - see IOM 593.01. The Standard narrative report is used for human pharmaceutical and medical device inspections, and Official Action Indicated (OAI) classified inspections in other program areas - see IOM 593.03. The "Summary of Findings" report format may be used for some Voluntary Action Indicated (VAI) classified inspections as directed by your supervisor. Additional requirements for human drug and medical device reports are described in IOM 549 and 559. For all reporting formats, include additional information as directed by your assignment, Compliance Program Guidance Manual, or your Supervisor. All reports must be prepared as stand-alone documents outside of FACTS. Your Establishment Inspection Report (EIR) must:
593.01 - Non-Violative EstablishmentsInvestigators should use "Summary of Findings", stand-alone, narrative reports for non-violative establishments, unless otherwise directed by your supervisor, the assignment or the Compliance Program Guidance Manual involved. Exception: human pharmaceutical and medical device GMP inspection reports, which have additional reporting requirements should be written in the Standard Narrative report format as in 593.03. The Summary of Findings Report may not be written solely in the FACTS provided "Inspection Summary" heading. The Summary of Findings report must include:
593.02 - Violative EstablishmentsAll violative EIR's must in addition to the information required for non-violative reports contain the following:
593.03 - Individual Narrative HeadingsThere are many acceptable ways
of organizing a narrative report. The key is to cover the required
information in IOM
593and 593.02,
or as required by the assignment, Compliance Program Guidance Manual, or
your supervisor.
The appropriate use of headings
should not result in repetition of the same information in different
sections. You are encouraged to create headings as necessary to present
the inspectional findings in the most concise manner.
For non-violative and some VAI
reports, a single heading such as "Summary of Findings" is sufficient
(for exceptions, see IOM
593.01)
Turbo EIR must be used to generate
the FDA 483 and write the EIR for any inspection where all applicable
cite modules exist. You cannot write the EIR in Turbo if the FDA 483
was issued to the firm and it was NOT generated using Turbo EIR. NOTE:
Turbo EIR can be used to write the EIR for any inspection where no
FDA 483 was issued.
STANDARD NARRATIVE REPORT: HEADINGS,
CONTENT AND ARRANGEMENT OF YOUR REPORT
The Standard narrative report
format is the format used for most reports in all program areas. The
Standard narrative format contains sections within specific headings.
Reporting requirements under these headings fall into two categories:
those which must be reported every time (if applicable) and those which
only need to be reported if an element has changed (example: Jurisdiction
- "changes in the current catalog of products"). You should follow
the Standard narrative reporting guidance for specific program areas
in the situations below noting any exceptions or additional information
which may be required.
Initial or OAI classified inspections:
A full standard narrative report is required for all program areas.
Note : All human
drug inspections require full narrative reporting regardless of classification.While
a complete Standard Narrative is required,
this format
does not require full and detailed narratives for every area/element for
every human drug inspection. The firm's state of compliance, the previous
inspectional report and information, complexity of operations and other
aspects all are determinants in how much reporting will be necessary. In
many cases, brief summaries addressing the format areas will be sufficient.
Other additional reporting for
human drug and medical device inspections may be required - see IOM
549 and 559.
Reporting of "changes only" is
permitted for:
Non-initial, NAI classified inspections
- Medical Device inspections
Non-initial, VAI classified inspections
- Biologics, Bioresearch Monitoring, BSE, Cosmetics, Food, Medical
Device, Medicated Feeds, and Veterinary Drug inspections HEADINGS: Summary
Persons Interviewed and
Administrative Data
Report Full Names and
Titles of:
History
Interstate (I.S.) Commerce
Jurisdiction (Products Manufactured and/or Distributed)
Individual Responsibility -
Report with whom you dealt, and in what regard (both during and prior
to the start of the inspection):
who provided relevant information,
who accompanied you during
the inspection,
who refused access to required
records or any other refusal of information (Note: a separate
heading for Refusals may be needed if refusals are significant,
extensive or an Inspection Warrant is anticipated),
who refused to permit inspection
(IOM
514) and
who participated in the discussion
with management (IOM
516)
Describe roles and authorities of responsible individuals, including the full names and titles of individuals providing you with information.
Firm's Training Program -
The firm's training programs are of particular significance where
inspectional findings find people may not be adequately trained.
Manufacturing/Design Operations
Manufacturing Codes
Complaints (if applicable) - Note: The complaints included in this portion of the EIR are those reported to the FDA by consumers, health care professionals, industry, etc. - Not necessarily the complaints received by the firm.
Recall Procedures - Describe plans and procedures for removing products from marketing channels if necessary. Objectionable Conditions and Management's Response (those written and provided to management at the conclusion of the inspection)
NOTE: Observations of a verbal nature should be reported in sufficient detail under the General Discussion with Management (correlate any Exhibits, samples, etc. to any "verbal" observations). Refusals - Provide full details of all refusals of/for requested information, statutory information, photography, entry, etc. received during the inspection, including who made the refusal and, if available, why the refusal was given. General Discussion with Management
Additional Information - Report changes only.
Voluntary Corrections
Exhibits and Samples Collected - List all exhibits attached. See IOM 594, Exhibits.
NOTE: For complex inspections a cross-reference from the FDA 483 and verbal observations to applicable exhibits and samples can be useful during further review. Attachments - Attachments as referred to here are any material attached to and referred to in the EIR, which are not evidentiary in nature; such as assignments, Center provided protocols, etc. See IOM 527.02 for identification of non-evidentiary material attached to the EIR. Documents attached to the EIR may be referred to in the EIR and listed here, such as the FDA 482, FDA 483, copy of the FDA 463a, etc. (in form number order); but such documents/forms must not be numbered, altered from their issued state, bear adhesive identification labels, etc. See the opening sentence of IOM 594. List and attach copies of associated reports (Recall Attachment B Report, etc.). Signature - All participants must sign the final narrative portion of the EIR. The prescribed format is to type each persons name, title, and district (or other affiliation) below the signature. In some cases immediate signature by all participants is not possible. An example as to how this can be accomplished is to forward an electronic "draft" copy of the EIR for all to read and approve, then followed or accompanied by the original signature sheet. When signed, return to the lead investigator for proper filing and routing. When using this method, a photocopy of the original signature page is made with the lead investigator's signature and temporarily attached to the EIR. 594 - EXHIBITSExhibits are materials collected from the firm and do not include FDA forms or copies of assignments. Exhibits should contribute to the objective of the assignment and the clarity of the report. They may include flow-plans, schematics, layouts, etc. If the materials collected from the firm are not needed as exhibits, they should be destroyed in accordance with district policy. Submit four copies of new or suspect labeling or other material collected as exhibits for labeling purposes. These should be mounted in a manner so complete sets are submitted, i.e., labels 1-10 in each of three sets. Identify records, labeling and documents with at least the Exhibits' number, date of EI and your initials. See IOM 527.02. 594.01 - Electronic informationElectronic information, databases or summary data from databases may be obtained from firms and evaluated during the course of an EI. This data may form the basis for observations or information included in the EIR. It is preferable to include a printed version and/or a summary of the data as an exhibit. When it is included as an exhibit to the EIR, it should be stored so as to protect the integrity of the data. See IOM 527.03 for procedures for collecting and identifying electronic data. Electronic media should be protected from extreme temperatures and most magnetic fields. Additional precautions may be necessary and you should be guided by your district procedures for storage of electronic data. 595 - ADDENDUM TO EIRIf your EIR requires correcting or clarification after it has been finalized, signed and distributed, you should prepare an addendum, with your supervisor's approval. The addendum should clearly identify itself with the EIR being added to, explain the necessity for the addendum, and clearly define what section(s) and page(s) are being revised. The addendum must be signed by the preparer.
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