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EIR (Establishment Inspection Report) issued from FDA

  • 1.  EIR (Establishment Inspection Report) issued from FDA

    Posted 22-Nov-2013 01:11

    I am wondering whether EIR has same effect with GMP certificate.
    As far as I know, EIR is a kind of inspection report which issed by inspector to inform deficiencies in facility to manufacturer. Unless manufacturer correct the deficiencies, I guess EIR cannot be used as GMP certificate.
    Furthermore, does EIR has a kind of expiry date?

    -------------------------------------------
    NaRi Jung
    RA country manager
    Korea, Republic of
    -------------------------------------------


  • 2.  RE:EIR (Establishment Inspection Report) issued from FDA

    Posted 23-Nov-2013 03:45
    Hi NaRi Jung,

    Upon completion of FDA Inspection, if there are any deficiencies, then FDA will issue FDA Form 483 (Inspectional Observations) to the Manufacturer.

    Then the FDA Investigator will send the report to the District Office. If US Domestic facility, the corresponding FDA District Office will send the EIR to the manufacturer; if Foreign Manufacturing Site, the Centre (CBER/CDRH,etc..) will send the EIR to the Manufacturer.

    EIR will result into three actions:
    - No Action Indicated (Site is in Compliance) (NAI)
    - Voluntary Action Indicated (VAI)
    - Official ACtion Indicated (OAI)

    If the manufacturers receive the FDA Form 483, then they will send the 483 response to FDA within 30 days.
    If FDA is not satisfied with the response, then it may issue a Warning Letter to the Manufacturers.

    EIR is not equivalent to a GMP Certificate; it's a report only, not certificate, with no expiration date.

    Regards,
    Sreenu
    -------------------------------------------
    Sattu Sreenu Babu
    Manager-Regulatory Affairs - SEA Region
    Life Technologies
    Singapore
    -------------------------------------------








  • 3.  RE:EIR (Establishment Inspection Report) issued from FDA

    Posted 24-Nov-2013 01:45
    Hi

    FDA upon inspection of facility issues 483s if there are observations (normally this will be issued during the inspection or immediately after). Either after resolution of 483s or if there are no 483s CDER/CBER issues Establishment Inspection Report to the inspected entity.

    Usually EIR will be site specific, where, if the 483s are addressed, FDA will classify the facility as acceptable. For many other countries, this serves as GMP certificate. There is no stipulated expiry, but normally this will be considered valid by regulators for three years.

    Regards,
    Shrivathsa




  • 4.  RE:EIR (Establishment Inspection Report) issued from FDA

    Posted 25-Nov-2013 08:38
    When asked for a cGMP certificate I always get a Certificate to Foreign Government from the FDA.  On the first page of this document it states the following,

     "The manufacturing plant(s) in which the product(s) is producted is subject to periodic inspections.  The last such inspection showed that the plant(s), at that time, appeared to be in substantial compliance with current good manufacturing practice requirements for the product(s) listed above."

    Most foreign governments understand that the USA does not issue cGMP certificate and accept this.

    -------------------------------------------
    Sheila Grant
    Regulatory Affairs Associate
    Sultan Healthcare
    Hackensack NJ
    United States
    -------------------------------------------








  • 5.  RE:EIR (Establishment Inspection Report) issued from FDA

    Posted 25-Nov-2013 11:59
    A Form 483 Inspectional Observations (commonly referred to as a 483) is issued only by the investigators/inspectors who performed the inspection, and only at the close of an inspection.  It lists any objectionable observations, i.e., GMP deficiencies, noted during the inspection.  If no GMP deficiencies were noted, no 483 is issued.  This is a delightful outcome of an inspection, but is uncommon.

    Responses to 483s are not required, but it would be foolish not to respond.  The response provides the company's perspective and explanation of anything the investigators listed on the 483.  Responses must be submitted to FDA within 15 days, not 30 days. 

    An Establishment Inspection Report (EIR) is written by the investigators/inspectors to document everything they saw and all discussions that occurred during the inspection.  Usually these are completed within a month after the inspection, but not always.  If a 483 was issued, the EIR will provide detailed discussions of the observations and will include documentation collected during the inspection that support the observations.  These can become the basis for additional regulatory action, if required. 

    The EIR will report on the entire scope of the inspection.  This can include a single product on a multi-product site, an entire site and all products manufactured there, several sites of a specified company, a particular building (e.g., a new warehouse or QC facility) or whatever the purpose of the inspection was.  EIRs relate only to a single inspection, and have no relevance to other sites, facilities or products of the company if those were not covered during the inspection.  It is simply a report that describes FDA's perspective on that particular inspection.

    If no 483 was issued, an EIR must still be written by the inspectors/investigators to document the scope and findings of the inspection.

    FDA does not issue GMP certificates.  An EIR is simply a report describing what happened during a single inspection, and therefore has no 'expiration date' or period of validity.  An EIR is not a GMP certificate, and has no similarity to a GMP certificate. 

    Regards,
    Kirsten

    -------------------------------------------
    Kirsten L. Vadheim PhD, RAC
    Principal
    BioCompliance Consulting, Inc.
    Redmond WA
    United States
    -------------------------------------------








  • 6.  RE: EIR (Establishment Inspection Report) issued from FDA

    Posted 15-Oct-2015 17:21


    Also, would anyone know if it's customary to do an e-Copy for one's response to an EIR and/or Warning Letter?

    Thank you! 

    ------------------------------
    Justin Osmond
    Ottawa ON
    Canada



  • 7.  RE: EIR (Establishment Inspection Report) issued from FDA

    Posted 17-Oct-2015 12:08


    Justin,

    For foreign inspections, FDA has been moving towards allowing firms to respond to the Form FDA 483 via an e-Copy.  Specifically, ask your Investigator about the informal FDA memo entitled "Optional Method for Submission of Your Timely Response to the FDA 483", which provides for submission of your response via email.  I was given this option recently when helping resolve a 483 for one of my foreign clients.

    Hope this helps.

    Best regards,

    Kevin Randall, ASQ CQA, RAC (U.S., Canada, Europe)

    Principal Consultant

    ComplianceAcuity, Inc.

    ------------------------------
    Kevin Randall RAC
    Principal Consultant
    ComplianceAcuity, Inc.
    Golden CO
    United States



  • 8.  RE:EIR (Establishment Inspection Report) issued from FDA

    Posted 23-Nov-2013 09:01
    The EIR is the closest thing to a GMP certificate issued by FDA.  FDA always issues an EIR after an inspection, whether deficiencies are identified or not.  It's the 483 form that identifies deficiencies that must be corrected.  See page 3 of this FDA Field Management Directive for inspection outcome classifications:

    http://www.fda.gov/downloads/ICECI/Inspections/FieldManagementDirectives/UCM289084.pdf

    I can speak only to inspections for compliance with the FDA's Quality System Regulation (QSR), which applies only to medical devices.  The relationship between the EIR and a GMP certificate (eg, an ISO 13485 certificate) often arises when registering a medical device in a jurisdiction that offers an abbreviated registration track for products that are already marketed in another jurisdiction.  Usually these regulatory agencies have identified a list of other agencies that it accepts as "reference agencies," which is to say that your product qualifies for the abbreviated process if it has been approved by one or more of the reference agencies.  They usually require a copy of the approval letter and also a GMP certificate applicable within that jurisdiction.  The FDA and EU notified bodies are probably the most common reference agencies.

    The FDA process is not a perfect fit for this approach, since it does not issue "approval" letters for 510(k) devices and it does not issue GMP certificates, nor does it accept (so far?) ISO 13485 certification as evidence of QSR compliance.  This can require a bit of back-and-forth with the ex-US agency to explain the US scheme and what the EIR (and clearance letter) mean under that scheme, but generally the ex-US agencies that recognize the FDA as a reference agency are knowledgeable about the FDA process, so, unless you get a newbie reviewer, or an agency that has adopted this approach fairly recently, an EIR with No Action Indicated will be accepted as the FDA's "GMP certificate" for the purposes of abbreviated registration.


    -------------------------------------------
    Julie Omohundro RAC
    RAQA Services
    Research Triangle Park NC
    United States
    -------------------------------------------








  • 9.  RE:EIR (Establishment Inspection Report) issued from FDA

    Posted 23-Nov-2013 09:33
    There really is no such thing as a "GMP Certificate." Most manufactures simply assert that the business is compliant with GMP standards and regulations. There are third party companies that will certify you as compliant with the certifying bodies standard, but nothing you get from the FDA can be used to show certification-at least as it relates to cGMP. ------------------------------------------- Richard Massey Regulatory Affairs Manager Snugzusa, Inc. Salt Lake City UT United States -------------------------------------------


  • 10.  RE:EIR (Establishment Inspection Report) issued from FDA

    Posted 24-Nov-2013 09:33
    Sorry, I overlooked your question about an expiry date for an EIR.

    No, the EIR does not have an expiry date.  FDA is "required" to inspect drug and device manufacturing facilities every two years, but I can't recall a time it succeeded in maintaining schedule.  I would ask for "the most recent" EIR and, if it is more than 3 years old, I would check the FDA inspections database for a more recent inspection, keeping in mind that it can take a while for FDA to issue the EIR after the inspection.  If pressed by an ex-US agency regarding a dated EIR, you can also use the FDA database to document that the EIR is a report of the most current FDA inspection.

    Also keep in mind that, if your US manufacturer opens  a new facility, it can be several years before the FDA comes to inspect it, and during that period, you can't use the FDA as the reference agency to expedite registration of products manufactured in the new facility, because you won't have an EIR for the new to serve as its "GMP certificate."


    -------------------------------------------
    Julie Omohundro RAC
    RAQA Services
    Research Triangle Park NC
    United States
    -------------------------------------------








  • 11.  RE:EIR (Establishment Inspection Report) issued from FDA

    Posted 25-Nov-2013 09:19

    Hello..

    Is the facility under Consent Decree?  If so, FDA will issue a GMP certification.  If not, then you are correct.  An EIR is a report of each inspection that is redacted to prevent revealing product / employee names to the public.  The observation is what is needed.  An EIR report does not expire.  It is a history of the company's GMP activities for the FDA inspector to evaluate before visiting the site again.. which should be every 2 years.  Obviously clients rely on these reports as well. 

    Please check out the FDA's website on Inspection Classifications and Warning Letters to see if this might help:

    http://www.accessdata.fda.gov/scripts/inspsearch/

    http://www.fda.gov/drugs/guidancecomplianceregulatoryinformation/enforcementactivitiesbyfda/warninglettersandnoticeofviolationletterstopharmaceuticalcompanies/ucm339597.htm

    -------------------------------------------
    Alison Trado
    Coordinator, Regulatory and Quality Affairs
    Wellspring Pharmaceutical Corporation
    Sarasota FL
    United States
    -------------------------------------------








  • 12.  RE: EIR (Establishment Inspection Report) issued from FDA

    Posted 15-Oct-2015 17:18


    I am obviously late to this discussion, but I wondered, based on the quality of the posts, whether someone could answer a simple question about response timelines. 

    When FDA says you have 15 business days to respond to a letter, when is "day 1" on the clock? Is it the day the letter is received (presumably by email on the day of issue), or is it the day after? 

    Thank you,

    Justin

    ------------------------------
    Justin Osmond
    Ottawa ON
    Canada



  • 13.  RE: EIR (Establishment Inspection Report) issued from FDA

    Posted 16-Oct-2015 14:40


    It has always been my understanding that the 15 days countdown begins when you sign receipt of a certified letter by the FDA or the day you receive an electronic email with acknowledgment of receipt. 

    ------------------------------
    Stephen Collins
    Director of Quality & Regulatory Affairs
    Phoenix AZ
    United States



  • 14.  RE: EIR (Establishment Inspection Report) issued from FDA

    Posted 19-Oct-2015 09:32


    I don't think it matters, but I always boil these questions down to their simplest form:

    If I receive a letter on Tuesday that says I have one day to reply, I don't think it makes any sense for me to interpret this as requirement to respond that same day.  So I take it that Tuesday is Day 0 and Wednesday is Day 1.

    ------------------------------
    Julie Omohundro RAC
    Durham NC
    United States



  • 15.  RE: EIR (Establishment Inspection Report) issued from FDA

    Posted 19-Oct-2015 12:47


    Justin,

    I have successfully received "VAI letters" from FDA on multiple occasions for 483 responses that FDA received from me on business day 15, where day 1 was the next business day after the date of the 483.  (A "VAI letter" is where FDA essentially states that the response appears to be addressing FDA's concerns, and that FDA will officially verify resolution of the objectionable conditions at the next regularly-scheduled inspection.)

    Hope this helps.

    Best regards,

    Kevin Randall, ASQ CQA, RAC (U.S., Canada, Europe)

    Principal Consultant

    ComplianceAcuity, Inc.

    ------------------------------
    Kevin Randall RAC
    Principal Consultant
    ComplianceAcuity, Inc.
    Golden CO
    United States



  • 16.  RE: EIR (Establishment Inspection Report) issued from FDA

    Posted 19-Oct-2015 12:50
    Justin,

    "When FDA says you have 15 business days to respond to a letter, when is "day 1" on the clock?"

    Day 1 is the day after not counting the day of your receipt of the letter/notice.

    Legal basis?

    As the US FDA is a federal agency in the US, I am interpreting based on the Federal Rules of Civil Procedures (FRCP).

    Thank you.  

    s/ David
    ____________________________________________________________
    Dr. David Lim, Ph.D., RAC, ASQ-CQA 
    President and CEO | REGULATORY DOCTOR and GCS
    Phone (Toll-Free): 1-(800) 321-8567


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