To clarify regarding the legal obligation to reply to 483, the FDA Frequently Asked Questions regarding 483's on the FDA website it states:
Q: What is the purpose of an FDA Form 483?
A: The FDA Form 483 notifies the company’s management of objectionable conditions. At the conclusion of an inspection, the FDA Form 483 is presented and discussed with the company’s senior management. Companies are encouraged to respond to the FDA Form 483 in writing with their corrective action plan and then implement that corrective action plan expeditiously.
The word used by the FDA is "encouraged", meaning not mandatory. That being said, the FDA looks at the 483 report to decide if further action is necessary. It is advisable to respond to each problem cited in the 483 to explain how the company will fully address each issue in order to satisfy the FDA that further action is not necessary. It should be noted that any documents promised in a response to a 483 will be expected to be delivered in a reasonable amount of time.
The implementation of the corrective actions proposed by the company for each problem listed on the 483 will be followed up on at the next inspection. If the corrective actions are not fully implemented, the company risks receiving a warning letter.
Regards,
John Minier, RAC
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John Minier RAC
Sr. Manager, Regulatory Affairs
Integra Lifesciences
Plainsboro NJ
United States
Original Message:
Sent: 10-18-2015 09:44
From: Joyce Dunsmore
Subject: EIRs and 483's
An EIR is just the investigators report to the office of compliance on the inspection findings. It is normally for internal use. A 483 will be prepared if deficiencies are found that require correction. That will be sent to the person who was head of office for the inspection, or the designee.
Someone said you don't need to respond to a 483. That is not correct. You must address each and every deficiency cited in a 483. If the 483 cites quality related issues, you must address what the implications are to you system as well. You must provide a reasonable time frame for addressing and completing each deficiency along with any applicable pertinent documentation, not band-aid solutions. Inadequate response to a 483 can and will likely lead to a warning letter. 483's are not available under FOI, but warning letters become public knowledge.
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Joyce Dunsmore
Clinical, Regulatory & Quality Affairs Consultant
Cocoa FL
United States
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