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  • [Solved] 510 work review

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  • [Solved] MGT 608 Week three discussion post 2 question. Your initial post should be roughly 150 words in length. Cite sources you reference in-text and under a “References” section in APA format

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    – ## WeekThreediscussionpost2HM.docx **## WeekThreediscussionpost2HM.docx** Week THREE discussion post 2 LINK TO BOOK: [https://bookshelf.vitalsource.com/reader/books/9781394217328/epubcfi/6/2[%3Bvnd.vst.idref%3DAcover]!/4](https://bookshelf.vitalsource.com/reader/books/9781394217328/epubcfi/6/2%5…

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    – ## WeekThreediscussionpost2HM.docx

    **## WeekThreediscussionpost2HM.docx**

    Week THREE discussion post 2

    LINK TO BOOK:
    [https://bookshelf.vitalsource.com/reader/books/9781394217328/epubcfi/6/2[%3Bvnd.vst.idref%3DAcover]!/4](https://bookshelf.vitalsource.com/reader/books/9781394217328/epubcfi/6/2%5b%3Bvnd.vst.idref%3DAcover%5d!/4) (I will send username and password separately in message).

    [**Discussion 6: Identify the Business Opportunity and Define the Goal**](https://nationalu.brightspace.com/d2l/le/120512/discussions/topics/449520/View)

    **Instructions**

    Utilizing your organization, identify the supply chain opportunity. You may choose a company if you are not working or have a company to discuss.

    · If you are considering "fix and improve something already existing" (p. 258), then utilize Goldratt's theory of constraints as your guidelines (Chapter 6).

    · If your organization should "build something new," utilize the resources found in Chapter 8 to create your process.

    Contributions must display original thinking and good knowledge of the subject matter, including links and references to sources to support your arguments. Additionally, make sure you cite sources you reference in-text and under a "References" section in APA format.

    **## WeekThreediscussionpost2HM.docx**

    Week THREE discussion post 2

    LINK TO BOOK:
    [https://bookshelf.vitalsource.com/reader/books/9781394217328/epubcfi/6/2[%3Bvnd.vst.idref%3DAcover]!/4](https://bookshelf.vitalsource.com/reader/books/9781394217328/epubcfi/6/2%5b%3Bvnd.vst.idref%3DAcover%5d!/4) (I will send username and password separately in message).

    [**Discussion 6: Identify the Business Opportunity and Define the Goal**](https://nationalu.brightspace.com/d2l/le/120512/discussions/topics/449520/View)

    **Instructions**

    Utilizing your organization, identify the supply chain opportunity. You may choose a company if you are not working or have a company to discuss.

    · If you are considering "fix and improve something already existing" (p. 258), then utilize Goldratt's theory of constraints as your guidelines (Chapter 6).

    · If your organization should "build something new," utilize the resources found in Chapter 8 to create your process.

    Contributions must display original thinking and good knowledge of the subject matter, including links and references to sources to support your arguments. Additionally, make sure you cite sources you reference in-text and under a "References" section in APA format.

  • [Solved] 600 work3

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  • [Solved] GLR STUDY

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    – ## GRLASSIGNMENTNUMBER2.docx – ## GRLR-HomeworkAssignment2-supportingdocument-StridePharmaceuticalWL.pdf – GRLR-HomeworkAssignment2-supportingdocument-2022FDAOutofSpecificationguidance.pdf **## GRLASSIGNMENTNUMBER2.docx** ![](https://www.sweetstudy.com/questions/glr-study)Version 10 **Homework Ass…

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    – ## GRLASSIGNMENTNUMBER2.docx

    – ## GRLR-HomeworkAssignment2-supportingdocument-StridePharmaceuticalWL.pdf

    – GRLR-HomeworkAssignment2-supportingdocument-2022FDAOutofSpecificationguidance.pdf

    **## GRLASSIGNMENTNUMBER2.docx**

    ![](https://www.sweetstudy.com/questions/glr-study)Version 10

    **Homework Assignment 2**

    Pathway for Patient Health

    Global Regulatory and Legal Requirements of Quality

    | |
    | — |
    | **Complete this assignment by typing your answers into this Word document** |

    First Name:

    Last Name:

    Email address:

    · Save this file as: First Name Last Name GRLR Project 2 (e.g. Marla Phillips GRLR Project 2.doc)

    · Submit this assignment in Canvas

    · Assignment due dates are as listed in the syllabus.

    · Generative AI use is not allowed on this assignment.

    | |
    | — |
    | **This assignment must be submitted by the due date that was provided to you by 11:59pm (EST)** |

    **Review the Warning Letter issued to Strides Pharmaceutical by the FDA on July 1, 2019.**

    **Resources** you will need for this Assignment:

    · As the warning letter under review in this assignment may not be available on the active
    [www.FDA.gov](http://www.fda.gov/) website, a copy has been provided in your class materials.

    · The 2022 FDA Out-of-Specification Guidance.
    [https://www.fda.gov/media/158416/download](https://www.fda.gov/media/158416/download)

    **Questions:**

    1. Explain why the “Quality System” was determined to be inadequate by the FDA. Provide evidence from the Warning Letter to support your response. Identify 3 sections of 21CFR211 (Title 21 of the Code of Federal Regulation, Part 211) that you feel were violated, and explain why.

    (
    **Hint:** See the assignment rubric below to ensure that you are providing a complete answer.)

    2. After reviewing the 2022 FDA Guidance on handling out of specification test results (only need to read sections I – IV.B.1), what should Strides Pharmaceuticals have done to investigate their failing results? Provide a brief explanation of the steps they should have taken.

    (
    **Hint:** See the assignment rubric below to ensure that you are providing a complete answer.)

    3. Practice looking up warning letters on the FDA.gov website.

    a. Find the FDA searchable Warning Letter database page.

    b. Provide the following information for the most recent Warning letter issued by the Center of Drug Evaluation and Research (CDER).

    i. Link to warning letter:

    ii. Company name:

    iii. List the violation(s) cited and the referenced regulations (if there are more than two violations sited, just provide information on two):

    (Note: This will look something like this:

    _Your firm failed to have, for each batch of drug product, appropriate laboratory determination of satisfactory conformance to final specifications for the drug product, including the identity and strength of each active ingredient, prior to release (21 CFR 211.165(a))._

    -or, for another example:

    _Your product is misbranded under section 502(a) of the FD&C Act, 21 U.S.C. 352(a)._)

    | | |
    | — | — |
    | **Grading Comments for Question 1** | **Score for Question 1**<br>**(Possible 4)** |
    | | |

    | | |
    | — | — |
    | **Grading Comments for Question 2** | **Score for Question 2**<br>**(Possible 4)** |
    | | |

    | | |
    | — | — |
    | **Grading Comments for Question 3** | **Score for Question 2**<br>**(Possible 2)** |
    | | |

    **Rubric:**

    | | | | | |
    | — | — | — | — | — |
    | | **Does not meet requirements** | **Some requirements met** | **Good** | **Excellent** |
    | **Questions 1** | No engagement/effort with this question. (0)<br>Use of AI (0) | The student identified some minimal examples of quality system violations, but did not provide CFR references or explanation. (1) | The student identified examples of quality system violations, provided CFR references, but did not explain how the CFR sections were violated. (2-3) | The student identified examples of quality system violations, provided CFR references, and explained how the CFR sections were violated. (4) |
    | **Question 2** | No engagement/effort with this question. (0)<br>Use of AI (0) | The student attempted to identify what Stride should have done to investigate the failing results, but the explanation was inadequate, and the student did not describe the steps. (1) | The student identified what Stride should have done to investigate the failing results, but did not describe the steps. (2-3) | The student identified what Stride should have done to investigate the failing results, and described the steps (4) |
    | **Question 3** | No engagement/effort with this question. (0)<br>Use of AI (0) | The student provides a reference to a warning letter from an FDA Center other than CDER (0.5) | The student identifies and references a CDER issued warning letter but does not accurately identify the violations and CFR references. (1-1.5) | The student identifies and references a CDER issued warning letter and correctly provides the requested information. (2) |

    Marla A. Phillips, Ph.D. | CEO and President | Pathway for Patient Health

    Marla.Phillips@Pathway4PH.org | 513-238-4338 | www.Pathway4PH.org

    ## image1.png

    **## GRLR-HomeworkAssignment2-supportingdocument-StridePharmaceuticalWL.pdf**

    1/12/2020 Strides Pharma Science Limited – 576722 – 07/01/2019 | FDA

    https://www.fda.gov/inspections-compliance-enforcement-and-criminal-investigations/warning-letters/strides-pharma-science-limited-576722-07012019 1/5

    WARNING LETTER

    Strides Pharma Science Limited
    MARCS-CMS 576722 — JULY 01, 2019

    Delivery Method:

    UPS

    Product:

    Drugs

    UPS Warning Letter 320-19-28

    Return Receipt Requested

    July 01, 2019

    Mr. Arun Kumar

    Chief Executive Officer/Managing Director

    Recipient:

    Mr. Arun Kumar

    Chief Executive O�cer/Managing Director

    Strides Pharma Science Limited

    Strides House, Bilekahalli
    Bannerghatta Road
    Bangalore 560076
    India

    Issuing O�ce:

    Center for Drug Evaluation and Research

    10903 New Hampshire Avenue
    Silver Spring, MD 20993
    United States

    1/12/2020 Strides Pharma Science Limited – 576722 – 07/01/2019 | FDA

    https://www.fda.gov/inspections-compliance-enforcement-and-criminal-investigations/warning-letters/strides-pharma-science-limited-576722-07012019 2/5

    Strides Pharma Science Limited

    Strides House, Bilekahalli

    Bannerghatta Road

    Bangalore 560076

    India

    Dear Mr. Kumar:

    The U.S. Food and Drug Administration (FDA) inspected your drug manufacturing facility, Strides Pharma Science
    Limited at Unit-II, R. S. No.: 32, 33 & 34 PIMS Road Periyakalapet, Puducherry, from January 28 to February 5, 2019.

    This warning letter summarizes significant violations of current good manufacturing practice (CGMP) regulations for
    finished pharmaceuticals. See 21 CFR, parts 210 and 211.

    Because your methods, facilities, or controls for manufacturing, processing, packing, or holding do not conform to
    CGMP, your drug products are adulterated within the meaning of section 501(a)(2)(B) of the Federal Food, Drug, and
    Cosmetic Act (FD&C Act), 21 U.S.C. 351(a)(2)(B).

    We reviewed your February 26, 2019, response in detail and acknowledge receipt of your subsequent correspondence.

    During our inspection, our investigators observed specific violations including, but not limited to, the following.

    1. Your firm failed to establish an adequate quality control unit with the responsibility and authority to approve
    or reject all components, drug product containers, closures, in-process materials, packaging materials, labeling,
    and drug products (21 CFR 211.22(a)).

    Your quality unit (QU) lacks appropriate responsibility and control over your drug manufacturing operations.
    During the inspection, our investigator observed discarded CGMP documents and evidence of uncontrolled shredding of
    documents. For example, multiple bags of uncontrolled CGMP documents with color coding indicating they were from
    drug production, quality, and laboratory operations were awaiting shredding. Our investigator also found a blue binder
    containing CGMP records, including batch records for U.S. drug products, discarded with other records in a 55-gallon
    drum in your scrap yard. CGMP documents in the binder were dated as recently as January 21, 2019: seven days before
    our inspection. Your QU did not review or check these documents prior to disposal.
    Your QU is responsible for the oversight of your drug manufacturing operations, including the review and approval of
    documents and document controls, to ensure a complete contemporaneous record of each batch of drug product
    manufactured. That record is retained for CGMP purposes including annual review. In addition, your QU is responsible
    for ensuring your production areas are adequately monitored and that employees understand your firm’s procedures and
    their assigned tasks.
    The uncontrolled destruction of CGMP records, and your lack of adequate documentation practices, raise questions about
    the effectiveness of your QU and the integrity and accuracy of your CGMP records.
    In your response you state the binder of CGMP documents in your scrap yard was “inadvertently come [sic] to scrap
    yard” and that you were investigating the issue. You also committed to using bound log books and restricting printing to
    reduce uncontrolled documents. In addition, you committed to strengthen your training program to include instructor-led
    classes geared towards good documentation practices.

    1/12/2020 Strides Pharma Science Limited – 576722 – 07/01/2019 | FDA

    https://www.fda.gov/inspections-compliance-enforcement-and-criminal-investigations/warning-letters/strides-pharma-science-limited-576722-07012019 3/5

    Your response is inadequate because, while you acknowledge the binder of CGMP records in your scrap yard, you did not
    assess other documents found in the scrapyard, nor did you assess how poor documentation practices affected distributed
    drug product or how you would strengthen your QU oversight.
    Your firm’s quality systems are inadequate. See FDA’s guidance document Quality Systems Approach to Pharmaceutical
    CGMP Regulations for help implementing quality systems and risk management approaches to meet the requirements of
    CGMP regulations 21 CFR, parts 210 and 211 at https://www.fda.gov/media/71023/download
    (h�ps://www.fda.gov/media/71023/download%0d)

    2. Your firm failed to thoroughly investigate any unexplained discrepancy or failure of a batch or any of its
    components to meet any of its specifications, whether or not the batch has already been distributed (21 CFR
    211.192).

    Your firm’s investigations of out-of-specification (OOS) results were closed without adequate scientific justification.
    For example, you opened an OOS investigation for (b)(4) USP active pharmaceutical ingredient (API) for an unknown
    impurity which exceeded your specification. Your investigation identified an “old reagent” as a root cause, despite your
    inability to reproduce the unknown impurity. You subsequently retested a new sample with fresh reagents and used the
    passing results to release the API for use in producing your (b)(4) USP drug product. You did not evaluate the original
    failing API sample. Your root cause determination and investigation were not scientifically justified.
    In your response you acknowledged that the original sample should have been tested as part of your investigation to
    determine a root cause and that the final root cause was not definitively concluded. You analyzed reserve samples for the
    lots of drug product manufactured with the API and found them to meet specifications. You also provided a retrospective
    review for all of your previous “invalidated” OOS results for products manufactured between January 2017 and March
    2019.
    Your response is inadequate. You failed to include the data that supports your reserve sample testing for batches
    manufactured containing the lot of API identified in your OOS investigation. In addition, you identified nine additional
    OOS investigations in which your root cause determination and investigation were not scientifically justified. You did not
    extend your investigation to include any associated reserve samples of batches that may have been manufactured using
    OOS materials.
    In response to this letter:

    For any OOS results with inconclusive or no root cause identified in the laboratory, include a thorough
    review of production (e.g., batch manufacturing records, adequacy of the manufacturing steps, raw
    materials, process capability, deviation history, batch failure history). Provide a corrective action and
    preventive action (CAPA) plan that identifies root causes and specifies meaningful improvements.

    Provide all reserve sample testing results. Include all analytical data for the API and drug product batches,
    including any batches manufactured using API with associated OOS results with inconclusive or no root
    cause.

    For more information about proper handling of OOS results and documenting your investigations, refer to the FDA
    guidance for industry Investigating OOS Test Results for Pharmaceutical Production at

    https://www.fda.gov/downloads/Drugs/GuidanceComplianceRegulatoryInformation/Guidances/UCM070287.pdf
    (h�ps://www.fda.gov/downloads/Drugs/GuidanceComplianceRegulatoryInforma�on/Guidances/UCM070287.pdf)

    Data Integrity Remediation

    [https://www.fda.gov/media/71023/download%0d](https://www.fda.gov/media/71023/download%0d)

    [https://www.fda.gov/downloads/Drugs/GuidanceComplianceRegulatoryInformation/Guidances/UCM070287.pdf](https://www.fda.gov/downloads/Drugs/GuidanceComplianceRegulatoryInformation/Guidances/UCM070287.pdf)

    1/12/2020 Strides Pharma Science Limited – 576722 – 07/01/2019 | FDA

    https://www.fda.gov/inspections-compliance-enforcement-and-criminal-investigations/warning-letters/strides-pharma-science-limited-576722-07012019 4/5

    Your quality system does not adequately ensure the accuracy and integrity of data to support the safety, effectiveness, and
    quality of the drugs you manufacture. See FDA’s guidance document Data Integrity and Compliance With Drug CGMP
    for guidance on establishing and following CGMP-compliant data integrity practices
    at https://www.fda.gov/downloads/Drugs/GuidanceComplianceRegulatoryInformation/Guidances/UCM495891.pdf
    (h�ps://www.fda.gov/downloads/Drugs/GuidanceComplianceRegulatoryInforma�on/Guidances/UCM495891.pdf)

    We strongly recommend that you retain a qualified consultant to assist in your remediation.

    In response to this letter, provide the following:

    A. An assessment of the extent of data integrity deficiencies at your facility. Identify omissions, alterations, deletions,
    record destruction, non-contemporaneous record completion, and other deficiencies. Describe all parts of your
    facility’s operations in which you discovered data integrity lapses.

    B. A current risk assessment of the potential effects of the observed failures on the quality of your drugs. Your
    assessment should include analyses of the risks to patients caused by the release of drugs affected by a lapse of data
    integrity and analyses of the risks posed by ongoing operations.

    C. A management strategy for your firm that includes the details of your global corrective action and preventive action
    plan. The detailed corrective action plan should describe how you intend to ensure the reliability and completeness
    of all data generated by your firm, including microbiological and analytical data, manufacturing records, and all
    data submitted to FDA.

    Conclusion
    Violations cited in this letter are not intended as an all-inclusive list. You are responsible for investigating these
    violations, for determining the causes, for preventing their recurrence, and for preventing other violations in all your
    facilities.
    If you are considering an action that is likely to lead to a disruption in the supply of drugs produced at your facility, FDA
    requests that you contact CDER’s Drug Shortages Staff immediately, at drugshortages@fda.hhs.gov, so that FDA can
    work with you on the most effective way to bring your operations into compliance with the law. Contacting the Drug
    Shortages Staff also allows you to meet any obligations you may have to report discontinuances or interruptions in your
    drug manufacture under 21 U.S.C. 356C(b) and allows FDA to consider, as soon as possible, what actions, if any, may be
    needed to avoid shortages and protect the health of patients who depend on your products.
    Until you correct all violations completely and we confirm your compliance with CGMP, FDA may withhold approval of
    any new applications or supplements listing your firm as a drug manufacturer.
    Failure to correct these violations may also result in FDA refusing admission of articles manufactured at Strides Pharma
    Science Limited, FEI 3012448465, at Unit-II, R. S. No.: 32, 33 & 34 PIMS Road Periyakalapet, Puducherry into the
    United States under section 801(a)(3) of the FD&C Act, 21 U.S.C. 381(a)(3). Under the same authority, articles may be
    subject to refusal of admission, in that the methods and controls used in their manufacture do not appear to conform to
    CGMP within the meaning of section 501(a)(2)(B) of the FD&C Act, 21 U.S.C. 351(a)(2)(B).
    After you receive this letter, respond to this office in writing within 15 working days. Specify what you have done since
    our inspection to correct your violations and to prevent their recurrence. If you cannot complete corrective actions within
    15 working days, state your reasons for delay and your schedule for completion.
    Send your electronic reply to CDER-OC-OMQ-Communications@fda.hhs.gov (mailto:CDER-OC-OMQ-

    Communica�ons@fda.hhs.gov) or mail your reply to:

    Carla Norris

    Compliance Officer

    [https://www.fda.gov/downloads/Drugs/GuidanceComplianceRegulatoryInformation/Guidances/UCM495891.pdf](https://www.fda.gov/downloads/Drugs/GuidanceComplianceRegulatoryInformation/Guidances/UCM495891.pdf)

    [mailto:CDER-OC-OMQ-Communications@fda.hhs.gov](mailto:CDER-OC-OMQ-Communications@fda.hhs.gov)

    1/12/2020 Strides Pharma Science Limited – 576722 – 07/01/2019 | FDA

    https://www.fda.gov/inspections-compliance-enforcement-and-criminal-investigations/warning-letters/strides-pharma-science-limited-576722-07012019 5/5

    U.S. Food and Drug Administration

    White Oak Building 51, Room 4359

    10903 New Hampshire Avenue

    Silver Spring, MD 20993

    USA

    Please identify your response with FEI 3012448465.

    Sincerely,

    /S/

    Francis Godwin

    Director

    Office of Manufacturing Quality

    Office of Compliance

    Center for Drug Evaluation and Research

    cc:
    Mr. Umesh Kale
    President & Chief Quality Officer

    Strides Pharma Science Limited

    Strides House, Bilekahalli

    Bannerghatta Road

    Bangalore 560076

    India

     More Warning Letters (/inspections-compliance-enforcement-and-criminal-investigations/compliance-actions-and-activities/warning-letters)

    [https://www.fda.gov/inspections-compliance-enforcement-and-criminal-investigations/compliance-actions-and-activities/warning-letters](https://www.fda.gov/inspections-compliance-enforcement-and-criminal-investigations/compliance-actions-and-activities/warning-letters)

    **GRLR-HomeworkAssignment2-supportingdocument-2022FDAOutofSpecificationguidance.pdf**

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    **## GRLASSIGNMENTNUMBER2.docx**

    ![](https://www.sweetstudy.com/questions/glr-study)Version 10

    **Homework Assignment 2**

    Pathway for Patient Health

    Global Regulatory and Legal Requirements of Quality

    | |
    | — |
    | **Complete this assignment by typing your answers into this Word document** |

    First Name:

    Last Name:

    Email address:

    · Save this file as: First Name Last Name GRLR Project 2 (e.g. Marla Phillips GRLR Project 2.doc)

    · Submit this assignment in Canvas

    · Assignment due dates are as listed in the syllabus.

    · Generative AI use is not allowed on this assignment.

    | |
    | — |
    | **This assignment must be submitted by the due date that was provided to you by 11:59pm (EST)** |

    **Review the Warning Letter issued to Strides Pharmaceutical by the FDA on July 1, 2019.**

    **Resources** you will need for this Assignment:

    · As the warning letter under review in this assignment may not be available on the active
    [www.FDA.gov](http://www.fda.gov/) website, a copy has been provided in your class materials.

    · The 2022 FDA Out-of-Specification Guidance.
    [https://www.fda.gov/media/158416/download](https://www.fda.gov/media/158416/download)

    **Questions:**

    1. Explain why the “Quality System” was determined to be inadequate by the FDA. Provide evidence from the Warning Letter to support your response. Identify 3 sections of 21CFR211 (Title 21 of the Code of Federal Regulation, Part 211) that you feel were violated, and explain why.

    (
    **Hint:** See the assignment rubric below to ensure that you are providing a complete answer.)

    2. After reviewing the 2022 FDA Guidance on handling out of specification test results (only need to read sections I – IV.B.1), what should Strides Pharmaceuticals have done to investigate their failing results? Provide a brief explanation of the steps they should have taken.

    (
    **Hint:** See the assignment rubric below to ensure that you are providing a complete answer.)

    3. Practice looking up warning letters on the FDA.gov website.

    a. Find the FDA searchable Warning Letter database page.

    b. Provide the following information for the most recent Warning letter issued by the Center of Drug Evaluation and Research (CDER).

    i. Link to warning letter:

    ii. Company name:

    iii. List the violation(s) cited and the referenced regulations (if there are more than two violations sited, just provide information on two):

    (Note: This will look something like this:

    _Your firm failed to have, for each batch of drug product, appropriate laboratory determination of satisfactory conformance to final specifications for the drug product, including the identity and strength of each active ingredient, prior to release (21 CFR 211.165(a))._

    -or, for another example:

    _Your product is misbranded under section 502(a) of the FD&C Act, 21 U.S.C. 352(a)._)

    | | |
    | — | — |
    | **Grading Comments for Question 1** | **Score for Question 1**<br>**(Possible 4)** |
    | | |

    | | |
    | — | — |
    | **Grading Comments for Question 2** | **Score for Question 2**<br>**(Possible 4)** |
    | | |

    | | |
    | — | — |
    | **Grading Comments for Question 3** | **Score for Question 2**<br>**(Possible 2)** |
    | | |

    **Rubric:**

    | | | | | |
    | — | — | — | — | — |
    | | **Does not meet requirements** | **Some requirements met** | **Good** | **Excellent** |
    | **Questions 1** | No engagement/effort with this question. (0)<br>Use of AI (0) | The student identified some minimal examples of quality system violations, but did not provide CFR references or explanation. (1) | The student identified examples of quality system violations, provided CFR references, but did not explain how the CFR sections were violated. (2-3) | The student identified examples of quality system violations, provided CFR references, and explained how the CFR sections were violated. (4) |
    | **Question 2** | No engagement/effort with this question. (0)<br>Use of AI (0) | The student attempted to identify what Stride should have done to investigate the failing results, but the explanation was inadequate, and the student did not describe the steps. (1) | The student identified what Stride should have done to investigate the failing results, but did not describe the steps. (2-3) | The student identified what Stride should have done to investigate the failing results, and described the steps (4) |
    | **Question 3** | No engagement/effort with this question. (0)<br>Use of AI (0) | The student provides a reference to a warning letter from an FDA Center other than CDER (0.5) | The student identifies and references a CDER issued warning letter but does not accurately identify the violations and CFR references. (1-1.5) | The student identifies and references a CDER issued warning letter and correctly provides the requested information. (2) |

    Marla A. Phillips, Ph.D. | CEO and President | Pathway for Patient Health

    Marla.Phillips@Pathway4PH.org | 513-238-4338 | www.Pathway4PH.org

    ## image1.png

    **## GRLR-HomeworkAssignment2-supportingdocument-StridePharmaceuticalWL.pdf**

    1/12/2020 Strides Pharma Science Limited – 576722 – 07/01/2019 | FDA

    https://www.fda.gov/inspections-compliance-enforcement-and-criminal-investigations/warning-letters/strides-pharma-science-limited-576722-07012019 1/5

    WARNING LETTER

    Strides Pharma Science Limited
    MARCS-CMS 576722 — JULY 01, 2019

    Delivery Method:

    UPS

    Product:

    Drugs

    UPS Warning Letter 320-19-28

    Return Receipt Requested

    July 01, 2019

    Mr. Arun Kumar

    Chief Executive Officer/Managing Director

    Recipient:

    Mr. Arun Kumar

    Chief Executive O�cer/Managing Director

    Strides Pharma Science Limited

    Strides House, Bilekahalli
    Bannerghatta Road
    Bangalore 560076
    India

    Issuing O�ce:

    Center for Drug Evaluation and Research

    10903 New Hampshire Avenue
    Silver Spring, MD 20993
    United States

    1/12/2020 Strides Pharma Science Limited – 576722 – 07/01/2019 | FDA

    https://www.fda.gov/inspections-compliance-enforcement-and-criminal-investigations/warning-letters/strides-pharma-science-limited-576722-07012019 2/5

    Strides Pharma Science Limited

    Strides House, Bilekahalli

    Bannerghatta Road

    Bangalore 560076

    India

    Dear Mr. Kumar:

    The U.S. Food and Drug Administration (FDA) inspected your drug manufacturing facility, Strides Pharma Science
    Limited at Unit-II, R. S. No.: 32, 33 & 34 PIMS Road Periyakalapet, Puducherry, from January 28 to February 5, 2019.

    This warning letter summarizes significant violations of current good manufacturing practice (CGMP) regulations for
    finished pharmaceuticals. See 21 CFR, parts 210 and 211.

    Because your methods, facilities, or controls for manufacturing, processing, packing, or holding do not conform to
    CGMP, your drug products are adulterated within the meaning of section 501(a)(2)(B) of the Federal Food, Drug, and
    Cosmetic Act (FD&C Act), 21 U.S.C. 351(a)(2)(B).

    We reviewed your February 26, 2019, response in detail and acknowledge receipt of your subsequent correspondence.

    During our inspection, our investigators observed specific violations including, but not limited to, the following.

    1. Your firm failed to establish an adequate quality control unit with the responsibility and authority to approve
    or reject all components, drug product containers, closures, in-process materials, packaging materials, labeling,
    and drug products (21 CFR 211.22(a)).

    Your quality unit (QU) lacks appropriate responsibility and control over your drug manufacturing operations.
    During the inspection, our investigator observed discarded CGMP documents and evidence of uncontrolled shredding of
    documents. For example, multiple bags of uncontrolled CGMP documents with color coding indicating they were from
    drug production, quality, and laboratory operations were awaiting shredding. Our investigator also found a blue binder
    containing CGMP records, including batch records for U.S. drug products, discarded with other records in a 55-gallon
    drum in your scrap yard. CGMP documents in the binder were dated as recently as January 21, 2019: seven days before
    our inspection. Your QU did not review or check these documents prior to disposal.
    Your QU is responsible for the oversight of your drug manufacturing operations, including the review and approval of
    documents and document controls, to ensure a complete contemporaneous record of each batch of drug product
    manufactured. That record is retained for CGMP purposes including annual review. In addition, your QU is responsible
    for ensuring your production areas are adequately monitored and that employees understand your firm’s procedures and
    their assigned tasks.
    The uncontrolled destruction of CGMP records, and your lack of adequate documentation practices, raise questions about
    the effectiveness of your QU and the integrity and accuracy of your CGMP records.
    In your response you state the binder of CGMP documents in your scrap yard was “inadvertently come [sic] to scrap
    yard” and that you were investigating the issue. You also committed to using bound log books and restricting printing to
    reduce uncontrolled documents. In addition, you committed to strengthen your training program to include instructor-led
    classes geared towards good documentation practices.

    1/12/2020 Strides Pharma Science Limited – 576722 – 07/01/2019 | FDA

    https://www.fda.gov/inspections-compliance-enforcement-and-criminal-investigations/warning-letters/strides-pharma-science-limited-576722-07012019 3/5

    Your response is inadequate because, while you acknowledge the binder of CGMP records in your scrap yard, you did not
    assess other documents found in the scrapyard, nor did you assess how poor documentation practices affected distributed
    drug product or how you would strengthen your QU oversight.
    Your firm’s quality systems are inadequate. See FDA’s guidance document Quality Systems Approach to Pharmaceutical
    CGMP Regulations for help implementing quality systems and risk management approaches to meet the requirements of
    CGMP regulations 21 CFR, parts 210 and 211 at https://www.fda.gov/media/71023/download
    (h�ps://www.fda.gov/media/71023/download%0d)

    2. Your firm failed to thoroughly investigate any unexplained discrepancy or failure of a batch or any of its
    components to meet any of its specifications, whether or not the batch has already been distributed (21 CFR
    211.192).

    Your firm’s investigations of out-of-specification (OOS) results were closed without adequate scientific justification.
    For example, you opened an OOS investigation for (b)(4) USP active pharmaceutical ingredient (API) for an unknown
    impurity which exceeded your specification. Your investigation identified an “old reagent” as a root cause, despite your
    inability to reproduce the unknown impurity. You subsequently retested a new sample with fresh reagents and used the
    passing results to release the API for use in producing your (b)(4) USP drug product. You did not evaluate the original
    failing API sample. Your root cause determination and investigation were not scientifically justified.
    In your response you acknowledged that the original sample should have been tested as part of your investigation to
    determine a root cause and that the final root cause was not definitively concluded. You analyzed reserve samples for the
    lots of drug product manufactured with the API and found them to meet specifications. You also provided a retrospective
    review for all of your previous “invalidated” OOS results for products manufactured between January 2017 and March
    2019.
    Your response is inadequate. You failed to include the data that supports your reserve sample testing for batches
    manufactured containing the lot of API identified in your OOS investigation. In addition, you identified nine additional
    OOS investigations in which your root cause determination and investigation were not scientifically justified. You did not
    extend your investigation to include any associated reserve samples of batches that may have been manufactured using
    OOS materials.
    In response to this letter:

    For any OOS results with inconclusive or no root cause identified in the laboratory, include a thorough
    review of production (e.g., batch manufacturing records, adequacy of the manufacturing steps, raw
    materials, process capability, deviation history, batch failure history). Provide a corrective action and
    preventive action (CAPA) plan that identifies root causes and specifies meaningful improvements.

    Provide all reserve sample testing results. Include all analytical data for the API and drug product batches,
    including any batches manufactured using API with associated OOS results with inconclusive or no root
    cause.

    For more information about proper handling of OOS results and documenting your investigations, refer to the FDA
    guidance for industry Investigating OOS Test Results for Pharmaceutical Production at

    https://www.fda.gov/downloads/Drugs/GuidanceComplianceRegulatoryInformation/Guidances/UCM070287.pdf
    (h�ps://www.fda.gov/downloads/Drugs/GuidanceComplianceRegulatoryInforma�on/Guidances/UCM070287.pdf)

    Data Integrity Remediation

    [https://www.fda.gov/media/71023/download%0d](https://www.fda.gov/media/71023/download%0d)

    [https://www.fda.gov/downloads/Drugs/GuidanceComplianceRegulatoryInformation/Guidances/UCM070287.pdf](https://www.fda.gov/downloads/Drugs/GuidanceComplianceRegulatoryInformation/Guidances/UCM070287.pdf)

    1/12/2020 Strides Pharma Science Limited – 576722 – 07/01/2019 | FDA

    https://www.fda.gov/inspections-compliance-enforcement-and-criminal-investigations/warning-letters/strides-pharma-science-limited-576722-07012019 4/5

    Your quality system does not adequately ensure the accuracy and integrity of data to support the safety, effectiveness, and
    quality of the drugs you manufacture. See FDA’s guidance document Data Integrity and Compliance With Drug CGMP
    for guidance on establishing and following CGMP-compliant data integrity practices
    at https://www.fda.gov/downloads/Drugs/GuidanceComplianceRegulatoryInformation/Guidances/UCM495891.pdf
    (h�ps://www.fda.gov/downloads/Drugs/GuidanceComplianceRegulatoryInforma�on/Guidances/UCM495891.pdf)

    We strongly recommend that you retain a qualified consultant to assist in your remediation.

    In response to this letter, provide the following:

    A. An assessment of the extent of data integrity deficiencies at your facility. Identify omissions, alterations, deletions,
    record destruction, non-contemporaneous record completion, and other deficiencies. Describe all parts of your
    facility’s operations in which you discovered data integrity lapses.

    B. A current risk assessment of the potential effects of the observed failures on the quality of your drugs. Your
    assessment should include analyses of the risks to patients caused by the release of drugs affected by a lapse of data
    integrity and analyses of the risks posed by ongoing operations.

    C. A management strategy for your firm that includes the details of your global corrective action and preventive action
    plan. The detailed corrective action plan should describe how you intend to ensure the reliability and completeness
    of all data generated by your firm, including microbiological and analytical data, manufacturing records, and all
    data submitted to FDA.

    Conclusion
    Violations cited in this letter are not intended as an all-inclusive list. You are responsible for investigating these
    violations, for determining the causes, for preventing their recurrence, and for preventing other violations in all your
    facilities.
    If you are considering an action that is likely to lead to a disruption in the supply of drugs produced at your facility, FDA
    requests that you contact CDER’s Drug Shortages Staff immediately, at drugshortages@fda.hhs.gov, so that FDA can
    work with you on the most effective way to bring your operations into compliance with the law. Contacting the Drug
    Shortages Staff also allows you to meet any obligations you may have to report discontinuances or interruptions in your
    drug manufacture under 21 U.S.C. 356C(b) and allows FDA to consider, as soon as possible, what actions, if any, may be
    needed to avoid shortages and protect the health of patients who depend on your products.
    Until you correct all violations completely and we confirm your compliance with CGMP, FDA may withhold approval of
    any new applications or supplements listing your firm as a drug manufacturer.
    Failure to correct these violations may also result in FDA refusing admission of articles manufactured at Strides Pharma
    Science Limited, FEI 3012448465, at Unit-II, R. S. No.: 32, 33 & 34 PIMS Road Periyakalapet, Puducherry into the
    United States under section 801(a)(3) of the FD&C Act, 21 U.S.C. 381(a)(3). Under the same authority, articles may be
    subject to refusal of admission, in that the methods and controls used in their manufacture do not appear to conform to
    CGMP within the meaning of section 501(a)(2)(B) of the FD&C Act, 21 U.S.C. 351(a)(2)(B).
    After you receive this letter, respond to this office in writing within 15 working days. Specify what you have done since
    our inspection to correct your violations and to prevent their recurrence. If you cannot complete corrective actions within
    15 working days, state your reasons for delay and your schedule for completion.
    Send your electronic reply to CDER-OC-OMQ-Communications@fda.hhs.gov (mailto:CDER-OC-OMQ-

    Communica�ons@fda.hhs.gov) or mail your reply to:

    Carla Norris

    Compliance Officer

    [https://www.fda.gov/downloads/Drugs/GuidanceComplianceRegulatoryInformation/Guidances/UCM495891.pdf](https://www.fda.gov/downloads/Drugs/GuidanceComplianceRegulatoryInformation/Guidances/UCM495891.pdf)

    [mailto:CDER-OC-OMQ-Communications@fda.hhs.gov](mailto:CDER-OC-OMQ-Communications@fda.hhs.gov)

    1/12/2020 Strides Pharma Science Limited – 576722 – 07/01/2019 | FDA

    https://www.fda.gov/inspections-compliance-enforcement-and-criminal-investigations/warning-letters/strides-pharma-science-limited-576722-07012019 5/5

    U.S. Food and Drug Administration

    White Oak Building 51, Room 4359

    10903 New Hampshire Avenue

    Silver Spring, MD 20993

    USA

    Please identify your response with FEI 3012448465.

    Sincerely,

    /S/

    Francis Godwin

    Director

    Office of Manufacturing Quality

    Office of Compliance

    Center for Drug Evaluation and Research

    cc:
    Mr. Umesh Kale
    President & Chief Quality Officer

    Strides Pharma Science Limited

    Strides House, Bilekahalli

    Bannerghatta Road

    Bangalore 560076

    India

     More Warning Letters (/inspections-compliance-enforcement-and-criminal-investigations/compliance-actions-and-activities/warning-letters)

    [https://www.fda.gov/inspections-compliance-enforcement-and-criminal-investigations/compliance-actions-and-activities/warning-letters](https://www.fda.gov/inspections-compliance-enforcement-and-criminal-investigations/compliance-actions-and-activities/warning-letters)

    **GRLR-HomeworkAssignment2-supportingdocument-2022FDAOutofSpecificationguidance.pdf**

    This file is too large to display. [View in new window](https://www.sweetstudy.com/files/grlr-homeworkassignment2-supportingdocument-2022fdaoutofspecificationguidance-pdf)

    **## GRLASSIGNMENTNUMBER2.docx**

    ![](https://www.sweetstudy.com/questions/glr-study)Version 10

    **Homework Assignment 2**

    Pathway for Patient Health

    Global Regulatory and Legal Requirements of Quality

    | |
    | — |
    | **Complete this assignment by typing your answers into this Word document** |

    First Name:

    Last Name:

    Email address:

    · Save this file as: First Name Last Name GRLR Project 2 (e.g. Marla Phillips GRLR Project 2.doc)

    · Submit this assignment in Canvas

    · Assignment due dates are as listed in the syllabus.

    · Generative AI use is not allowed on this assignment.

    | |
    | — |
    | **This assignment must be submitted by the due date that was provided to you by 11:59pm (EST)** |

    **Review the Warning Letter issued to Strides Pharmaceutical by the FDA on July 1, 2019.**

    **Resources** you will need for this Assignment:

    · As the warning letter under review in this assignment may not be available on the active
    [www.FDA.gov](http://www.fda.gov/) website, a copy has been provided in your class materials.

    · The 2022 FDA Out-of-Specification Guidance.
    [https://www.fda.gov/media/158416/download](https://www.fda.gov/media/158416/download)

    **Questions:**

    1. Explain why the “Quality System” was determined to be inadequate by the FDA. Provide evidence from the Warning Letter to support your response. Identify 3 sections of 21CFR211 (Title 21 of the Code of Federal Regulation, Part 211) that you feel were violated, and explain why.

    (
    **Hint:** See the assignment rubric below to ensure that you are providing a complete answer.)

    2. After reviewing the 2022 FDA Guidance on handling out of specification test results (only need to read sections I – IV.B.1), what should Strides Pharmaceuticals have done to investigate their failing results? Provide a brief explanation of the steps they should have taken.

    (
    **Hint:** See the assignment rubric below to ensure that you are providing a complete answer.)

    3. Practice looking up warning letters on the FDA.gov website.

    a. Find the FDA searchable Warning Letter database page.

    b. Provide the following information for the most recent Warning letter issued by the Center of Drug Evaluation and Research (CDER).

    i. Link to warning letter:

    ii. Company name:

    iii. List the violation(s) cited and the referenced regulations (if there are more than two violations sited, just provide information on two):

    (Note: This will look something like this:

    _Your firm failed to have, for each batch of drug product, appropriate laboratory determination of satisfactory conformance to final specifications for the drug product, including the identity and strength of each active ingredient, prior to release (21 CFR 211.165(a))._

    -or, for another example:

    _Your product is misbranded under section 502(a) of the FD&C Act, 21 U.S.C. 352(a)._)

    | | |
    | — | — |
    | **Grading Comments for Question 1** | **Score for Question 1**<br>**(Possible 4)** |
    | | |

    | | |
    | — | — |
    | **Grading Comments for Question 2** | **Score for Question 2**<br>**(Possible 4)** |
    | | |

    | | |
    | — | — |
    | **Grading Comments for Question 3** | **Score for Question 2**<br>**(Possible 2)** |
    | | |

    **Rubric:**

    | | | | | |
    | — | — | — | — | — |
    | | **Does not meet requirements** | **Some requirements met** | **Good** | **Excellent** |
    | **Questions 1** | No engagement/effort with this question. (0)<br>Use of AI (0) | The student identified some minimal examples of quality system violations, but did not provide CFR references or explanation. (1) | The student identified examples of quality system violations, provided CFR references, but did not explain how the CFR sections were violated. (2-3) | The student identified examples of quality system violations, provided CFR references, and explained how the CFR sections were violated. (4) |
    | **Question 2** | No engagement/effort with this question. (0)<br>Use of AI (0) | The student attempted to identify what Stride should have done to investigate the failing results, but the explanation was inadequate, and the student did not describe the steps. (1) | The student identified what Stride should have done to investigate the failing results, but did not describe the steps. (2-3) | The student identified what Stride should have done to investigate the failing results, and described the steps (4) |
    | **Question 3** | No engagement/effort with this question. (0)<br>Use of AI (0) | The student provides a reference to a warning letter from an FDA Center other than CDER (0.5) | The student identifies and references a CDER issued warning letter but does not accurately identify the violations and CFR references. (1-1.5) | The student identifies and references a CDER issued warning letter and correctly provides the requested information. (2) |

    Marla A. Phillips, Ph.D. | CEO and President | Pathway for Patient Health

    Marla.Phillips@Pathway4PH.org | 513-238-4338 | www.Pathway4PH.org

    ## image1.png

    **## GRLR-HomeworkAssignment2-supportingdocument-StridePharmaceuticalWL.pdf**

    1/12/2020 Strides Pharma Science Limited – 576722 – 07/01/2019 | FDA

    https://www.fda.gov/inspections-compliance-enforcement-and-criminal-investigations/warning-letters/strides-pharma-science-limited-576722-07012019 1/5

    WARNING LETTER

    Strides Pharma Science Limited
    MARCS-CMS 576722 — JULY 01, 2019

    Delivery Method:

    UPS

    Product:

    Drugs

    UPS Warning Letter 320-19-28

    Return Receipt Requested

    July 01, 2019

    Mr. Arun Kumar

    Chief Executive Officer/Managing Director

    Recipient:

    Mr. Arun Kumar

    Chief Executive O�cer/Managing Director

    Strides Pharma Science Limited

    Strides House, Bilekahalli
    Bannerghatta Road
    Bangalore 560076
    India

    Issuing O�ce:

    Center for Drug Evaluation and Research

    10903 New Hampshire Avenue
    Silver Spring, MD 20993
    United States

    1/12/2020 Strides Pharma Science Limited – 576722 – 07/01/2019 | FDA

    https://www.fda.gov/inspections-compliance-enforcement-and-criminal-investigations/warning-letters/strides-pharma-science-limited-576722-07012019 2/5

    Strides Pharma Science Limited

    Strides House, Bilekahalli

    Bannerghatta Road

    Bangalore 560076

    India

    Dear Mr. Kumar:

    The U.S. Food and Drug Administration (FDA) inspected your drug manufacturing facility, Strides Pharma Science
    Limited at Unit-II, R. S. No.: 32, 33 & 34 PIMS Road Periyakalapet, Puducherry, from January 28 to February 5, 2019.

    This warning letter summarizes significant violations of current good manufacturing practice (CGMP) regulations for
    finished pharmaceuticals. See 21 CFR, parts 210 and 211.

    Because your methods, facilities, or controls for manufacturing, processing, packing, or holding do not conform to
    CGMP, your drug products are adulterated within the meaning of section 501(a)(2)(B) of the Federal Food, Drug, and
    Cosmetic Act (FD&C Act), 21 U.S.C. 351(a)(2)(B).

    We reviewed your February 26, 2019, response in detail and acknowledge receipt of your subsequent correspondence.

    During our inspection, our investigators observed specific violations including, but not limited to, the following.

    1. Your firm failed to establish an adequate quality control unit with the responsibility and authority to approve
    or reject all components, drug product containers, closures, in-process materials, packaging materials, labeling,
    and drug products (21 CFR 211.22(a)).

    Your quality unit (QU) lacks appropriate responsibility and control over your drug manufacturing operations.
    During the inspection, our investigator observed discarded CGMP documents and evidence of uncontrolled shredding of
    documents. For example, multiple bags of uncontrolled CGMP documents with color coding indicating they were from
    drug production, quality, and laboratory operations were awaiting shredding. Our investigator also found a blue binder
    containing CGMP records, including batch records for U.S. drug products, discarded with other records in a 55-gallon
    drum in your scrap yard. CGMP documents in the binder were dated as recently as January 21, 2019: seven days before
    our inspection. Your QU did not review or check these documents prior to disposal.
    Your QU is responsible for the oversight of your drug manufacturing operations, including the review and approval of
    documents and document controls, to ensure a complete contemporaneous record of each batch of drug product
    manufactured. That record is retained for CGMP purposes including annual review. In addition, your QU is responsible
    for ensuring your production areas are adequately monitored and that employees understand your firm’s procedures and
    their assigned tasks.
    The uncontrolled destruction of CGMP records, and your lack of adequate documentation practices, raise questions about
    the effectiveness of your QU and the integrity and accuracy of your CGMP records.
    In your response you state the binder of CGMP documents in your scrap yard was “inadvertently come [sic] to scrap
    yard” and that you were investigating the issue. You also committed to using bound log books and restricting printing to
    reduce uncontrolled documents. In addition, you committed to strengthen your training program to include instructor-led
    classes geared towards good documentation practices.

    1/12/2020 Strides Pharma Science Limited – 576722 – 07/01/2019 | FDA

    https://www.fda.gov/inspections-compliance-enforcement-and-criminal-investigations/warning-letters/strides-pharma-science-limited-576722-07012019 3/5

    Your response is inadequate because, while you acknowledge the binder of CGMP records in your scrap yard, you did not
    assess other documents found in the scrapyard, nor did you assess how poor documentation practices affected distributed
    drug product or how you would strengthen your QU oversight.
    Your firm’s quality systems are inadequate. See FDA’s guidance document Quality Systems Approach to Pharmaceutical
    CGMP Regulations for help implementing quality systems and risk management approaches to meet the requirements of
    CGMP regulations 21 CFR, parts 210 and 211 at https://www.fda.gov/media/71023/download
    (h�ps://www.fda.gov/media/71023/download%0d)

    2. Your firm failed to thoroughly investigate any unexplained discrepancy or failure of a batch or any of its
    components to meet any of its specifications, whether or not the batch has already been distributed (21 CFR
    211.192).

    Your firm’s investigations of out-of-specification (OOS) results were closed without adequate scientific justification.
    For example, you opened an OOS investigation for (b)(4) USP active pharmaceutical ingredient (API) for an unknown
    impurity which exceeded your specification. Your investigation identified an “old reagent” as a root cause, despite your
    inability to reproduce the unknown impurity. You subsequently retested a new sample with fresh reagents and used the
    passing results to release the API for use in producing your (b)(4) USP drug product. You did not evaluate the original
    failing API sample. Your root cause determination and investigation were not scientifically justified.
    In your response you acknowledged that the original sample should have been tested as part of your investigation to
    determine a root cause and that the final root cause was not definitively concluded. You analyzed reserve samples for the
    lots of drug product manufactured with the API and found them to meet specifications. You also provided a retrospective
    review for all of your previous “invalidated” OOS results for products manufactured between January 2017 and March
    2019.
    Your response is inadequate. You failed to include the data that supports your reserve sample testing for batches
    manufactured containing the lot of API identified in your OOS investigation. In addition, you identified nine additional
    OOS investigations in which your root cause determination and investigation were not scientifically justified. You did not
    extend your investigation to include any associated reserve samples of batches that may have been manufactured using
    OOS materials.
    In response to this letter:

    For any OOS results with inconclusive or no root cause identified in the laboratory, include a thorough
    review of production (e.g., batch manufacturing records, adequacy of the manufacturing steps, raw
    materials, process capability, deviation history, batch failure history). Provide a corrective action and
    preventive action (CAPA) plan that identifies root causes and specifies meaningful improvements.

    Provide all reserve sample testing results. Include all analytical data for the API and drug product batches,
    including any batches manufactured using API with associated OOS results with inconclusive or no root
    cause.

    For more information about proper handling of OOS results and documenting your investigations, refer to the FDA
    guidance for industry Investigating OOS Test Results for Pharmaceutical Production at

    https://www.fda.gov/downloads/Drugs/GuidanceComplianceRegulatoryInformation/Guidances/UCM070287.pdf
    (h�ps://www.fda.gov/downloads/Drugs/GuidanceComplianceRegulatoryInforma�on/Guidances/UCM070287.pdf)

    Data Integrity Remediation

    [https://www.fda.gov/media/71023/download%0d](https://www.fda.gov/media/71023/download%0d)

    [https://www.fda.gov/downloads/Drugs/GuidanceComplianceRegulatoryInformation/Guidances/UCM070287.pdf](https://www.fda.gov/downloads/Drugs/GuidanceComplianceRegulatoryInformation/Guidances/UCM070287.pdf)

    1/12/2020 Strides Pharma Science Limited – 576722 – 07/01/2019 | FDA

    https://www.fda.gov/inspections-compliance-enforcement-and-criminal-investigations/warning-letters/strides-pharma-science-limited-576722-07012019 4/5

    Your quality system does not adequately ensure the accuracy and integrity of data to support the safety, effectiveness, and
    quality of the drugs you manufacture. See FDA’s guidance document Data Integrity and Compliance With Drug CGMP
    for guidance on establishing and following CGMP-compliant data integrity practices
    at https://www.fda.gov/downloads/Drugs/GuidanceComplianceRegulatoryInformation/Guidances/UCM495891.pdf
    (h�ps://www.fda.gov/downloads/Drugs/GuidanceComplianceRegulatoryInforma�on/Guidances/UCM495891.pdf)

    We strongly recommend that you retain a qualified consultant to assist in your remediation.

    In response to this letter, provide the following:

    A. An assessment of the extent of data integrity deficiencies at your facility. Identify omissions, alterations, deletions,
    record destruction, non-contemporaneous record completion, and other deficiencies. Describe all parts of your
    facility’s operations in which you discovered data integrity lapses.

    B. A current risk assessment of the potential effects of the observed failures on the quality of your drugs. Your
    assessment should include analyses of the risks to patients caused by the release of drugs affected by a lapse of data
    integrity and analyses of the risks posed by ongoing operations.

    C. A management strategy for your firm that includes the details of your global corrective action and preventive action
    plan. The detailed corrective action plan should describe how you intend to ensure the reliability and completeness
    of all data generated by your firm, including microbiological and analytical data, manufacturing records, and all
    data submitted to FDA.

    Conclusion
    Violations cited in this letter are not intended as an all-inclusive list. You are responsible for investigating these
    violations, for determining the causes, for preventing their recurrence, and for preventing other violations in all your
    facilities.
    If you are considering an action that is likely to lead to a disruption in the supply of drugs produced at your facility, FDA
    requests that you contact CDER’s Drug Shortages Staff immediately, at drugshortages@fda.hhs.gov, so that FDA can
    work with you on the most effective way to bring your operations into compliance with the law. Contacting the Drug
    Shortages Staff also allows you to meet any obligations you may have to report discontinuances or interruptions in your
    drug manufacture under 21 U.S.C. 356C(b) and allows FDA to consider, as soon as possible, what actions, if any, may be
    needed to avoid shortages and protect the health of patients who depend on your products.
    Until you correct all violations completely and we confirm your compliance with CGMP, FDA may withhold approval of
    any new applications or supplements listing your firm as a drug manufacturer.
    Failure to correct these violations may also result in FDA refusing admission of articles manufactured at Strides Pharma
    Science Limited, FEI 3012448465, at Unit-II, R. S. No.: 32, 33 & 34 PIMS Road Periyakalapet, Puducherry into the
    United States under section 801(a)(3) of the FD&C Act, 21 U.S.C. 381(a)(3). Under the same authority, articles may be
    subject to refusal of admission, in that the methods and controls used in their manufacture do not appear to conform to
    CGMP within the meaning of section 501(a)(2)(B) of the FD&C Act, 21 U.S.C. 351(a)(2)(B).
    After you receive this letter, respond to this office in writing within 15 working days. Specify what you have done since
    our inspection to correct your violations and to prevent their recurrence. If you cannot complete corrective actions within
    15 working days, state your reasons for delay and your schedule for completion.
    Send your electronic reply to CDER-OC-OMQ-Communications@fda.hhs.gov (mailto:CDER-OC-OMQ-

    Communica�ons@fda.hhs.gov) or mail your reply to:

    Carla Norris

    Compliance Officer

    [https://www.fda.gov/downloads/Drugs/GuidanceComplianceRegulatoryInformation/Guidances/UCM495891.pdf](https://www.fda.gov/downloads/Drugs/GuidanceComplianceRegulatoryInformation/Guidances/UCM495891.pdf)

    [mailto:CDER-OC-OMQ-Communications@fda.hhs.gov](mailto:CDER-OC-OMQ-Communications@fda.hhs.gov)

    1/12/2020 Strides Pharma Science Limited – 576722 – 07/01/2019 | FDA

    https://www.fda.gov/inspections-compliance-enforcement-and-criminal-investigations/warning-letters/strides-pharma-science-limited-576722-07012019 5/5

    U.S. Food and Drug Administration

    White Oak Building 51, Room 4359

    10903 New Hampshire Avenue

    Silver Spring, MD 20993

    USA

    Please identify your response with FEI 3012448465.

    Sincerely,

    /S/

    Francis Godwin

    Director

    Office of Manufacturing Quality

    Office of Compliance

    Center for Drug Evaluation and Research

    cc:
    Mr. Umesh Kale
    President & Chief Quality Officer

    Strides Pharma Science Limited

    Strides House, Bilekahalli

    Bannerghatta Road

    Bangalore 560076

    India

     More Warning Letters (/inspections-compliance-enforcement-and-criminal-investigations/compliance-actions-and-activities/warning-letters)

    [https://www.fda.gov/inspections-compliance-enforcement-and-criminal-investigations/compliance-actions-and-activities/warning-letters](https://www.fda.gov/inspections-compliance-enforcement-and-criminal-investigations/compliance-actions-and-activities/warning-letters)

    **GRLR-HomeworkAssignment2-supportingdocument-2022FDAOutofSpecificationguidance.pdf**

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  • [Solved] Education Unit 5 EDU 769 Discussion 1 and Reading Assignments ( Please Read Attached File)

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    Unit 5 – _Human Resources for School Leaders: 11 Steps to Utilizing HR to Improve Student Learning_ – Chapter 7 _,_ The Role of Assessing Teaching and Learning in Promoting Organizational Change – Chapter 8, Methods and Value of Assessing Teaching and Learning Processes for Professional Growth – Scr…

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    Unit 5
    – _Human Resources for School Leaders: 11 Steps to Utilizing HR to Improve Student Learning_
    – Chapter 7 _,_ The Role of Assessing Teaching and Learning in Promoting Organizational Change
    – Chapter 8, Methods and Value of Assessing Teaching and Learning Processes for Professional Growth
    – Scriptures
    – Romans 12: 6-8
    – Colossians 3: 23-24
    ## Unit 5: Discussion Question 1
    **Discussion Questions:** Post your initial responses to the discussion forum by Wednesday 11:59 p.m. and respond to the discussion of others by Saturday 11:59 p.m.
    – **Discussion Question 1** _(10 points)_
    – Prompt: Discuss the teacher evaluation process at your school. What are the pros and cons of the evaluation process and documents? Use information from Chapter 8 of _Human Resources for School Leaders: 11 Steps to Utilizing HR to Improve Student Learning_ to identify 2-3 ways to improve the implementation or use of the teacher evaluation system in your district/school.
    – Requirements: Initial discussion question responses must be 250 – 300 words each. A response to a classmate must be at least 100 words. Three responses to classmates’ postings are required.
    \
    Screenshot2025-09-16172031.png](https://www.sweetstudy.com/files/screenshot2025-09-16172031-png "Screenshot2025-09-16172031.png")

  • [Solved] catherine owens 500 picot

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    In-depth study guidance and analytical solution covering catherine owens 500 picot.

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    Full assignment prompt and step-by-step guidance are included in the downloadable solution file.

  • [Solved] Case Study

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    – ## CaseStudy.docx **## CaseStudy.docx** **3 pages Do not go over. Due 9/18/2025** **Use intext citations and open access references** **Case Study** This assignment is aimed at examining an ethical situation that you may have experienced or know about related to your field of work. Create your own…

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    – ## CaseStudy.docx

    **## CaseStudy.docx**

    **3 pages Do not go over. Due 9/18/2025**

    **Use intext citations and open access references**

    **Case Study**

    This assignment is aimed at examining an ethical situation that you may have experienced or know about related to your field of work. Create your own ethical case study based on your experiences and readings.  Choose a topic or issue related to your professional field of work or profession. Consider topics related to the organizational work setting for this paper.  In your paper, include the following:

    ·
    Introduction: research the literature on ethics and leadership and provide a definition and need for ethics in an organization:

    ·
    Rationale for the case study:

    · Describe the reason for the case that you present (
    _Why is the topic relevant? How does it expand or contribute to a leader’s knowledge about ethics?_). Document your comments with appropriate related references.

    ·
    Case study: Provide a narrative with the case study topic that you identified. Include the following:

    ·
    **Setting:** Briefly describe the setting

    ·
    **Situation**: Describe the situation.

    ·
    **Impact:** State how it affects the organization and who or what is impacted. State whether the situation affects people inside or outside the organization.
    If the situation is from your own organization, be sure to use pseudonyms to maintain confidentiality at all times.

    ·
    Ethical stance or position: clearly describe why the case/situation poses an ethical challenge for an organization.

    ·
    References: Use appropriate documentation to support your narrative.

    ·
    Handout: Provide a one-page handout summarizing the case. Include as an appendix to your paper.

    Use this scenario and rewrite it according to the above outline.

    The ethical dilemma of a hidden tool

    As a prison maintenance technician, I was replacing a corroded pipe in a laundry room that is accessible to inmates. Following the facility's strict security procedures, I conducted a thorough inventory of the tools before and after the job. The inventory was logged and verified by a correctional officer.

    Later that day, while doing a final check of the work area, I found a small, heavy-duty screwdriver that was accidentally left behind, wedged tightly in a crevice behind a washing machine. I was alone, and no inmates were in the laundry room at the moment.

    I was faced with a serious ethical choice with multiple conflicting duties:

    · Duty to security and safety: I knew that losing track of a tool, especially one that could be used as a weapon, was a severe security breach that puts staff and other inmates at risk. Reporting the incident would ensure that it was documented and all relevant procedures were reviewed to prevent future occurrences.

    · Duty to personal integrity: Admitting to the mistake meant facing disciplinary action, potential job loss, or being labeled unreliable in a high-security environment. As the technician, I could simply re-secure the tool and say nothing, hoping no one ever finds out.

    · Duty to procedure: The official tool inventory has already been signed and recorded as correct, so reporting the finding would require backtracking and potentially implicate the supervising officer as well.

    Possible courses of action and their ethical considerations

    Report the missing tool immediately.

    · Ethical justification: Prioritizes the safety and security of the facility and its personnel. It is the honest and transparent course of action, upholding professional integrity and the strict codes of conduct required in a correctional environment.

    · Consequences: The technician would face discipline, which could range from a verbal warning to termination. It could also lead to additional security checks and a review of protocols.

    Re-secure the tool and say nothing.

    · Ethical justification: Avoids personal and professional repercussions. From a narrow, self-interested perspective, this might seem like the "right" choice to preserve one's career.

    · Consequences: This action is a severe breach of professional conduct and potentially criminal negligence. If the tool is later found or used by an inmate, the technician could be held responsible for any harm caused. It also creates a personal liability and the constant anxiety of being found out.

    The resolution

    The most ethical choice for me was to report the incident immediately to my supervisor, despite the personal consequences. The risk to human life and the security of the facility outweighs any concerns about career repercussions. Many correctional facilities provide ethics training to help employees handle these exact situations. This type of training emphasizes the importance of safety and accountability in high-risk environments.

    **## CaseStudy.docx**

    **3 pages Do not go over. Due 9/18/2025**

    **Use intext citations and open access references**

    **Case Study**

    This assignment is aimed at examining an ethical situation that you may have experienced or know about related to your field of work. Create your own ethical case study based on your experiences and readings.  Choose a topic or issue related to your professional field of work or profession. Consider topics related to the organizational work setting for this paper.  In your paper, include the following:

    ·
    Introduction: research the literature on ethics and leadership and provide a definition and need for ethics in an organization:

    ·
    Rationale for the case study:

    · Describe the reason for the case that you present (
    _Why is the topic relevant? How does it expand or contribute to a leader’s knowledge about ethics?_). Document your comments with appropriate related references.

    ·
    Case study: Provide a narrative with the case study topic that you identified. Include the following:

    ·
    **Setting:** Briefly describe the setting

    ·
    **Situation**: Describe the situation.

    ·
    **Impact:** State how it affects the organization and who or what is impacted. State whether the situation affects people inside or outside the organization.
    If the situation is from your own organization, be sure to use pseudonyms to maintain confidentiality at all times.

    ·
    Ethical stance or position: clearly describe why the case/situation poses an ethical challenge for an organization.

    ·
    References: Use appropriate documentation to support your narrative.

    ·
    Handout: Provide a one-page handout summarizing the case. Include as an appendix to your paper.

    Use this scenario and rewrite it according to the above outline.

    The ethical dilemma of a hidden tool

    As a prison maintenance technician, I was replacing a corroded pipe in a laundry room that is accessible to inmates. Following the facility's strict security procedures, I conducted a thorough inventory of the tools before and after the job. The inventory was logged and verified by a correctional officer.

    Later that day, while doing a final check of the work area, I found a small, heavy-duty screwdriver that was accidentally left behind, wedged tightly in a crevice behind a washing machine. I was alone, and no inmates were in the laundry room at the moment.

    I was faced with a serious ethical choice with multiple conflicting duties:

    · Duty to security and safety: I knew that losing track of a tool, especially one that could be used as a weapon, was a severe security breach that puts staff and other inmates at risk. Reporting the incident would ensure that it was documented and all relevant procedures were reviewed to prevent future occurrences.

    · Duty to personal integrity: Admitting to the mistake meant facing disciplinary action, potential job loss, or being labeled unreliable in a high-security environment. As the technician, I could simply re-secure the tool and say nothing, hoping no one ever finds out.

    · Duty to procedure: The official tool inventory has already been signed and recorded as correct, so reporting the finding would require backtracking and potentially implicate the supervising officer as well.

    Possible courses of action and their ethical considerations

    Report the missing tool immediately.

    · Ethical justification: Prioritizes the safety and security of the facility and its personnel. It is the honest and transparent course of action, upholding professional integrity and the strict codes of conduct required in a correctional environment.

    · Consequences: The technician would face discipline, which could range from a verbal warning to termination. It could also lead to additional security checks and a review of protocols.

    Re-secure the tool and say nothing.

    · Ethical justification: Avoids personal and professional repercussions. From a narrow, self-interested perspective, this might seem like the "right" choice to preserve one's career.

    · Consequences: This action is a severe breach of professional conduct and potentially criminal negligence. If the tool is later found or used by an inmate, the technician could be held responsible for any harm caused. It also creates a personal liability and the constant anxiety of being found out.

    The resolution

    The most ethical choice for me was to report the incident immediately to my supervisor, despite the personal consequences. The risk to human life and the security of the facility outweighs any concerns about career repercussions. Many correctional facilities provide ethics training to help employees handle these exact situations. This type of training emphasizes the importance of safety and accountability in high-risk environments.

  • [Solved] MGT 608 Week Four discussion post 1 question. Your initial post should be roughly 150 words in length. Cite sources you reference in-text and under a “References” section in APA format

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    – ## WeekFourdiscussionpost1HM.docx **## WeekFourdiscussionpost1HM.docx** Week FOUR discussion post 1 [**Discussion 8: Define Supply Chain Management**](https://nationalu.brightspace.com/d2l/le/120512/discussions/topics/449522/View) Must post first. **Instructions** Since you have spent the past fou…

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    – ## WeekFourdiscussionpost1HM.docx

    **## WeekFourdiscussionpost1HM.docx**

    Week FOUR discussion post 1

    [**Discussion 8: Define Supply Chain Management**](https://nationalu.brightspace.com/d2l/le/120512/discussions/topics/449522/View)

    Must post first.

    **Instructions**

    Since you have spent the past four weeks growing in your knowledge of Supply Chain Management, write a summary overview of what SCM is. Then, based on your interests, pick one of the concepts from our textbook, identify that concept in your post, and utilize additional learning to expound on that concept.

    Contributions must display original thinking and good knowledge of the subject matter, including links and references to sources to support your arguments. A minimum of three posts are required for each discussion (1 post and 2 replies). Additionally, make sure you cite sources you reference in-text and under a "References" section in APA format

    **## WeekFourdiscussionpost1HM.docx**

    Week FOUR discussion post 1

    [**Discussion 8: Define Supply Chain Management**](https://nationalu.brightspace.com/d2l/le/120512/discussions/topics/449522/View)

    Must post first.

    **Instructions**

    Since you have spent the past four weeks growing in your knowledge of Supply Chain Management, write a summary overview of what SCM is. Then, based on your interests, pick one of the concepts from our textbook, identify that concept in your post, and utilize additional learning to expound on that concept.

    Contributions must display original thinking and good knowledge of the subject matter, including links and references to sources to support your arguments. A minimum of three posts are required for each discussion (1 post and 2 replies). Additionally, make sure you cite sources you reference in-text and under a "References" section in APA format

  • [Solved] MGT 608 Week Four discussion post 2 question. Your initial post should be roughly 150 words in length. Cite sources you reference in-text and under a “References” section in APA format

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    – ## WeekFourdiscussionpost2HM.docx **## WeekFourdiscussionpost2HM.docx** Week FOUR discussion post 1 LINK TO BOOK: [https://bookshelf.vitalsource.com/reader/books/9781394217328/epubcfi/6/2[%3Bvnd.vst.idref%3DAcover]!/4](https://bookshelf.vitalsource.com/reader/books/9781394217328/epubcfi/6/2%5b%3…

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    Assignment Prompt & Instructions

    – ## WeekFourdiscussionpost2HM.docx

    **## WeekFourdiscussionpost2HM.docx**

    Week FOUR discussion post 1

    LINK TO BOOK:
    [https://bookshelf.vitalsource.com/reader/books/9781394217328/epubcfi/6/2[%3Bvnd.vst.idref%3DAcover]!/4](https://bookshelf.vitalsource.com/reader/books/9781394217328/epubcfi/6/2%5b%3Bvnd.vst.idref%3DAcover%5d!/4) (I will send username and password separately in message).

    [**Discussion 8: Define Supply Chain Management**](https://nationalu.brightspace.com/d2l/le/120512/discussions/topics/449522/View)

    Must post first.

    **Instructions**

    Since you have spent the past four weeks growing in your knowledge of Supply Chain Management, write a summary overview of what SCM is. Then, based on your interests, pick one of the concepts from our textbook, identify that concept in your post, and utilize additional learning to expound on that concept.

    Contributions must display original thinking and good knowledge of the subject matter, including links and references to sources to support your arguments. Additionally, make sure you cite sources you reference in-text and under a "References" section in APA format.

    **## WeekFourdiscussionpost2HM.docx**

    Week FOUR discussion post 1

    LINK TO BOOK:
    [https://bookshelf.vitalsource.com/reader/books/9781394217328/epubcfi/6/2[%3Bvnd.vst.idref%3DAcover]!/4](https://bookshelf.vitalsource.com/reader/books/9781394217328/epubcfi/6/2%5b%3Bvnd.vst.idref%3DAcover%5d!/4) (I will send username and password separately in message).

    [**Discussion 8: Define Supply Chain Management**](https://nationalu.brightspace.com/d2l/le/120512/discussions/topics/449522/View)

    Must post first.

    **Instructions**

    Since you have spent the past four weeks growing in your knowledge of Supply Chain Management, write a summary overview of what SCM is. Then, based on your interests, pick one of the concepts from our textbook, identify that concept in your post, and utilize additional learning to expound on that concept.

    Contributions must display original thinking and good knowledge of the subject matter, including links and references to sources to support your arguments. Additionally, make sure you cite sources you reference in-text and under a "References" section in APA format.

  • [Solved] MM556 DB 3

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    In-depth study guidance and analytical solution covering MM556 DB 3.

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