DR 3 Southerncaliforniacompoundingpharmacyllc
DR 3 Southerncaliforniacompoundingpharmacyllc
OBSERVATION 1
Personnel and environmental monitoring conducted within the ISO 5 Environments on a (15) (4) frequency are
deficient.
Specifically, your firm does not perform growth promotion for each batch of media purchased or use a positive
control when conducting 6 4 gloved finger assessment and surface sampling. Your firm conducts gloved
fingertip test and surface sampling as part of the compounding personnel qualification.
OBSERVATION 2
Gowning and aseptic practices are deficient.
Specifically, during the aseptic operation for Rx# 15 6 on 7/10/19, we observed operator's head enter the
ISO 5 Laminar Airflow Workstation (LAFW) during aseptic operations with exposed skin on forehead and
cheeks. In addition, operator's skin was exposed at the ankle during aseptic operations and lower back skin was
exposed during 15 4 cleaning of the ISO 7 Buffer room.
OBSERVATION 3
The firm's cleaning and disinfecting procedure in the aseptic processing area are deficient.
Specifically,
Your firm uses non-sterile wipes sprayed with I (6) (4) to wipe components prior to introduction into the
ISO 5 Laminar Airflow Workstation (LAFW) and to clean ISO 5 LAFW counter top where the sterile drug
products are prepared. On 7/10/19, during sterile compounding of Rx #, (6) (6~;, operator was observed moving
items staged on the ISO 7 buffer room storage table to the ISO 5 LAFW without first sanitizing the items with
~ (b)(4)
In addition your finn utilizes the following non-sterile products to clean the ISO 5 LAFW:
(b) (4)
OBSERVATION 4
Smoke study conducted on 6/21/2019 to determine unidirectional airflows in ISO 5 LAFW was inadequate.
Specifically, the smoke study failed to adequately simulate dynamic conditions and did not provide adequate
coverage to demonstrate unidirectional air flow during routine operations. ISO 5 LAFW is where the finn
produces all its sterile drug products.
OBSERVATION 5
Laboratory controls do not include the establishment of scientifically sound and appropriate specifications,
sampling plans, and test procedures designed to assure drug products confonn to appropriate standards of identity,
strength, quality and purity.
Specifically, finished non-sterile drug products are not tested for the presence of microorganisms, for example:
Ketoprofen 20%/Lidocaine 10%, lot no. 07419K20L10A, submitted for l (6f(4] process validation sample did
not include a test for the presence of microorganisms.
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08/01/2019
FORM FDA 483 9/08 PREVIOl!fS EDITION OBSOLETE'---" INSPECTIONAL OBSERVATIONS Page 2 of2
The observations of objectionable conditions and practices listed on the front of this form
are reported:
1. Pursuant to Section 704(b) of the Federal Food, Drug and Cosmetic Act, or
2. To assist firms inspected in complying with the Acts and regulations enforced by the
Food and Drug Administration.
Section 704(b) of the Federal Food, Drug, and Cosmetic Act (21 USC 374(b)) provides: