Category: Uncategorized

Design Controls for Combination Products: The Most Common Compliance Gap

Posted on by Brandon Miller

Why Design Controls Matter for Combination Products

Design controls represent one of the most significant regulatory challenges for companies entering the combination product market, especially those with a pharmaceutical or biologics background.

 

Key Regulatory Frameworks Involved

Pharma companies are well-versed in process validation under GMPs (21 CFR Part 210/211). However, combination products that include a device component require adherence to device regulations under 21 CFR Part 820, which mandates design controls.

 

What’s Required Under Design Controls?

Design controls involve structured development planning and documentation, including:

  • Design and development planning
  • User needs and design inputs
  • Design outputs and verification
  • Design validation (often including human factors/usability testing)
  • Design transfer
  • Design history files (DHF)

 

The Importance of Human Factors and Validation Testing

These are not just technicalities—they’re critical quality elements the FDA uses to determine whether a product will perform as intended when used by real patients. One of the most commonly misunderstood areas is design validation, which often requires human factors testing to confirm that the user can safely and effectively operate the device component.

 

How to Integrate Design Controls into a Pharma QMS

For many drug companies, integrating these design requirements means:

  • Creating new SOPs for design and development
  • Training teams on device regulations
  • Hiring or consulting with medical device experts

 

Get Help From Combination Product Experts

RCA offers deep expertise in integrating design controls into pharmaceutical systems. Whether you need support with SOP development, training, or validation planning, RCA is here to help. Contact us today to learn more.

Avoiding Common 503B GMP Deficiencies: Key Lessons from FDA Warning Letters

Posted on by Brandon Miller

503B outsourcing facilities play a critical role in addressing drug shortages and providing large-scale compounded medications. However, with this privilege comes the responsibility of adhering to stringent FDA regulations under Current Good Manufacturing Practices (CGMP). Repeated violations can lead to FDA warning letters, product recalls, and even shutdowns. Understanding common pitfalls is essential for maintaining compliance and ensuring patient safety.

 

In this blog, we examine some of the most frequent deficiencies cited in FDA warning letters to 503B facilities and how you can proactively prevent them.

 

Inadequate Aseptic Processing Controls

A recurring theme in FDA inspections is the failure to maintain proper aseptic technique and conditions. This includes:

  • Inadequate aseptic employee techniques
  • Improper personnel gowning and behavior
  • Poor cleanroom design and maintenance
  • Inadequate airflow and HEPA filter placement
  • Insufficient monitoring of environmental conditions
  • Poor cleaning, disinfection and sanitation controls

How to Avoid: Conduct a comprehensive GMP review of your aseptic processes, validate cleanroom performance, and implement rigorous training for all personnel involved in sterile compounding.

 

Deficient Environmental Monitoring Programs

Many facilities fall short in establishing adequate environmental monitoring (EM) protocols. Common issues include:

  • Irregular or infrequent sampling
  • Lack of meaningful trending and analysis
  • Delayed response to out-of-specification (OOS), alert and action results
  • Insufficient timely corrective actions

How to Avoid: Develop a robust EM and PM program that includes real-time data collection, regular review of trends, and timely corrective actions. Use EM data as a proactive quality tool, not just a compliance checkbox.

 

Incomplete or Inaccurate Documentation

Documentation is the backbone of GMP compliance. FDA has consistently cited 503B facilities for:

  • Missing batch records, incomplete entries and poor GDPs
  • Failure of thorough and timely deviations and investigations
  • Lack of CAPAs
  • Lack of traceability in production processes

How to Avoid: Enforce strict documentation procedures and requirements. Ensure all entries are legible, contemporaneous, original, accurate and reviewed regularly by quality assurance experts. Implement validated electronic systems where feasible to reduce human error.

 

Insufficient Process Validation

Many 503B facilities do not adequately validate their compounding processes. This includes:

  • Limited or no validation of sterile filtration and filling processes
  • Absence of complete media fill simulations
  • Failure to scientifically demonstrate repeatability and reliability of processes

How to Avoid: Develop and execute a thorough validation master plan (VMP) and perform validation studies. Conduct media fills under worst-case conditions and ensure all critical parameters are tested and documented and the facility is operating in a state of control.

 

Poor Quality Unit Oversight

The FDA expects a robust and independent quality unit (QU) to oversee all aspects of production. Common failures include:

  • QU lacking authority or involvement in decision-making
  • Quality responsibilities split among unqualified personnel
  • Inadequate review of batch records and investigations
  • Poor or incomplete quality SOPs

How to Avoid: Empower your quality unit with the necessary resources, training, and authority to act independently. Quality should not be siloed—it must be embedded into every layer of your operation.

 

Final Thoughts

503B outsourcing facilities operate under intense regulatory scrutiny, and for good reason: they are entrusted with producing high risk sterile medications on a large scale. By studying past deficiencies and strengthening internal systems, facilities can avoid the missteps that lead to enforcement actions.

 

Stay proactive, stay informed, and remember that compliance is not a one-time task—it’s an ongoing commitment to excellence.

 

Need help assessing your compliance and strengthening your quality systems? Contact RCA today to get expert guidance tailored to your facility’s needs.

 

New FDA Policy Targets Foreign Manufacturers with Unannounced Inspections

Posted on by Brandon Miller

On May 6, 2025, the U.S. Food and Drug Administration (FDA) announced it will expand its use of unannounced inspections at foreign manufacturing facilities. This shift is part of the FDA’s ongoing effort to strengthen oversight of imported medical products and food—bringing foreign inspection standards in line with domestic ones.

 

Read the official announcement from FDA →

 

Why the FDA Is Increasing Surprise Inspections Overseas

Historically, the FDA provided advance notice for most inspections of foreign manufacturers—sometimes weeks in advance. However, recent data showed that inspections with notice revealed significantly more compliance issues than domestic unannounced inspections, raising concerns about manipulated or concealed deficiencies.

 

Key drivers behind the FDA’s decision include:

  • Eliminating discrepancies between domestic and international inspection protocols
  • Reducing the opportunity for facility preparation or data alteration
  • Enhancing the agency’s ability to ensure products meet Good Manufacturing Practices (GMP) and regulatory expectations

 

What Foreign Manufacturers Need to Do to Stay Compliant

With little or no notice now expected before an FDA inspection, foreign manufacturers must shift to a “compliance-at-all-times” mindset. The cost of being unprepared—especially for those exporting to the U.S.—can include 483 observations, import alerts, or refusal of entry.

 

Key Compliance Steps to Take Immediately:

  • Conduct internal GMP audits to ensure systems and records meet FDA standards
  • Implement mock FDA inspections to simulate surprise visits and train teams
  • Ensure quality documentation is inspection-ready at all times
  • Reinforce data integrity practices to prevent any sign of manipulation or lack of transparency

 

Why Inspection Readiness Is Now a Competitive Advantage

In a regulatory environment that rewards transparency and punishes delay, having a proactive inspection strategy isn’t just about risk management—it’s about business continuity and market access.

Companies that are prepared can:

  • Respond calmly and accurately under pressure
  • Avoid regulatory delays or costly disruptions
  • Strengthen their global reputation for compliance

 

How RCA Helps You Prepare for Unannounced FDA Inspections

At Regulatory Compliance Associates (RCA), we partner with life science companies around the globe to ensure they’re inspection-ready at all times. Our experts include former FDA and industry professionals who know exactly what investigators look for.

 

RCA’s Inspection Readiness Services Include:

  • GMP gap assessments for foreign and domestic facilities
  • Mock FDA inspections tailored to your operations and risk profile
  • Data integrity reviews to uncover hidden vulnerabilities
  • On-site training for regulatory inspection best practices
  • Real-time inspection support from regulatory experts

Whether you’re a pharmaceutical manufacturer, medical device producer, food supplier, or combination product company, RCA helps you transform unannounced inspections from a threat into a strategic differentiator.

 

Medical Device Compliance Training & Inspection Readiness

Pharmaceutical Compliance Training & Inspection Readiness

 

Don’t Let a Surprise Inspection Derail Your U.S. Market Access

The FDA’s expanded authority to conduct unannounced inspections is a clear signal: global compliance expectations are rising. Companies that adapt quickly will thrive—those that don’t may find themselves locked out of critical markets.

 

Partner with RCA today to prepare your facility for unannounced inspections. We’ll help you stay compliant, inspection-ready, and confident—no matter when the FDA arrives.

 

Use the contact us form below to get started now.

 

Preparing for a successful FDA Inspection as a 503B Facility

Posted on by Brandon Miller

FDA inspections are a pivotal moment for any 503B outsourcing facility. Unlike 503A pharmacies, which are primarily state-regulated, 503B facilities are held to Current Good Manufacturing Practices (CGMP) 21 CRF 210 & 211 and regularly inspected by the FDA. A successful inspection can bolster a facility’s credibility and market reach, while a failed one can lead to warning letters, product recalls, or even facility shutdowns.

 

In this blog, we’ll explore what 503B facilities need to know to prepare for FDA inspections, highlight common deficiencies, and offer proactive strategies for maintaining a state of readiness.

 

Understanding the Scope of an FDA Inspection

FDA inspections for 503B facilities are extensive and focus on compliance with 21 CFR Part 210 & 211 and (CGMP regulations). These inspections may include:

  • Quality assurance and management systems
  • Facility walkthroughs and evaluation of environmental controls
  • Review of data integrity, batch records and standard operating procedures (SOPs)
  • Personnel training and gowning practices
  • Validation of equipment, processes, and cleaning procedures
  • Microbiological monitoring and contamination control
  • Supplier qualification, to name a few

The FDA typically provides little to no advance notice before an inspection, making inspection readiness essential.

 

Common Deficiencies Cited During Inspections

Over the years, the FDA has issued numerous, FDA 483 observations and warning letters to 503B facilities. Common issues include:

  • Inadequate aseptic processing controls
  • Lack of testing for sterile product lines
  • Lack of facility and clean room qualifications
  • Failure to validate sterilization methods
  • Poor data integrity and documentation practices
  • Incomplete environmental monitoring and poor processing environments
  • Lack of proper cleaning validation
  • Deficient complaint handling procedures

These deficiencies not only put patient safety at risk but also threaten the operational viability of the facility and increases drug shortages.

 

How to Prepare: A Strategic Framework

Preparation for FDA inspections should be built into the daily operations of a 503B facility. Here’s a structured approach:

  1. Conduct thorough internal audits and mock FDA audits: Simulate inspections to uncover gaps and train staff on inspection etiquette.
  2. Develop and Maintain Robust SOPs: Ensure SOPs are comprehensive, current, and implemented consistently.
  3. Validate: Equipment, processes, cleaning, and software systems must all be validated.
  4. Implement a Quality Management System (QMS): An effective QMS enables tracking of deviations, CAPAs, and change controls.
  5. Train Continuously: Ensure all employees understand their roles and responsibilities during an FDA inspection.
  6. Establish a Quality Culture: As example, for documentation, emphasize accuracy, completeness, and timeliness in all record-keeping activities.

Implementing a Culture of Compliance

Compliance should not be a one-time event tied to inspections—it should be embedded in the culture and the sites pharmaceutical quality system. Facilities that embrace continuous improvement, routine internal audits, and proactive risk management are better positioned to pass FDA inspections.

 

Leadership buy-in is critical. Management must support compliance initiatives with adequate resources, staff training, and a clear vision for quality excellence.

 

Final Thoughts

Preparing for an FDA inspection is a multifaceted process which requires ongoing commitment, attention to detail, and a strong quality mindset. By building a robust quality system and fostering a compliance-driven quality culture, facilities can not only pass inspections but thrive in a competitive and regulated environment.

 

Need help preparing for your next FDA inspection? Contact RCA today to get expert support from seasoned professionals who understand the intricacies of 503B compliance.

 

Navigating the 503A vs. 503B Divide: What Compounding Pharmacies Need to Know

Posted on by Brandon Miller

The compounding pharmacy industry plays a critical role in modern healthcare by offering personalized medication solutions that mass manufacturers often cannot provide. But with this important role comes a complex and evolving regulatory landscape. For compounding pharmacies, understanding the distinction between 503A and 503B facilities is essential for ensuring compliance and sustainable operation.

 

In this blog, we’ll break down the key differences between 503A and 503B compounders, the unique regulatory frameworks governing each, and what pharmacies need to consider if they are operating or transitioning within this space.

 

What Are 503A and 503B Facilities?

Under the Drug Quality and Security Act (DQSA) of 2013, compounding pharmacies are categorized into two types:

  • 503A Compounding Pharmacies: These facilities prepare medications based on individual patient prescriptions. They are primarily regulated by state boards of pharmacy and must comply with the standards set forth in the United States Pharmacopeia (USP), such as USP <797> for sterile compounding.
  • 503B Outsourcing Facilities: These facilities can produce larger batches of medications, often without patient-specific prescriptions, and distribute them across state lines. They are regulated by the FDA and must comply with Current Good Manufacturing Practices (CGMPs) under 21 CFR Part 211.

 

Key Differences Between 503A and 503B

Feature

503A

503B

Prescription Requirement

Required for each compounded medication

Not required for every unit; can produce in bulk

Manufacturing Standards

USP Guidelines

CGMP (21 CFR 211)

Inspection Frequency

= state-driven

Risk-based FDA inspections

Distribution

Intrastate (usually)

Interstate distribution allowed

 

Why the Distinction Matters

The need for stricter oversight of compounding facilities came to the forefront following the 2012 fungal meningitis outbreak traced to the New England Compounding Center. This public health tragedy, which resulted in over 100 deaths, highlighted the dangers of unregulated mass production in pharmacy settings and prompted federal reforms that created the 503B outsourcing facility category.

 

Today, the 503A vs. 503B divide is more than a regulatory technicality—it’s a fundamental distinction that impacts a facility’s operations, compliance burden, and market reach.

 

Challenges and Considerations for Compounders

Pharmacies considering a transition from 503A to 503B status must be prepared for a significant shift in operational complexity and GMP compliance requirements. This includes:

  • Building and validating cleanroom environments
  • Implementing full-scale environmental and personnel monitoring programs
  • Data Integrity and GDP requirements
  • Complaint handling system and recalls
  • Conducting process validation and product stability studies
  • Cleaning validation studies
  • Establishing robust quality management systems (QMS)
  • Preparing for FDA inspections and potential 483 observations

Many 503B facilities also struggle with aseptic processing controls, supplier qualification programs, and adequate documentation practices—common areas cited in FDA warning letters.

 

Strategic Advice for Compounders

Whether you’re an established 503A pharmacy or considering expansion into 503B territory, here are key recommendations:

  1. Perform a Proactive Gap Assessment: Understand where your current operations fall short of 503B standards.
  2. Inspection Readiness
  3. Invest in Expertise: Consider partnering with consultants who specialize in regulatory compliance and quality systems.
  4. Stay Informed: Keep up with FDA guidance, warning letters, and industry trends.
  5. Prioritize Training and Documentation: Ensure your team is well-trained and your processes are clearly documented.
  6. Plan for Long-Term Compliance: Adopt a continuous improvement mindset to meet evolving expectations.

 

Final Thoughts

The compounding pharmacy sector is under increasing scrutiny, especially for those operating under 503B provisions. Understanding the distinctions and requirements between 503A and 503B categories is critical to maintaining compliance, avoiding regulatory pitfalls, and ultimately, delivering safe and effective medications to patients.

 

If you’re navigating this complex landscape, now is the time to evaluate your current state and plan strategically for the future. Compliance is no longer just about meeting minimum standards—it’s about building a foundation for long-term success. Contact RCA today to speak with our experts and get the guidance you need to stay compliant and competitive in the evolving compounding pharmacy landscape.

Understanding the Knowledge-Aided Assessment and Structured Application (KASA)

Posted on by Brandon Miller

As regulatory processes evolve, the Knowledge-Aided Assessment and Structured Application (KASA) system is set to transform FDA application reviews through automation and structured data analysis. Designed to enhance efficiency and consistency, KASA aims to supplement traditional narrative-based reviews with a data-driven approach to regulatory decision-making.

 

What is KASA?

KASA is a data-based review tool that will allow the FDA to assess the Quality portion of applications more effectively by leveraging structured data elements. This system is expected to provide standardized, automated quality risk assessments, helping streamline the evaluation of NDAs, ANDAs, and BLAs.

 

Potential Benefits of KASA

  • Improved Efficiency: Automates portions of the review process, reducing manual workload for FDA reviewers.
  • Enhanced Consistency: Establishes a standardized framework for application assessments and a collaborative multi-disciplinary review, minimizing variability in regulatory decisions.
  • Mitigation of Delays: May help counteract potential slowdowns due to FDA workforce reductions, ensuring timely reviews despite resource constraints.

 

Challenges and Uncertain Timeline

Although the FDA had scheduled a webinar to discuss KASA’s implementation, it was postponed until further notice due to recent administrative shifts. The future rollout of KASA will depend on FDA leadership priorities and resource allocation under the new administration.

 

What This Means for Industry Stakeholders

Companies submitting regulatory applications should stay informed about KASA developments. As the system moves forward, ensuring structured, well-organized data submissions will be crucial for efficient regulatory review processes.

 

While the timeline for KASA’s full implementation remains unclear, its eventual adoption promises a more streamlined, consistent, and technology-driven approach to FDA application reviews.

 

Stay Ahead with RCA

For expert guidance and tailored solutions in navigating complex FDA requirements, contact RCA today to secure compliance, streamline approvals, and achieve regulatory success with confidence.

 

To begin the Regulatory Compliance Associates scoping process today, please enter your information in the blue form below and click the submit button at the bottom of the webpage. You may also email us at [email protected].