INSPECTIONAL OBSERVATIONS - Forest/Inwood Laboratories, Inc.

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ATTACHMENT #4

DEPARTMENT OF HEALTH AND HUMAN SERVICES

PUBLIC HEALTH SERVICE

FOOD AND DRUG ADMINISTRATION

850 Third Ave

Brooklyn, NY 11232

718/340-7000

NAME OF INDIVIDUAL TO WHOM REPORT ISSUED

Timothy Getek, Ph.D.

PERIOD OF INSPECTION

10/5 … 23/98

C. F. NUMBER

24-36921

TITLE OF INDIVIDUAL

Associate Director Bioanalytical Lab.

TYPE ESTABLISHMENT INSPECTED

Bioanalytical Lab

FIRM NAME

Forest/Inwood Laboratories, Inc.

NAME OF FIRM. BRANCH OR UNIT INSPECTED

Same

STREET ADDRESS

220 Sea Lane

STREET ADDRESS OF PREMISES INSPECTED

Same

CITY AND STATE (Zip Code)

Farmingdale, NY 11735

CITY AND STATE (Zip Code)

Same

DURING AN INSPECTION OF YOUR FIRM (I) (WE) OBSERVED:

Observations were made regarding studies XXXX R/5000/001, FLU-PK-03-000

(Rimantadine), and R/1700/004 (Isosorbide Dinitrate).

1. The SOP #F-001 entitled "Analytical Run Acceptance Criteria" is not objective in

that it permits calibration standards to be deleted so that quality control (QC) value

will fall within the acceptable limits. Examples include:

a) XXXX Stock Solution Stability: Run

b) XXXX Runs XXXX

2. SOP #F-001 permits calculation of accuracy of QCs using the validated QC value

as the true value, rather than using the theoretical value. Calculation of accuracy

using the theoretical value as the true value would result in the majority of QCs not

meeting the acceptance criteria in about 50% of the analytical runs for XXXX and XXXX.

3. The reported assay precision in the analytical runs was not accurate because the

precision analysis did not include the standards and QCs which failed to meet the

acceptance criteria. For example, inclusion of all standard values in XXXX

increased the coefficient of variation (CV) for XXXX (from 2.5 -

10.2% to 2.5-15.5%) and for XXXX (from 2.5-9.8% to 2.5-12.0%).

Similarly, inclusion of all standard ,values in XXXX increased the CV

for XXXX (from 3.6 - 9.6% to 3.6 -18.3%) and XXXX (from 2.2 -

8.0% to 2.2 - 21.9%).

SEE REVERSE OF THIS PAGE

EMPLOYEE(S) SIGNATURE

EMPLOYEE(S) NAME AND TITLE (Print or Type)

Lawrence Farina, Investigator

Gary Lehr, Chemist

DATE ISSUED

10/23/98

FORM FDA 483 (5/95) PREVIOUS EDITION MAY BE USED.

INSPECTIONAL OBSERVATIONS … PAGE 1 OF 6 PAGES

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