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Circumstances that Constitute Delaying, Denying, Limiting, or Refusing a Drug or Device Inspection: Guidance for Industry

FinalOffice of Inspections and Investigations Center for Drug Evaluation and Research Center for Biologics Evaluation and Research Center for Veterinary Medicine Center for Devices and Radiological Health06/20/2024

Description

On July 9, 2012, the Food and Drug Administration Safety and Innovation Act (FDASIA) (Public Law 112-144) was signed into law. Section 707 of FDASIA added section 501(j) to the Federal Food, Drug, and Cosmetic Act (FD&C Act) to deem adulterated a drug that “has been manufactured, processed, packed, or held in any factory, warehouse, or establishment and the owner, operator, or agent of such factory, warehouse, or establishment delays, denies, or limits an inspection, or refuses to permit entry or inspection.” Section 707(b) of FDASIA required the Food and Drug Administration (FDA) to issue guidance that defined the circumstances that would constitute delaying, denying, or limiting inspection, or refusing to permit entry or inspection, for purposes of section 501(j).

Scope & Applicability

Product Classes

4
Drug

Defined in section 201(g) of the FD&C Act; Articles intended for use in diagnosis, cure, mitigation, treatment, or prevention of disease; Product classification based on chemical action or specific intended uses like altering pH

Device

Defined in section 201(h) of the FD&C Act; Instrument or apparatus which does not achieve primary purpose through chemical action; Product classification based on primary intended purpose and chemical action

Prescription drugs

Subject to inspection authority

Restricted devices

Subject to inspection authority

Stakeholders

6
FDA Investigator

Authorized representative conducting the inspection

Owner

Person whose actions may cause a product to be deemed adulterated

Operator

Person whose actions may cause a product to be deemed adulterated

Agent

Person whose actions may cause a product to be deemed adulterated

Outsourcing facilities

Facilities compounding drug products pursuant to section 503B.

U.S. agent

Representative of a foreign owner who serves as the FSVP importer; Person in the US acting as a communications link or FSVP representative.; Designated representative for foreign owners; designated representative for foreign owners

Regulatory Context

Attributes

1
Reasonable timeframe

Standard for providing records to FDA

Related CFR Sections (1)

Related Warning Letters (10)

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    Darmerica, LLC

    2025-12-23
  • OTC/Unapproved New Drug/Misbranded

    Supergoop!

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  • OTC/Unapproved New Drug/Misbranded

    K & Care Organics

    2025-08-12
  • OTC/Unapproved New Drug/Misbranded

    Fallien Cosmeceuticals Ltd. dba Fallene Ltd.

    2025-08-12
  • Failure to List/Misbranded

    Shenzhen Hengkaifeng Commerce and Trade Co., Ltd

    2025-05-27
  • Electronic Drug Registration and Listing System (eDRLS)/Violations

    Prodose, Inc. formerly known as Spirit Pharmaceuticals LLC

    2025-04-29
  • CGMP/Finished Pharmaceutical/Adulterated

    Jagsonpal Pharmaceuticals Limited

    2025-02-18
  • CGMP/Finished Pharmaceuticals/Adulterated/Misbranded/Failure to Register

    Omni Lens Pvt. Ltd.

    2024-10-22
  • Failure to Register and List

    Media Networks Sydney Pty Limited

    2024-08-20
  • Failure to Register and List

    Zen Enterprises LLC

    2024-04-23

See Also (8)