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Small Entity Compliance Guide: Current Good Manufacturing Practice in Manufacturing, Packaging, Labeling, or Holding Operations for Dietary Supplements

FinalHuman Foods Program12/16/2010
Current Good Manufacturing PracticeQuality ControlCAPADS CGMP ruleProduction and Process Control SystemDS CGMP

Description

This guidance represents the Food and Drug Administration's (FDA's) current thinking on this topic. It does not create or confer any rights for or on any person and does not operate to bind FDA or the public. You can use an alternative approach if the approach satisfies the requirements of the applicable statutes and regulations.

Key Topics

Terms and concepts identified from this document

Scope & Applicability

Product Classes

3
Dietary Supplement

Products containing dietary ingredients intended to supplement the diet; The final product category for which the NDI is intended.

Botanical Dietary Supplement

Specific type of dietary supplement subject to the rule

Vitamin/Mineral Dietary Supplement

Specific type of dietary supplement subject to the rule

Stakeholders

10
Small Entity

Target audience for the compliance guide

Qualified Person

individual responsible for evaluating potential risks

Qualified Individuals

may participate in material review by providing analysis

Supplier

Facility supplying raw materials or ingredients; Facility providing raw materials to a manufacturer

Supervisor

Personnel assigned to ensure compliance by individuals with the requirements of part 121

Quality Control Personnel

Personnel responsible for review, approval, or rejection requirements; Responsible for reviewing and approving calibrations, controls, and documentation.; Individuals responsible for approving or rejecting processes and materials; responsible for material review and disposition decisions; Responsible for approving repackaging or relabeling; Quality control personnel conduct a material review and make a disposition decision.

Contractor

Contract acceptor for transportation of APIs

Manufacturer

Entity responsible for submitting NDINs

Retailer

Entity required to comply with cigarette warning requirements

Practitioner

Licensed individual who orders the use of the prescription device

Regulatory Context

Document Types

6
Master Manufacturing Record

ensure that the dietary supplement is packaged and labeled as specified in the master manufacturing record; Required documentation for manufacturing operations; Required documentation under Subpart H; Document specifying how the dietary supplement is to be packaged and labeled.; Specifies how dietary supplements are packaged and labeled; deviations from this record trigger material review; written record required for each unique formulation and batch size; Requirements for packaging and labels m

Electronic Records

Records in electronic form created or maintained under Agency regulations

Product Complaint

A qualified person review all product complaints.

Citizen Petition

Requesting sesame be regulated similarly to major food allergens

Batch Production Record

Records documenting the manufacturing of a batch

Certificate of Analysis

Document indicating analytical results of testing; record relied on to control L. monocytogenes in ingredients; document provided for a food prior to or upon receipt of the food; COA documentation

Attributes

3
Full-time equivalent employees

Metric used to define a small business

Shelf Life Date

Determines holding period for reserve samples; Keep written records for one year past the shelf life date.

Expiration Date

Property of a device that may be changed via established protocols

Technical Details

Substances

4
Dietary Ingredient

Vitamins, minerals, herbs used in dietary supplements

Cattle-derived material

specific regulatory requirements apply

Water

common component that may contribute to total bioburden

Raw Agricultural Commodity

Material incorporated into dietary supplements

Testing Methods

6
Scientifically Valid Method

A scientific method that is accurate, precise, and specific for its intended purpose.; required for each established specification to determine if it is met

Validated scientific method

Recommended for performing tests or examinations

Statistical Sampling Plan

Method for identifying finished batches for representative sampling

Chemical Analysis

used to demonstrate relevance of previous toxicity testing

Gross Organoleptic Analysis

One of the methods used to determine whether specifications are met.

Laboratory Operations

Subpart J – Production and Process Control: Requirements for Laboratory Operations

Processes

10
Identity Testing

interim final rule setting forth a procedure for requesting an exemption from a requirement for the manufacturer to conduct at least one appropriate test to verify identity; Verification of the identity of each dietary ingredient

Pasteurizing

Measure taken to destroy undesirable microorganisms

Sterilizing

Required direction for water, bottles, and nipples

Sanitation

Cleaning and sanitizing procedures for food processing environments; General sanitation program and monitoring recommendations; Sanitation procedures to minimize Listeria contamination; Routine cleaning and sanitizing schedules

laboratory control processes

processes including sampling plans and testing methods

Quarantine

Storage or identification of an ACTP in a physically separate area to prevent improper release.

Material Review

Evaluation by quality control personnel before disposition; evaluation of components or products that fail specifications; Conduct a material review and make a disposition decision for returned products.

Reprocessing

End-user sterilization validation

Water Treatment

Corrective measure when agricultural water does not meet numerical criteria

Calibration

Required for critical equipment to maintain quality

Clinical Concepts

1
Serious Adverse Event

Adverse events resulting in death, hospitalization, or significant disability.

Identified Hazards

Hazards

3
Microbial Contamination

Risk associated with tattoo inks that can lead to infection.; Risk associated with insanitary conditions in tattoo ink preparation

Contamination

Microorganisms or particulate matter that could adversely affect the device.

Microbiological contamination

Potential for contamination of covered produce; Known or reasonably foreseeable hazards in water

Standards & References

External Standards

3
USP

United States Pharmacopeia standards for compendial drug substances; confirming conformance to the application-approved specification and USP

AOAC International

Use of a method published by an authoritative source such as AOAC International

compendia reference standards

recommended for use in performing tests and examinations

Specifications

10
Specifications

Specifications to identify dietary ingredients, other ingredients, and contaminants

Product specifications

Failure of the product to meet product specifications

theoretical yield

expected yield at each point of the manufacturing process

Product Specification

limits that must be met for finished batches

Limits on Contaminants

Specification for components

Composition

Component and product specification

Strength

Concentration of the active pharmaceutical ingredient

Purity

Drug product purity should be carefully evaluated early in product development.

Identity

Final product release criteria

In-process Specifications

Documentation for meeting specifications for identity, purity, strength, and composition

Related CFR Sections (20)

Enforcement Impact

Deficiencies cited in Warning Letters referencing the same regulations

Failure to have and implement a HACCP plan
24
Unapproved New Drugs
21
Failure to establish and follow written procedures for quality control operations
11
Failure to establish product specifications
11
Misbranded Drugs
11
Failure to establish component specifications
10
Adulterated
7
Adulterated Dietary Supplements
7
Failure to prepare and follow a written master manufacturing record
6
Misbranded Dietary Supplements
5

Related Warning Letters (10)

See Also (8)

Small Entity Compliance Guide: Current Good Manufacturing Practice in Manufacturing, Packaging, Labeling, or Holding Operations for Dietary Supplements | Guideline Explorer | BioRegHub