FDA 483 OBSERVATION · #22 OF 1,923 MOST-CITED

Absence of Written Procedures

FDA cited this observation 831 times across 707 firms in recent inspections. Below: how it breaks down by program area and fiscal year, and real examples of how FDA worded it on Form FDA 483.

What this grouping is not

An observation-type page groups FDA’s published citation records. The grouping, the compliance steps and the root causes are SPEQ synthesis, not an FDA classification of any citation, and a count measures what FDA published rather than risk.

BY PROGRAM AREA
Drugs831
BY FISCAL YEAR
FY202661
FY2025147
FY2024108
FY202369
FY202273
FY202141
FY202033
FY201979
FY201869
FY201777
FY201674

What this observation means, and how to comply

SPEQ's practitioner reading of this finding. The regulatory basis is a cited fact; the interpretation, compliance steps, and root causes are SPEQ synthesis — not an FDA classification of the citation.

21 CFR 211 / 21 CFR 820 (written-procedure requirements)

A written procedure that the regulation requires simply did not exist. Distinct from an inadequate procedure, this is the outright absence of the SOP, work instruction, or defined method for a regulated activity.

Why FDA writes it — Many GMP and QSR requirements are explicit that a written procedure “shall be established.” When none exists, the activity is uncontrolled by definition and there is no basis on which people can perform it consistently — so the absence is a direct regulatory violation, not a matter of degree.

HOW TO COMPLY
  • Identify every activity for which the regulation explicitly requires a written procedure, and confirm each one exists, is approved, and is current.
  • Establish the missing procedure with the required scope, responsibilities, and acceptance criteria before the activity is performed.
  • Train personnel to the procedure and record the training.
  • Include the procedure in the document-control system so it stays current.
WHY FIRMS GET CITED
  • A required procedure was never created because the activity “was always done a certain way” informally.
  • A regulatory requirement to have a specific written procedure was not mapped to an owned, controlled document.
PROFESSIONAL · REMEDIATION PLAYBOOK · SPEQ SYNTHESIS

How to close this finding — and stop it recurring

CHECKING ACCESS

Checking your Professional access…

What this observation is associated with

Firms cited for this observation also appear in FDA compliance actions — warning letters, injunctions, or seizures — at 5.1× the rate of the average FDA-cited firm (39.5% vs 7.8%), across 707 FEI-matched firms.

This is an association, not causation, and reflects co-occurrence in FDA's records — not a claim that the observation caused or preceded the action.

CHECKING ACCESS

Checking your Professional access…

How FDA worded it — real examples

Your firm failed to establish adequate written procedures for production and process controls designed to assure that the drug products have the identity, strength, purity, and quality that they are purported or represented to possess.

Advanced Cosmetic Research Laboratories, Inc. · Chatsworth, California · Drugs · 2026-06-26

Your firm failed to establish written procedures for production and process controls designed to assure that the drug products have the identity, strength, purity, and quality that they are purported or represented to possess.

S.s.s. Company (international) · Atlanta, Georgia · Drugs · 2026-06-26

Your firm failed to establish written procedures for production and process controls designed to assure that the drug products have the identity, strength, purity, and quality that they are purported or represented to possess.

The Flower Remedy LLC · Englewood, Colorado · Drugs · 2026-06-12

Your firm failed to establish written procedures for production and process controls designed to assure that the drug products have the identity, strength, purity, and quality that they are purported or represented to possess.

Product Society LLC · North Hollywood, California · Drugs · 2026-06-12

Your firm failed to establish adequate written procedures for production and process controls designed to assure that the drug products have the identity, strength, purity, and quality that they are purported or represented to possess.

API Solutions Inc. · Daphne, Alabama · Drugs · 2026-05-27

Your firm failed to establish adequate written procedures for production and process controls designed to assure that the drug products have the identity, strength, purity, and quality that they are purported or represented to possess.

Samchundang Pharm Co., Ltd. · Hwaseong · Drugs · 2026-05-19

Related SPEQ references

Where to read the requirements behind this observation area on SPEQ. These are SPEQ's topic and audience pages — not an FDA classification of the citation.

Pharmaceutical quality system →Pharma industry →

Examples are a representative sample of FDA's published inspection observations. Open the 483 observation explorer →