FDA 483 OBSERVATION · #137 OF 1,923 MOST-CITED

Cleaning System

FDA cited this observation 216 times across 184 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
Drugs216
BY FISCAL YEAR
FY202615
FY202514
FY202421
FY202314
FY202221
FY202110
FY20208
FY201927
FY201818
FY201727
FY201641

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 117.35

The clean-in-place or automated cleaning system for food equipment did not reliably clean the surfaces it serves — spray coverage, flow, temperature, or chemical delivery was not adequate, or the system was assumed effective without proof. This falls under the sanitary-operations requirement of §117.35, with equipment design considerations reaching into §117.40.

Why FDA writes it — A CIP or automated cleaning system that leaves dead legs, shadowed surfaces, or under-dosed chemical creates a false sense of cleanliness while pathogens and allergen residues survive. FDA cites this because an unverified cleaning system lets contaminated equipment be released as clean, run after run.

HOW TO COMPLY
  • Define and record the critical cleaning parameters for the system — flow rate, spray-device coverage, temperature, chemical concentration, and cycle time.
  • Verify each cycle meets those parameters (flow/pressure readings, temperature logs, conductivity or titration) and alarm or reject when it does not.
  • Periodically inspect or swab hard-to-reach surfaces, dead legs, and gaskets to confirm the automated cycle actually reaches them.
  • Requalify the cleaning system after equipment changes, and keep records that tie each release to a completed, in-spec cycle.
WHY FIRMS GET CITED
  • Trust in the automated cycle without instrumentation or swabbing to prove the surfaces it cannot be seen cleaning are actually clean.
  • Equipment design with dead legs and shadowed geometry that the cleaning system was never validated against.
PROFESSIONAL · REMEDIATION PLAYBOOK · SPEQ SYNTHESIS

How to close this finding — and stop it recurring

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What this observation is associated with

Firms cited for this observation also appear in FDA compliance actions — warning letters, injunctions, or seizures — at 7.4× the rate of the average FDA-cited firm (57.6% vs 7.8%), across 184 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.

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How FDA worded it — real examples

Aseptic processing areas are deficient regarding the system for cleaning and disinfecting the equipment to produce aseptic conditions.

Pillar5 Pharma Inc. · Arnprior · Drugs · 2026-06-05

Aseptic processing areas are deficient regarding the system for cleaning and disinfecting the room and equipment to produce aseptic conditions.

Hanlim Pharm Co. Ltd. · Yongin · Drugs · 2026-04-24

Aseptic processing areas are deficient regarding the system for cleaning and disinfecting the room and equipment to produce aseptic conditions.

Altaire Pharmaceuticals, Inc. · Aquebogue, New York · Drugs · 2026-04-21

Aseptic processing areas are deficient regarding the system for cleaning and disinfecting the equipment to produce aseptic conditions.

Rohto-Mentholatum (Vietnam) Co., Ltd. · Ho Chi Minh · Drugs · 2026-04-14

Aseptic processing areas are deficient regarding the system for cleaning and disinfecting the to produce aseptic conditions.

Pharmaceutics International, Inc. · Cockeysville, Maryland · Drugs · 2026-03-06

Aseptic processing areas are deficient regarding the system for cleaning and disinfecting the room to produce aseptic conditions.

Sharp Sterile Manufacturing, LLC · Lee, Massachusetts · Drugs · 2026-03-05

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.

Cleaning validation →Pharma industry →

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