FDA 483 OBSERVATION · #121 OF 1,923 MOST-CITED

Design history file

FDA cited this observation 256 times across 238 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
Devices256
BY FISCAL YEAR
FY20268
FY202527
FY202431
FY202324
FY202222
FY20219
FY202018
FY201928
FY201834
FY201730
FY201625

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 820.30(j)

The Design History File (DHF) — the compilation of records describing the design history of a finished device — is missing, incomplete, or does not demonstrate that the design was developed in accordance with the approved design plan and the design-control requirements of §820.30.

Why FDA writes it — The DHF is the evidence that design controls were actually applied. Without it, FDA cannot confirm that inputs, outputs, reviews, verification, validation, and transfer occurred, so there is no assurance the marketed device is the one that was actually designed and validated.

HOW TO COMPLY
  • Maintain a DHF index that maps each §820.30 activity (plan, inputs, outputs, reviews, V&V, transfer, changes) to its underlying records.
  • Reconcile the DHF against the approved design plan and close any activity that has no corresponding record.
  • Keep the DHF current through design changes so it reflects the design as transferred to production.
  • Review DHF completeness at each design review and at design transfer before commercial release.
WHY FIRMS GET CITED
  • Design records live scattered across engineers’ folders and systems with no controlled compilation.
  • Legacy or acquired products were transferred without ever assembling a compliant DHF.
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 2.1× the rate of the average FDA-cited firm (16.0% vs 7.8%), across 238 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

The design history file was not established.

Peter Schiff Enterprises · Cookeville, Tennessee · Devices · 2025-12-31

The design history file was not established.

Foresight Imaging, LLC · Chelmsford, Massachusetts · Devices · 2025-12-12

The design history file does not demonstrate that the design was developed following the approved design plan.

3B Medical, Inc. · Dublin, Ohio · Devices · 2025-12-10

The design history file was not established.

3D Diagnostix Inc. · Allston, Massachusetts · Devices · 2025-11-21

The design history file was not established.

R.G. Enterprises (U.S.A.) Inc. · Madison Heights, Michigan · Devices · 2025-11-05

The design history file was not established.

Longhorn Vaccines And Diagnostics LLC · Bethesda, Maryland · Devices · 2025-10-30

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.

Medical devices →

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