FDA 483 OBSERVATION · #99 OF 1,923 MOST-CITED

DHR - not or inadequately maintained

FDA cited this observation 297 times across 281 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
Devices297
BY FISCAL YEAR
FY20263
FY202524
FY202428
FY202331
FY202226
FY202111
FY202012
FY201938
FY201833
FY201742
FY201649

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 820.184

The Device History Record (DHR) — the record demonstrating a device was manufactured in accordance with the DMR — was not maintained or was inadequate, so there was no evidence a specific batch/unit was made per its specifications.

Why FDA writes it — The DHR is the proof that a device was actually produced to its master record. Missing or incomplete DHRs mean the manufacturer cannot demonstrate a released device conformed to its specifications — undermining every release decision.

HOW TO COMPLY
  • Maintain a DHR for each batch, lot, or unit demonstrating manufacture per the DMR.
  • Include the dates of manufacture, quantity manufactured and released, acceptance records, primary identification label and labeling, and any device identification and control numbers used.
  • Complete the DHR contemporaneously as the device is produced.
  • Link the DHR to the DMR it was built to.
WHY FIRMS GET CITED
  • DHRs completed after the fact or missing acceptance records, so conformance is not demonstrable.
  • No linkage between the DHR and the DMR version it was built to.
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 1.2× the rate of the average FDA-cited firm (9.3% vs 7.8%), across 281 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

A device history record has not been maintained.

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

A device history record has not been adequately maintained.

Ashland Specialty Ingredients, G.P. · Fiskeville, Rhode Island · Devices · 2025-12-22

A device history record has not been maintained.

Safer Medical Products Inc. · Fircrest, Washington · Devices · 2025-10-08

A device history record has not been maintained.

Mesco, Inc. · Pasig · Devices · 2025-09-25

A device history record has not been adequately maintained.

BCM Co., Ltd. · Goyang · Devices · 2025-09-18

A device history record has not been adequately maintained.

CG Bio Co., Ltd. · Hwaseong · Devices · 2025-09-11

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 →