FDA 483 OBSERVATION · #66 OF 1,923 MOST-CITED

DMR - not or inadequately maintained

FDA cited this observation 371 times across 339 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
Devices371
BY FISCAL YEAR
FY20266
FY202525
FY202425
FY202335
FY202224
FY202113
FY202029
FY201943
FY201858
FY201758
FY201655

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 820.181

The Device Master Record (DMR) — the compilation of records defining how a device is produced — was not maintained or was inadequate, so the specifications and procedures for manufacturing the device were incomplete or missing.

Why FDA writes it — The DMR is the recipe for a device: specifications, production processes, quality-assurance procedures, packaging, and labeling. An incomplete DMR means the device is made without a controlled definition of how it should be made, so consistency and conformance cannot be assured.

HOW TO COMPLY
  • Maintain a DMR for each type of device, including device specifications, production process specifications, quality-assurance procedures and acceptance criteria, packaging and labeling specifications, and installation/servicing procedures where applicable.
  • Keep the DMR current through change control.
  • Ensure each DMR is prepared and approved per 21 CFR 820.40 (document controls).
  • Reference the DMR from the device history record so production traces back to it.
WHY FIRMS GET CITED
  • DMR content scattered and never compiled/controlled as a defined record.
  • DMR not updated when the device or process changes, so it no longer defines production.
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 1.6× the rate of the average FDA-cited firm (12.4% vs 7.8%), across 339 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 master record has not been adequately maintained.

Medivis, Inc. · New York, New York · Devices · 2026-03-03

A device master record has not been maintained.

ZIIP INC · Pleasant Hill, California · Devices · 2026-01-12

A device master record has not been maintained.

Specialty Health Products CO, LLC · Phoenix, Arizona · Devices · 2025-12-11

A device master record has not been adequately maintained.

ASEPTIKITS, LLC · North Salt Lake, Utah · Devices · 2025-12-03

A device master record has not been adequately maintained.

Hakko Co., Ltd. · Chikuma · Devices · 2025-11-13

A device master record has not been maintained.

Lightwave · Phoenix, Arizona · Devices · 2025-10-22

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 →