FDA 483 OBSERVATION · #106 OF 1,923 MOST-CITED

Document review entity's hazard analysis

FDA cited this observation 283 times across 274 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
Foods278
Veterinary Medicine5
BY FISCAL YEAR
FY202657
FY202569
FY202457
FY202331
FY202220
FY202129
FY202010
FY20195
FY20181
FY20174

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 1.505

Under FSVP the importer must analyze the hazards in each food to determine which require a control; where the importer relies on the foreign supplier’s or another entity’s hazard analysis, it must review and assess that document rather than accept it blindly.

Why FDA writes it — FDA cites this when the importer never obtained or evaluated the hazard analysis it depends on, so it cannot know which hazards need control — the entire FSVP program is built on a hazard analysis the importer has not actually reviewed.

HOW TO COMPLY
  • Obtain the hazard analysis you rely on and have a qualified individual review it for completeness against biological, chemical, and physical hazards.
  • Confirm the analysis identifies who controls each hazard requiring a control before you rely on it.
  • Document your review and reconcile any hazards the entity’s analysis missed by performing or supplementing the analysis yourself.
WHY FIRMS GET CITED
  • Accepting a supplier’s or broker’s hazard analysis on faith without an internal qualified-individual review.
  • No record showing the relied-upon hazard analysis was ever evaluated for adequacy or currency.
PROFESSIONAL · REMEDIATION PLAYBOOK · SPEQ SYNTHESIS

How to close this finding — and stop it recurring

CHECKING ACCESS

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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 1.1× the rate of the average FDA-cited firm (8.8% vs 7.8%), across 274 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

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How FDA worded it — real examples

You did not document your review and assessment of a hazard analysis conducted by another entity.

SUNSTAR67 · Cerritos, California · Foods · 2026-08-20

You did not document your review and assessment of a hazard analysis conducted by another entity.

DRISCOLL FOOD NJ · Wayne, New Jersey · Foods · 2026-08-20

You did not document that a hazard analysis conducted by another entity was conducted by a qualified individual.

FRESH FLAVOR INTERNATIONAL INC. · Reston, Virginia · Foods · 2026-08-17

You did not document your review and assessment of a hazard analysis conducted by another entity.

D. Coluccio & Sons Inc. · Brooklyn, New York · Foods · 2026-08-07

You did not document your review and assessment of a hazard analysis conducted by another entity.

Jorday Foods International LLC · Hackensack, New Jersey · Foods · 2026-08-05

You did not document your review and assessment of a hazard analysis conducted by another entity and that a hazard analysis conducted by another entity was conducted by a qualified individual.

Tang's Family Corporation · Hyattsville, Maryland · Foods · 2026-07-30

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.

HACCP →Food industry →Veterinary industry →

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