FDA 483 OBSERVATION · #288 OF 1,923 MOST-CITED

Failure to develop written procedures

FDA cited this observation 102 times across 95 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
Drugs102
BY FISCAL YEAR
FY20266
FY202512
FY202413
FY20236
FY20226
FY20215
FY20203
FY20197
FY201814
FY201715
FY201615

What this observation is associated with

Firms cited for this observation also appear in FDA compliance actions — warning letters, injunctions, or seizures — at 1.9× the rate of the average FDA-cited firm (14.7% vs 7.8%), across 95 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

Written procedures have not been developed for the surveillance and reporting to FDA of post marketing adverse drug experiences.

Primus Pharmaceuticals, Inc. · Scottsdale, Arizona · Drugs · 2026-07-23

Written procedures have not been developed for the surveillance, receipt, evaluation and reporting to FDA of post marketing adverse drug experiences.

HIKMA PHARMACEUTICALS USA INC. · Berkeley Heights, New Jersey · Drugs · 2026-07-13

Written procedures have not been developed for the surveillance, receipt, evaluation and reporting to FDA of post marketing adverse drug experiences.

Scilex Pharmaceuticals Inc. · Palo Alto, California · Drugs · 2026-05-20

Written procedures have not been developed for the of post marketing adverse drug experiences.

Milla Pharmaceuticals, Inc. · Saint Paul, Minnesota · Drugs · 2026-03-12

Written procedures have not been developed for the reporting to FDA of post marketing adverse drug experiences.

Misemer Pharmaceutical, Inc. · Ripley, Mississippi · Drugs · 2026-02-23

Written procedures have not been developed for the surveillance of post marketing adverse drug experiences.

Waylis Therapeutics LLC · Rahway, New Jersey · Drugs · 2026-02-12

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.

Quality risk management →Pharmaceutical quality system →Pharma industry →

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