FDA 483 OBSERVATION · #37 OF 1,923 MOST-CITED

Hazard analysis biological, chemical, physical

FDA cited this observation 592 times across 523 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
Foods583
Veterinary Medicine9
BY FISCAL YEAR
FY202686
FY202588
FY202489
FY2023110
FY2022114
FY202165
FY202024
FY20197
FY20184
FY20175

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 117.130

The hazard analysis did not adequately consider the biological, chemical (including radiological), and physical hazard categories — one or more hazard types was overlooked for the food and process.

Why FDA writes it — Hazards come in distinct categories, and missing a category leaves an entire class of risk uncontrolled. FDA cites this when an analysis addresses, say, microbial hazards but overlooks chemical (allergen, residue) or physical (foreign-object) hazards.

HOW TO COMPLY
  • Evaluate biological, chemical (including radiological), and physical hazards for each type of food.
  • Include hazards that occur naturally, may be unintentionally introduced, or may be intentionally introduced for economic gain.
  • Consider allergens as a chemical hazard where applicable.
  • Document the evaluation across all hazard categories, not just the obvious ones.
WHY FIRMS GET CITED
  • Focusing on microbial hazards and overlooking chemical (allergen/residue) or physical hazards.
  • Not considering the food’s specific ingredients and process when identifying hazard types.
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 2× the rate of the average FDA-cited firm (15.9% vs 7.8%), across 523 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

Your hazard analysis did not identify a hazard that requires a control.

Swedish Candy Group Inc. · Los Angeles, California · Foods · 2026-09-04

Your hazard analysis did not identify a hazard that requires a control.

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

Your hazard analysis did not identify a hazard that requires a control.

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

Your hazard analysis did not identify a hazard that requires a control.

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

Your hazard analysis did not identify a hazard that requires a control.

Glycerin Supplier LLC dba Ingredient Supplier · Houston, Texas · Foods · 2026-07-31

Your hazard analysis did not identify a hazard that requires a control.

Borges USA, Inc. · Fresno, California · Foods · 2026-07-31

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 →