FDA 483 OBSERVATION · #151 OF 1,923 MOST-CITED

Process adherence

FDA cited this observation 205 times across 196 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
Foods202
Veterinary Medicine3
BY FISCAL YEAR
FY202611
FY202532
FY202420
FY202319
FY202215
FY20211
FY202010
FY201922
FY201823
FY201727
FY201625

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 113.87

Processing operations for low-acid canned food did not adhere to the established scheduled process — retort operating procedures, venting, come-up time, initial-temperature limits, or the actual time/temperature delivered departed from what the scheduled process specifies. This is the operating-conduct requirement of §113.87.

Why FDA writes it — Even a correctly established scheduled process fails to deliver commercial sterility if the retort is not operated to it — a short vent, low initial temperature, or truncated process time can leave viable C. botulinum spores. FDA cites process adherence because the safety of every LACF lot depends on the process being executed exactly as established, load after load.

HOW TO COMPLY
  • Operate each retort strictly to the scheduled process, including come-up, venting, process time and temperature, and cooling.
  • Enforce initial-temperature and other critical-factor limits before starting a cycle, and hold product that starts outside them.
  • Have qualified retort operators and supervisors trained and evidenced as competent to run the scheduled process.
  • Detect any departure from the scheduled process, segregate the affected containers, and evaluate them under an established deviation procedure before release.
WHY FIRMS GET CITED
  • Operator shortcuts (short vents, early start below initial temperature) tolerated because throughput was prioritized over the scheduled process.
  • No systematic comparison of the actual delivered process against the scheduled process, so deviations are neither caught nor dispositioned.
PROFESSIONAL · REMEDIATION PLAYBOOK · SPEQ SYNTHESIS

How to close this finding — and stop it recurring

CHECKING ACCESS

Checking your Professional access…

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 (8.2% vs 7.8%), across 196 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

Checking your Professional access…

How FDA worded it — real examples

You did not process each low-acid canned food in conformity with at least the filed scheduled processes and modifications.

Chau Giang Food Processing Trade Co., LTD · Cu Chi Commune · Foods · 2026-06-24

You did not process each low-acid canned food in conformity with at least the filed scheduled processes and modifications.

Pujado Solano S.A. · Santona · Foods · 2026-04-07

You did not process a food in conformity with at least the scheduled process filed with FDA.

DXN Industries (M) Sdn. Bhd. · Jitra · Veterinary Medicine · 2026-03-04

You did not process a food in conformity with at least the scheduled process filed with FDA.

Fire Horse International LLC · Madison, Wisconsin · Foods · 2026-02-27

You did not process a food in conformity with at least the scheduled process filed with FDA.

VRB Consumer Products Pvt. Ltd. · Neemrana · Foods · 2026-01-30

You did not process each low-acid canned food in conformity with at least the filed scheduled processes and modifications.

KSB Foods Co., Ltd · Hwasung-Si · Foods · 2025-12-18

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.

Food industry →Veterinary industry →

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