FDA 483 OBSERVATION · #57 OF 1,923 MOST-CITED
Signed and dated
FDA cited this observation 437 times across 402 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.
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.
The HACCP plan (or a required record) was not signed and dated as the regulation requires — the individual accountability and the timing of the record were not established.
Why FDA writes it — A signature and date establish who is responsible for the plan and when it took effect or was reviewed. An unsigned or undated HACCP plan lacks the accountability the rule requires, and undated records break the timeline that demonstrates control.
- Ensure the HACCP plan is signed and dated by the most responsible individual on-site or a higher-level official, upon initial acceptance, upon modification, and upon reassessment.
- Sign and date required monitoring, corrective-action, and verification records as they are made.
- Use dating that establishes contemporaneity, not after-the-fact completion.
- Keep signatures attributable to identifiable individuals.
- A HACCP plan or record left unsigned or undated, removing accountability and timing.
- Records dated in batches rather than at the time of the activity.
How to close this finding — and stop it recurring
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 402 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.
How FDA worded it — real examples
Your HACCP plan was not signed and dated upon modification and at least annually.
Your HACCP plan was not signed and dated upon initial acceptance and at least annually.
Your HACCP plan was not signed and dated at least annually.
Your HACCP plan was not signed and dated upon initial acceptance.
Your HACCP plan was not signed and dated upon modification and at least annually.
Your HACCP plan was not signed and dated at least annually.
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.
Examples are a representative sample of FDA's published inspection observations. Open the 483 observation explorer →