FDA 483 OBSERVATION · #154 OF 1,923 MOST-CITED

Training , Education , Experience overall

FDA cited this observation 200 times across 189 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
Drugs200
BY FISCAL YEAR
FY20268
FY202525
FY202418
FY20238
FY202210
FY202118
FY202012
FY201924
FY201839
FY201723
FY201615

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 211.25

Drug CGMP requires each person engaged in the manufacture, processing, packing, or holding of a drug product to have the education, training, and experience — or a combination — to perform their assigned functions, with training in current GMP conducted by qualified individuals on a continuing basis.

Why FDA writes it — FDA cites this when personnel lack documented qualification or ongoing CGMP training, because in a validated pharmaceutical operation an inadequately trained operator or analyst is a root cause of deviations, data-integrity lapses, and product failures.

HOW TO COMPLY
  • Establish job descriptions defining the education, training, and experience each drug-manufacturing role requires.
  • Deliver initial and continuing CGMP training specific to each person’s functions, conducted by qualified trainers.
  • Document each employee’s qualifications and training history and keep it current with role and procedure changes.
WHY FIRMS GET CITED
  • CGMP training treated as a one-time hire event rather than the continuing program the rule requires.
  • No documented tie between an individual’s education, training, and experience and the specific functions they are assigned.
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 5.1× the rate of the average FDA-cited firm (39.1% vs 7.8%), across 189 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

Employees engaged in the processing of a drug product lack the training required to perform their assigned functions.

Scinopharm Taiwan, Ltd. · Tainan City · Drugs · 2026-06-23

Employees engaged in the processing of a drug product lack the training required to perform their assigned functions.

Oakwood Laboratories LLC · Solon, Ohio · Drugs · 2026-05-21

Employees engaged in the processing of a drug product lack the training required to perform their assigned functions.

Alcami Carolinas Corporation · Charleston, South Carolina · Drugs · 2026-04-22

Employees engaged in the manufacture, processing, packing and holding of a drug product lack the training required to perform their assigned functions.

Altaire Pharmaceuticals, Inc. · Aquebogue, New York · Drugs · 2026-04-21

Employees engaged in the packing of a drug product lack the training required to perform their assigned functions.

MD Logistics, LLC · Plainfield, Indiana · Drugs · 2026-04-03

Employees engaged in the manufacture of a drug product lack the training required to perform their assigned functions.

Gallant Pet Inc · San Diego, California · Drugs · 2026-02-27

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.

Pharma industry →

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