FDA 483 OBSERVATION · #89 OF 1,923 MOST-CITED

Verification procedures - adequacy

FDA cited this observation 313 times across 282 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
Foods313
BY FISCAL YEAR
FY202611
FY202516
FY202421
FY202330
FY202222
FY202112
FY202016
FY201935
FY201838
FY201763
FY201649

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 1.506

FSVP requires written procedures that ensure appropriate supplier verification activities are conducted; this observation means those procedures are missing or inadequate — they do not spell out what verification is done, by whom, or how it is judged sufficient.

Why FDA writes it — FDA cites inadequate written procedures because without them verification becomes ad hoc and unrepeatable, and neither the importer’s staff nor an investigator can confirm that the hazard-appropriate activities are reliably carried out.

HOW TO COMPLY
  • Write procedures that define, per supplier and hazard, which verification activities are performed, their frequency, and the acceptance criteria for results.
  • Assign the activities to a qualified individual and require dated documentation of each one.
  • Review and update the procedures whenever the hazard, supplier, or evaluation outcome changes, and keep superseded versions.
WHY FIRMS GET CITED
  • Relying on informal practice or email instructions instead of a controlled written procedure.
  • Procedures that name an activity but omit the frequency, responsibility, or acceptance criteria that make them auditable.
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 1.6× the rate of the average FDA-cited firm (12.4% vs 7.8%), across 282 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

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How FDA worded it — real examples

Your HACCP plan lists verification that have not been developed in accordance with 21 CFR 123.8(a) to ensure that your HACCP plan is adequate to control food safety hazards, and is being effectively implemented.

Stagnaro Brothers Seafood Inc. · Santa Cruz, California · Foods · 2026-08-20

Your HACCP plan lists verification procedures that have not been developed in accordance with 21 CFR 123.8(a) to ensure that your HACCP plan is adequate to control food safety hazards, and is being effectively implemented.

Jowdy Industries, Inc. · West Palm Beach, Florida · Foods · 2026-07-10

Your HACCP plan lists verification procedures that have not been developed in accordance with 21 CFR 123.8(a) to ensure that your HACCP plan is adequate to control food safety hazards, and is being effectively implemented.

YEONGDUKFOODS CO., LTD · Yeongdeok · Foods · 2026-06-16

Your HACCP plan lists verification procedures that have not been developed in accordance with 21 CFR 123.8(a) to ensure that your HACCP plan is adequate to control food safety hazards, and is being effectively implemented.

MFM Seafood Inc · San Francisco, California · Foods · 2026-05-26

Your HACCP plan lists verification that have not been developed in accordance with 21 CFR 123.8(a) to ensure that your HACCP plan is adequate to control food safety hazards, and is being effectively implemented.

Hwangto Co., Ltd. · Saha · Foods · 2026-04-30

Your HACCP plan lists verification procedures and frequencies that have not been developed in accordance with 21 CFR 123.8(a) to ensure that your HACCP plan is adequate to control food safety hazards, and is being effectively implemented.

BeiraNova Industria De Congelados S.A. · Viseu · Foods · 2026-04-20

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.

Pharmaceutical quality system →Food industry →

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