FDA 483 OBSERVATION · #142 OF 1,923 MOST-CITED

Written record of investigation incomplete

FDA cited this observation 213 times across 206 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
Drugs213
BY FISCAL YEAR
FY202612
FY202531
FY202410
FY202326
FY202221
FY202110
FY202016
FY201920
FY201825
FY201720
FY201622

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 211.192

The written record of an investigation into an unexplained discrepancy or a batch (or its components) failing to meet specification is incomplete — it lacks the conclusions, follow-up, root cause, or the extension of the investigation to other batches and products that may have been associated with the failure, as required by §211.192.

Why FDA writes it — The investigation record is how a firm proves it understood a failure and contained it. An incomplete record means FDA cannot confirm root cause was found or that other potentially affected batches were evaluated — the risk is releasing product that shares an undiscovered defect.

HOW TO COMPLY
  • Document each discrepancy or OOS investigation with a defined scope, root-cause analysis, conclusions, and a follow-up decision.
  • Explicitly assess whether other batches or products were associated with the failure and record the disposition of each.
  • Justify batch disposition (release, reject, rework) on the investigation’s findings, not on a retest that overrides the original result.
  • Require quality-unit review and approval of the completed investigation before final batch disposition.
WHY FIRMS GET CITED
  • Investigations close on the first plausible cause without confirming it or extending scope to related batches.
  • The template lacks required fields (conclusion, other-batch impact), so records read as complete when they are not.
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 2.4× the rate of the average FDA-cited firm (18.9% vs 7.8%), across 206 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

Written records of investigations into unexplained discrepancies and the failure of a batch or any of its components to meet specifications do not always include the conclusions and follow-up.

Playtex Manufacturing Inc · Ormond Beach, Florida · Drugs · 2026-07-10

Written records of investigations into unexplained discrepancies do not include the conclusions and follow-up.

Nexus Pharmaceuticals, LLC · Lincolnshire, Illinois · Drugs · 2026-06-04

Written records of investigations into unexplained discrepancies and the failure of a batch or any of its components to meet specifications do not always include the conclusions and follow-up.

Frontage Laboratories, Inc. · Exton, Pennsylvania · Drugs · 2026-04-14

Written records of investigations into the failure of a batch or any of its components to meet specifications do not always include the conclusions and follow-up.

Fresenius USA Manufacturing, Inc. · Ogden, Utah · Drugs · 2026-03-06

Written records of investigations into unexplained discrepancies do not include the conclusions and follow-up.

Enemeez LLC · Phoenix, Arizona · Drugs · 2026-02-12

Written records of investigations into unexplained discrepancies and the failure of a batch or any of its components to meet specifications do not always include the conclusions and follow-up.

Auriga Research Private Limited · Bengaluru · Drugs · 2026-02-06

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.

Quality risk management →Pharma industry →

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