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Add Continuati on Page AMENDMENT I EMPLOYEE($) NAME AND TITLE (Ptinr Of Type) DATE ISSUED SEE Kenneth 0 . Gee. C'SO REVERSE OF T HIS Andre" K. Haack. CSO 08/15/ 201 8 PAGE I (NMI) Kanakarajan, CSO FORM FDA 4 83 (9108) PREVIOUS EDITI ON OBSOLETE INSPECT IONAL OBSERVATIONS Pagelof9 DEPARTMENT OF HEALTH A NO HUMAN SERVICES FOOD AND DRUG ADMINISTRATION DI STRICT OFFICE ADDRESS ANO PHONE NUMBER 1970 I Fairchild Irvine, CA 92612-2445 (949)608- 2900 Fax: (949)608-44 I 7 Industry Information: www.fda. gov/oc/indus try DATE(S) OF INSPECl lON 7 1912018-8/2120 Is• FEI NUMBER 30 11893599 NAME AND TITLE OF INDIVIDUAL TO WHOM REPORT IS ISSUED TO: Ashwin K. Patel, Ch ief Operations Officer FIRM NAME Auro Phannacies. Inc. STREET ADDRESS 520 W La Habra Blvd CITY. STATE AND ZIP CODE La Habra, CA 9063 1-53 08 TYPE OF ESTABLISHMENT INSPECTED Producer of sterile and non sterile drug products THIS DOC.UMENT LISTS OBSERVATIONS MADE BY THE FDA REPRESENTATIVE($) DURING THE INSPECTION OF YOUR FACILllY. lHEY ARE INSPECTIONAL OBSERVATIONS: ANO DO NOT REPRESENT A FINAL AGENCY DETERMINATION REGARDING YOUR COMPLIANCE. IF YOU HAVE AN OBJECTION REGARDING AN OBSERVATION . OR HAVE IMPLEMENTED. OR PLAN TO IMPLEMENT CORRECTI VE ACTION IN RESPONSE TO AN OBSERVATION. YOU MAY DISCUSS THE OBJECTION OR ACTION IMTH THE FDA REPRESEN TATIVE(S) DURING THE INSPECTION OR SUBMIT THIS INFORMATION TO FDA AT THE ADDRESS ABOVE. IF YOU HAVE ANY QU ESTIONS. P LEASE CONTACT FDA AT THE PHONE NUMBER AND ADDRESS ABOVE. DURING AN INSPECTION OF YOUR FIRM (I) {'M) OBSERVED: OBSERVATION I The ISO 5 classified aseptic processing areas had vi sibl y dirty equipment or surface. Speci fi cally, we observed apparent brown and white residue in the ISO 5 class ified hoods tha1 are used in the production of steri le drugs. You stated t he hoods are cleaned ( t:>) (4) each production day. However, your fi rm was unaware of these observations un ti l they were di scussed on 07/ 09/20 I 8 and subsequently on 07/ I 8/2018. For example: A. On 0710912018, we observed apparent brown residue on the HEPA filter of an ISO 5 classified [(b) (4 )J lami nar flow hood, identi fied as Hood #2. This hood is used in dispensing of sterile drug prod ucts. In addition, we also observed apparent white residue on the [(t:>) (4) Jsurface, along with apparent brown residue in one perforati on ofth e[(b) (4) J. Both the resi due on the filter, and the[(b) are located on the ceiling directly above where sterile drug products are dispensed into fina l containers. This hood was last used to produce "NAO TRIHYDRATE 250 MGN IA L LY OPHI LIZ ED INJECTABLE'", lot I 805 3 1@ I2 on 05/31 /2018. RX [(b) (6) J. B. On 07I18/2 018, we observed apparent brown residue in nvo perforation s of an ISO 5 classified[ {o) ( l1 -)11aminar fl ow hood, identified as Hood #4. The [(o) (4) of this hood is located on the ce iling directly above where sterile drug products are dispensed into fina l containers. On 07/09/ 20 1 8, we observed this h ood used to produce "TESTOSTERONE CY PIONATE/ENANTHATE OIL INJ ECTION 126/54 MG/ ML INJECTABLE'", lot 180709@2 1.

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  • Add Continuation Page AMENDMENT I

    -~---- EMPLOYEE($) NAME AND TITLE (Ptinr Of Type) DATE ISSUED E~SIGNATURE

    SEE Kenneth 0 . Gee. C'SOREVERSE

    OF THIS Andre" K. Haack. CSO 08/15/201 8PAGE I Karthik~yan (NMI) Kanakarajan, CSO r-4~4,,,1.-FORM FDA 483 (9108) PREVIOUS EDITION OBSOLETE INSPECTIONAL OBSERVATIONS Pagelof9

    DEPARTMENT OF HEALTH A NO HUMAN SERVICES FOOD AND DRUG ADMINISTRATION

    DISTRICT OFFICE ADDRESS ANO PHONE NUMBER

    1970 I Fairchild

    Irvine, CA 92612-2445

    (949)608-2900 Fax:(949)608-44 I 7

    Industry Information: www.fda.gov/oc/industry

    DATE(S) OF INSPECllON

    71912018-8/2120 Is FEI NUMBER

    30 11893599

    NAME AND TITLE OF INDIVIDUAL TO WHOM REPORT IS ISSUED

    TO: Ashwin K . Patel, Chief Operations Officer FIRM NAME

    Auro Phannacies. Inc.

    STREET ADDRESS

    520 W La Habra Blvd CITY. STATE AND ZIP CODE

    La Habra, CA 9063 1-5308

    TYPE OF ESTABLISHMENT INSPECTED

    Producer ofsteri le and non sterile drug products

    THIS DOC.UMENT LISTS OBSERVATIONS MADE BY THE FDA REPRESENTATIVE($) DURING THE INSPECTION OF YOUR FACILllY. lHEY ARE INSPECTIONAL OBSERVATIONS: ANO DO NOT REPRESENT A FINAL AGENCY DETERMINATION REGARDING YOUR COMPLIANCE. IF YOU HAVE AN OBJECTION REGARDING AN OBSERVATION. OR HAVE IMPLEMENTED. OR PLAN TO IMPLEMENT CORRECTIVE ACTION IN RESPONSE TO AN OBSERVATION. YOU MAY DISCUSS THE OBJECTION OR ACTION IMTH THE FDA REPRESEN TATIVE(S) DURING THE INSPECTION OR SUBMIT THIS INFORMATION TO FDA AT THE ADDRESS ABOVE. IF YOU HAVE ANY QUESTIONS. PLEASE CONTACT FDA AT THE PHONE NUMBER AND ADDRESS ABOVE.

    DURING AN INSPECTION OF YOUR FIRM (I) {'M) OBSERVED:

    OBSERVATION I

    The ISO 5 classified aseptic processing areas had visibly dirty equipment or surface.

    Specifically, we observed apparent brown and white residue in the ISO 5 classified hoods tha1 are used in the production of sterile drugs. You stated the hoods are cleaned (t:>) (4) each production day. However, your fi rm was unaware of these observations unti l they were discussed on 07/09/20 I 8 and subsequently on 07/ I 8/2018. For example:

    A. On 0710912018, we observed apparent brown residue on the HEPA filter of an ISO 5 classified [(b) (4 )J laminar flow hood, identified as Hood #2. This hood is used in dispensing of sterile drug products. In addition, we also observed apparent white residue on the [(t:>) (4) Jsurface, along with apparent brown residue in one perforation ofthe[(b) (4)J. Both the residue on the filter, and the[(b) (4)~, are located on the ceiling directly above where sterile drug products are dispensed into fina l containers. This hood was last used to produce "NAO TRIHYDRATE 250 MGN IA L LYOPHILIZED INJECTABLE'", lot I80531@ I2 on 05/31 /2018. RX [~--(b) (6) -J.

    B. On 07I18/2018, we observed apparent brown residue in nvo perforations of an ISO 5 classified[{o) (l1-)11aminar flow hood, identified as Hood #4. The [(o) (4) of this hood is located on the ceiling directly above where sterile drug products are dispensed into fina l containers. On 07/09/20 18, we observed this hood used to produce "TESTOSTERONE CY PIONATE/ENANTHATE OIL INJ ECTION 126/54 MG/ML INJECTABLE'", lot 180709@2 1.

    www.fda.gov/oc/industry

  • --

    DEPARTMENT OF HEALTH ANO HUMAN SERVICES

    FOOD ANO DRUG ADMINISTRATION

    DISTRICT OFFICE ADDRESS AND PHONE NUMBER

    1970 I Fairchild

    Irvine, CA 92612-2445

    (949)608-2900 Fax:(949)608-44 I 7

    Industry Information: www.fda.gov/oc/industry

    DATE(S) OF INSPECTION

    7/9/2018-8/212018

    FEI NUMBER

    3011893599

    NAME ANO TITLE OF INDIVIDUAL TO WHOM REPORT IS ISSUED

    TO: Ashwin K. Patel, Chief Operations Officer

    FIRM NAME STREET ADDRESS

    Auro Pharmacies, Inc. 520 W La Habra Blvd

    CITY. STATE AND ZIP CODE TYPE OF ESTABLISHMENT INSPECTED

    La Habra, CA 9063 1-5308 Producer of ste rile and non sterile drug products

    E~IGNATURE SEE

    REVERSE

    OF THIS

    PAGc ,4:;k/Z:rtf

    AMENDMENT I

    Add Continuahon Page

    EMPlOYEE(S) NAME ANO TITLE (Print or Type) DATE ISSUED

    Kenneth 0 . Gee, CSO Andrew K. Haack. CSO Karthike)-.in (NMI) Kanakarajan, CSO

    08/ l 5/2018

    FORM FDA 483 (9/08) PREVIOUS EDITION OBSOLETE INSPECTIONAL OBSERVATIONS Page 2 of9

    C. On 07/J 8/2018, we observed apparent brown residue in five perforations ofan ISO 5 classified [(b) (4 )J laminar flow hood, identified as Hood #5. The [(t:>) (4)] ofthis hood is located on the ceiling directly above where drug sterile drug products are dispensed into final containers. On 07/09/20 18, we observed this hood used to produce " TESTOSTERONE CYPIONA TE/ENANTHATE OIL INJECTI ON 160/40 MG/ML INJECTABLE'', lot 180709@23. In addition, your firm identified a sterility test failure for the production of "ASCORBIC ACID INJECTION NO PRESERVATIVE 500 MG/ML INJECTABLE", lot 160829@5, on 08/29/2016.

    D. On 07109120 I8, we observed apparent white residue on the 1

    (b) (4) surface of the.~b) (4) Jand apparent brown residue in one circular metal perforation fonni ng the ceiling ofan ISO 5 classified t(b) (4 )J laminar flow hood, identified as Hood# I . The[{o) (4)] is located on the ceiling directly above where drug products purporting to be sterile are mixed. This hood was used to produce ''ATROPINE SULFATE 0.0 I%, OPHTHALMIC", Jot 180702@33 on 07/02/2018, RX [(b ) (6) I.

    E. On 07 / 18/20 I 8, we observed apparent brown residue on the HEPA filter ofan JSO 5 classified [(l:)f(4) laminar flow hood, identified as Hood #3 . Jn addition, we also observed apparent brown residue in one perforation of the [(t:>) (4 (. The airflow of this hood directs air from the HEPA filter through the [(t:> ) (4) ', both ofwhich are located on the [(b) (4 ) , to where steri le drug products are mix ed. On 07 /09/20 I 8, we observed this hood was used to produce "TESTOSTERONE CY PIONA TE/ENA NTH A TE OlL INJECTION 126/54 MG/ML INJECTABLE"', lot I 80709@2 I.

    F. On 07/18/2018, we observed apparent brown and b lack residue on the surface of the air supply vent covers supplying lSO 7 classified air to the asept ic compounding room . The air supply vent covers are located on the cei ling, and above Hood #3 and Hood #5, which are used to mix and dispense purported sterile drug products, respectively. In addition, Hood #3 and Hood #5 arc used in the production of several sterile drug products including "TESTOSTERONE CYPIONA TE/ENANTHA TE OTL INJECTION 126/54 MG/ML INJECTABLE,., lot 180709@2 I. and ''TESTOSTERONE CY Pl ONA TE/ENANTHATE OIL INJECTION 160/40 MG/ML INJECT ABLE'', lot I 80709@23 both on 07/09/2018.

  • DEPARTMENT OF HEALTH AND HUMAN SERVICES

    FOOD ANO DRUG ADMINISTRATION

    DISTRICT OFFICE ADDRESS ANO PHONE NUMBER OATE(S) OF INSPECTION

    19701 Fairchi ld 71912018-8/2/20 l 8 * Irvine, CA 92612-2445

    FEI NUMBER(949)608-2900 Fax:(949)608-44 I 7

    301 1893599

    Industry Jnformation: www.fda.gov/oc/industry NAME ANO TITLE OF INOIVlOUAl TO WHOM REPORT IS ISSUED

    TO: Ashwin K . Patel, Chief Operations Officer

    FIRM NAME STREET ADDRESS

    Auro Pharmacies, Inc. 520 W La Habra Blvd l--~~~~~~~~~~~~~~~~~~~~--1-~~~~~~~~~~~~~--~~~~~~--1

    TYPE OF ESTABLISHMENT INSPECTED CITY, STATE AND ZIP CODE

    La Habra, CA 90631-5308 Producer ofsterile and non sterile drug products

    AMENDMENT I

    Add Continuation Page

    EMPLOYEE($) NAME AND TITLE (Print or Type) DATE ISSUED

    SEE REVERSE Kenneth O. Gee. CSO OF THIS Andrew K. Haack, CSO 08/ J 5/2018 PAGE

    Karthikeran (NMI) Kanakarajan, CSO

    FORM FDA 483 (9/08) PREVIOUS EDITION OBSOLETE INSPECTIONAL OBSERVATIONS Page 3 of9

    OBSERVATION 2

    You did not make adequate product eva luation and take remedial action where actionable microbial contam ination was found to be present in the ISO 5 classified aseptic processing area during aseptic production.

    Specifica lly, you had viable air mon itoring samples above action levels~b) (4) J) consecutively in January, February and March of2018 in ISO 5 hoods that are used in the production of sterile drugs. Your tirm continued to produce sterile drugs without implementing a corrective and preventive action.

    A. On 01 /08/2018, your firm recovered I CFU/cubic meter from viable air samples collected from ISO 5 Hood #3 during production of"TESTOSTERONECYPIONATE/ENANTHATE OIL INJ ECTION 126/54 MG/ML INJECTABLE", lot 180108@25, RX ~b) (6)

    8. On 02/28/2018, your third-party contractor recovered I CFU/cubic meter from viable air particle monitoring during routine preventive maintenance of the ~b) (4) laminar air flow ISO 5 classified Hood #2. This hood was used to produce "NAO TRI HYDRATE 250 MG/V IAL LYOPHILIZED fNJECTABLE", lot 180430@16 on 0413012018, RX [(o) (6) J.

    C. Subsequently, on 0310812018. your firm recovered I CFU/cubic meter from viable air sample from ISO 5 classified Hood #4. This hood was used to produce "TESTOSTERONE ENANTHATE CYPIONA TE OIL INJECTION 126/54MG/ML INJ ECTABLE", lot 18031 4@ 17 on 03114/201 8, bf(6) .

    OBSERVATION 3

    Med ia fills were not performed that closely simulate aseptic production operations incorporating, as appropriate, worst-case activities and conditions that provide a challenge to aseptic operations.

  • DEPARTMENT OF HEAL TH AND HUMAN SERVICES

    FOOD ANO DRUG ADMINISTRATION

    DISTRICT OFFICE ADDRESS ANO PHONE NUMBER

    19701 Fairchild

    Irvine, CA 92612-2445

    (949)608-2900 Pax:(949)608-44 I 7

    lnduscry lnforma1ion: www.fda.gov/oc/industry

    DATE(S) OF INSPECTION

    71912018-8/2/201 8*

    FEI NUMBER

    3011893599

    NAME AND TITLE OF INDIVIDUAL TO 'MiOM REPORT IS ISSUED

    TO: Ashwin K. Pa1el, Chief Operations Officer FIRM NAME

    Auro Pham1acies. Inc. CITY. STATE ANO ZIP CODE

    La Habra, CA 90631-5308

    STREET ADDRESS

    520 W La Habra Blvd TYPE OF ESTABLISHMENT INSPECTED

    Producer of sterile and non sterile drug products

    AMENDMENT I

    Add Cont1nuahon Page

    EMPLOYEE(S) NAME AND TITLE (Print or Type) DATE ISSUED~SIGNATURE SEE

    REVERSE Kenneth 0. Gee, CSO OF THIS Andrew K. Hanek. CSO 08115/2018 PAGE I Karlhikcyan (NMl) Kanakarajan, CSO ~-&~~~Aark

    FORM FDA 483 (9/08) PREVIOUS EDITION OBSOLETE INSPECTIONAL OBSERVATIONS Page4 of 9

    Speci fically,

    A. Your firm had two media fill failures on I 0/06/2016 and subsequently on 03/08/20 I 8. Your fim1 continued processing sterile products despite these two media fill fai lures. For example:

    I. On 10/06/2016, a media fill batch was performed using11>H mL vials in lSO 5 classified Hood #4. Of the ~b>)( > mL vials in ISO 5 classified Hood #5. Of th ,(o) < >vials filled, one vial resulted in microbial growth. After this media fill failure, your firm continued to produce sterile drug products without implementing corrective and preventative actions.

    B. There is no hold time data to support that depyrogenated vials, sterilized stoppers and wipes that are used during the production of sterile drugs can be stored for indeterminate amount of time in your ISO 7 and ISO 8 areas.

    C. In addition, the validation study "VALIDATION OF HOLD TIME FOR STERILIZED GLASSWARE, UTENSILS & SUPPLIES", Y AL-SC-05.5002.0 I, addresses hold times for stoppers and other ~5) (4) I items used in sterile drug production. Yet this study does not address the following issues. For example:

    I. No simulation of tak ing stoppers and other items out from the ~b) (4l during the defined storage times. 2. The sample for bio burden detection were only incubated for [(o) (4) J while sterility testing requires an incubation time of[(5) (4)]. 3. The process does not appear to be part of a media 1111 simulation.

  • DEPARTMENT OF HEALTH AND HUMAN SERVICES

    NAME AND TITLE OF INDIVIDUAL TO WHOM REPORT IS ISSUED

    TO: Ashwin K. Patel. Chief Operations Officer 1--~--.,,,.-~~~~~~~~~~~~~~~~~~....-~~~~~-- ~~

    FIRM NAME STREET ADDRESS

    520 \V La Habra BlvdAuro Pharmacies, Inc. TYPE OF ESTABLISHMENT INSPECTEDCITY. STATE AND ZIP CODE

    Producer ofsterile and non sterile drug productsLa Habra, CA 9063 1-5308

    FOOD AND DRUG ADMINISTRATION

    DISTRICT OFFICE ADDRESS ANO PHONE NUMBER

    1970 I Fairchild

    Irvine, CA 92612-2445

    (949)608-2900 Fax:(949)608-4417

    Industry Information: ww\\ .fda.gov/oc/industry

    DATE(S) OF INSPE CTION

    7/9/20I8-8/2/2018*

    FEI NUMBER

    3011893599

    SEE REVERSE OF THIS PAGE

    AMENDMENT I

    Add Continuation Page

    EMPLOYEE(S) NAME AND TITLE (Pnnl or Type) DATE ISSUED

    Kenneth 0 . Gee, CSO Andrew K. Haack, CSO 08115/20 18 Karthikryan (NMI) Kanakarajan, CSO

    INSPECTIONAL OBSERVATIONS Page 5 of9

    OBSERVATION 4

    JS0-5 classified areas were not certified under dynamic cond itions. Specifically. uni-directional airflow was not verified under operational conditions.

    Specifically,

    Your dynam ic smoke study for ISO 5 classified Hood #2 and the ISO 5 (b) (4) , which demonstrates laminar airflow for the process of transferring via ls from Hood #2 to your b 4 . is inadequate in that it is not representative of your process, and objects that block airflow over the vials were observed. Furthermore. the video you provided cannot be adequately evaluated. For example, in the video your provided:

    A. No stoppers are present on the vials in the video you provided. Your process is to W..."'-1.-'-b 4

    ~~~~~J on

    vials as you transfer them from Hood #2 into the b 4

    B. You move vials b 4 as pa11 of the process to lransfer vials from Hood #2 to your(b) (4) . Wh ile vials move(

    ..,__,...,._,_b)(4)

    ~~~~~~~~~~~~~~~~~~~~~~~~~~...i

    . During this transfer, the flow of uni-directional air to the vials may be interrupted.

    C. The amount of smoke present in the video is insufficient to visualize uni-directional airflow in the region of the vials.

    OBSERVATION 5

    Vermin was observed in an area immediately adjacent to your production area.

  • DEPARTMENT OF HEALTH AND HUMAN SERVICES

    FOOD AND DRUG AOMINISTRATION

    DISTRICT OFFICE ADDRESS AND PHONE NUMBER OATE(S) OF INSPECTION

    19701 Fairchild 119120 1&-8121201 s

    Irvine, CA 92612-2445 - FEI NUMBER (949)608-2900 Fax:(949)608-44 I 7

    3011893599

    Industry Information: www.fda.gov/oc/induslry NAME ANO TITLE OF INDIVIDUAL TO IM-IOM REPORT IS ISSUED

    TO: Ashwin K. Patel, Chief Operations Officer ~~~--~~~~~~~~~~~~~~~~~~~~~~~~~~~-i

    FIRM NAME

    Auro Phannacies, Inc. CITY. STATE ANO ZIP CODE

    La Habra, CA 90631-5308

    STREET ADDRESS

    520 W La Habra Blvd TYPE OF ESTABLISHMENT INSPECTED

    Producer of sterile and non sterile drug products -

    SEE REVERSE

    OF THIS

    PAGE

    EM/f'J!'E(S) SIGNATURE

    G:f.-?~

    41/C,f~/~~ ;f

    AMENDMENT I

    Add Continuation Page

    EMPLOYEE(S) NAME ANO TITLE (Print or Type) DATE ISSUED

    Kenneth 0. Gee, CSO Andrew K. Haack, CSO Karthikeyan (NMI) Kanakarajan, CSO

    08/ 15/20 18

    FOR M FDA 4 83 (9108) PREVIOUS EDITION OBSOLETE INSPECTIONAL OB SERVATIONS Page 6 of9

    Specifically,

    On 07/09/20 18 we observed:

    A. Seven apparent ants along the floor wall-junction of the east wa ll ; and on the north wall of the pre-gown room, identified as room I 0 I. This room is where non-sterile hairnets and masks are donned. Jn addition, this room leads to the ISO 8 classified gowning room, where your operators don sterile gowns, hoods, and boots before entering the sterile suite.

    B. Additionally, on 07/09/2018 one apparent ant was observed on the outer surface of an FDA Investigator's sterile hood in the ISO 8 classified gowning room. This observation was made after he had exited the ISO 7 classified room where he observed the production of'TESTOSTERONE CYPIONATE/ENANTHATE OIL INJECTJON 126/54 MG/M L INJECTABLE", Jot 180709@2 l.

    OBSERVATION 6

    Personnel conducted aseptic manipulations in an area that blocked the movement of fi rst pass air around an open unit, either before or after it was fi lled with sterile product .

    Specifically,

    We observed a sterile technician using poor aseptic technique by placing his head and body into an ISO 5 classified [(o) (4) ] lam inar flow hood, identified as Hood #5 , while dispensing a drug purporting to be sterile after performing the final :Cb) (4) Jstep. The drug being dispensed was "TESTOSTERONE CYPl ONATE/ ENANTHATE OI L INJECTJON 160/40 MG/ML INJECTABLE", lot 180709@23.

  • DEPARTMENT OF HEALTH ANO HUMAN SERVICES FOOD AND DRUG ADMINISTRATION

    DISTRICT OFFICE ADDRESS AND PHONE NUMBER

    1970 I Fairchild

    Irvine, CA 92612-2445

    (949)608-2900 Fax:(949)608-44 I 7

    Industry Information: www.fda.gov/oc/industry NAME AND TITLE OF INDIVIDUAL TO WHOM REPORT IS ISSUED

    TO: Ashwin K . Patel, Chief Operations Officer FIRM NAME

    Auro Pharmacies, Inc. CITY, STATE AND ZIP CODE

    La Habra, CA 90631-5308

    DATE(S) OF INSPECTION

    119120 18-8121201 8

    FEI NUMBER

    3011893599

    STREET ADDRESS

    520 W La Habra Blvd TYPE OF ESTABLISHMENT INSPECTED

    Producer of sterile and non sterile drug products

    AMENDMENT I

    Add Continuation Page

    EMPLOYEE(S) NAME AND TITLE (Print or Type) DATE ISSUED

    SEE REVERSE I Kenneth 0 . Gee. CSO

    OF THIS Andrew K. Haack, CSO 08/15/20 18

    PAGE Karthikeyan (NMI) Kanakarajan, CSO

    FORM FDA 483 (9/08) INSPECTIONAL OBSERVATIONS Page 7 of9

    OBSERVATION 7

    Each component is not tested for conformity with all appropriate written specifications for purity, strength, and qual ity.

    Specifically, b 4 from your b 4 is used as an ingredient in the production of (b) (4) , non-sterile drug products. Regarding this, the following issues were observed:

    A. Your linn does not perfonn any microbial testing of the b 4 by your b 4 Additionally, your SOP, b 4 Operation, SOP-SC-01.1676.02, is deficient as the procedure does not require you to perform any microbial testing of the (15) (4) by your (15) (4)

    B. Your SOP(b) (4) Operation, SOP-SC-01.1 676.02. requires that 'lb> and (b) (4) be monitored, yet from 03/08/2018 to 07/16/2018 your firm has on ly monitored">. Your firm has not conducted any analytical b) 4 ) testing of the b 4 through your b 4 between the dates

    09/11/20 17 and 03/08/2018. For example, "'TETRACAINE HCL TOPICAL 2% SOLUTJON", lot 180212@2 l , made on 02/ 12/2018, RX (15) (6), shows b 4 ., was used as an ingredient.

    OBSERVATION 8

    The written stability testing program is not followed.

    http:SOP-SC-01.1676.02http:SOP-SC-01.1676.02

  • - -

    DEPARTMENT OF HEALTH AND HUMAN SERVICES

    FOOD AND DRUG ADMINI STRATION

    DISTRICT OFFICE ADDRESS AND PHONE NUMBER

    1970 I Fairchild

    Irvine, CA 92612-2445

    (949)608-2900 f'ax:(949)608-44 I 7

    Industry lnformation: www.fda.gov/oc/indL1Stl)' NAME AND TITLE OF INDIVIDUAL TO VVHOM REPORT IS ISSUED

    TO: Ashwin K. Patel, Chief Operations Officer FIRM NAME

    Auro Pharmacies, Inc. CITY. STATE AND ZIP CODE

    La Habra, CA 90631-5308

    OATE(S) OF INSPECTION

    119120J8-&12120 18 -FEI NUMBER 3011893599

    STREET ADDRESS

    520 W La Habra Blvd TYPE OF ESTABUSHMENTt NSPECTEO

    Producer of sterile and non steri le drug products

    - --E~NATURE

    SEE

    REVERSE

    OF THIS

    PAGE ~~~/4/~

    AMENDMENT I

    Add Cont1nuat1on Page

    EMPLOYEE(S) NAME ANO TITLE (Print or Type) DATE ISSUED

    Kenneth0. Gee. CSO Andrew K. Haack, CSO Kar1hikeyan (NMI) Kanakarajan, CSO

    08115/2018

    FORM FDA 483 (9108) PREVIOUS EDITION OBSOLETE INSPECTIONAL OBSERVATIONS Page 8 of9

    Specifically,

    Your firm has not conducted any stability studies to establish Beyond Use Dates (BUD) for your non-sterile drug products. For example, we observed: "TETRA CAINE HCL TOPICAL 2% SOLUTION.' of lot 180212@2 I, produced on 02/12/2018 where a BUD of 0511312018 was applied. You have no assurance that this BUD is appropriate.

    This is a repeat observation from the 2015 FDA inspection.

    OBSERVATION 9

    You have not established appropriate Beyond Use Dates for your products.

    You used stock solutions with 180 day (six-month) beyond use dates (BUD) as an ingredient in the production of sterile drug products. These following stock solutions were stored at room temperature in the ISO 7 classified clean room:

    A (o) (4 ) I, lot: r(o) (4 )1, prepared on: 02/26/2018, BUD: 08/25/2018

    B. f(b)(4 ) l, lot ~b) (4}t prepared on: 02/12/2018, BUD: 08/12/2018

    These stock solutions were used in the production of "FOLIC ACID INJECTION BENZYL ALCOHOL l 0 MG! ML INJECTABLE", lot J805 15@2 on 05/15/2018, RX [(b) (6) ~. with BUD of 08/12/2018 at room temperature.

  • DEPARTMENT OF HEAL TH ANO HUMAN SERVICES FOOD ANO DRUG ADMINISTRATION

    DISTRICT OFFICE ADDRESS AND PHONE NUMBER

    1970 I Fairchild

    Irvine, CA 92612-2445

    (949)608-2900 Fax:(949)608-44 I 7

    lndus1ry Information: www.fda.gov/oc/industry NAME AND TITLE OF INDIVIDUAL TO WHOM REPORT IS ISSUED

    TO: Ashwin K. Patel, Chief Operations Officer FIRM NAME STREET ADDRESS

    Auro Pharmacies, Inc. 520 W La Habra Blvd

    DATE(S) OF INSPECTION

    7/9/2018-812120 18*

    FEI NUMBER

    301 1893599 - ----~

    -----------~--!----------------------~ CITY. STATE AND ZIP CODE TYPE OF ESTABLISHMENT INSPECTED

    La Habra, CA 9063 I -5308 Producer of sterile and non sterile drug products

    FORM FDA 483 (9/08} PREVIOUS EDITION OBSOLETE INSPECTIONAL OBSERVATIONS Page 9 of 9

    OBSERVATION I 0

    Buildings used in the manufacture, processing, packing, or holding ofa drug product do not have the suitable construction to facilitate cleaning, maintenance, and proper operations.

    Specifically,

    A. On 07/09/2018, we observed a gap, approximately I /4 inch by 1 /2 inch, under the south door that opens to a hallway leading to the unclassified pre-gown room.

    8 . On 07/18/2018, in the ISO 8 classified prep room, we observed a lack of ~ackf1ow protection devices on the sink where municipal water and :(b) (4 ) is supplied. Water from these supplies are used to wash equipment and utensils used in the production of sterile drug products; and [of(4 ) ~ J -------~~~~~~~--

    DATES OF INSPECTION *7/09/201 8(Mon), 7/10/201 8(Tue), 7/ l l/20 18(Wed), 7/12/20 18(Thu), 7/13/2018(Fri). 7/16/201 8(Mon). 7/ 17/2018 (Tue), 7/18/20 J8(Wed), 7/ 19/20 I 8(Thu), 7/20/2018(Fri), 7/3 1/20 I8(Tue), 810 I /20 I 8(Wed), 8/02/20 I 8(Thu)

    AMENDMENTl

    Add Continuation Page

    l ~IGNATURE IEMPLOYEE(S) NAME ANO TITLE (Pnnt or Type) Kenneth 0 . Gee, CSO

    Andrew K . Haack. CSO Karthikeyan (NMI) Kanak.arajan, CSO

    IDATE ISSUED

    I08115120 18

    SEE

    REVERSE OF THIS

    PAGE Vlw?4cft'~ I

    DEPARTMENT OF HEALTH ANO HUMAN SERVICES FOOD AND DRUG ADMINISTRATION OBSERVATION 2 OBSERVATION 3 OBSERVATION 4 OBSERVATION 5OBSERVATION 6 OBSERVATION 7 OBSERVATION 8OBSERVATION 9 OBSERVATION 10DATES OF INSPECTION