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This docwuent lists observations made by the FDA representative(s) dwmg the inspection of your facility. They are inspectional
observations, and 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, conective action in response to an observation, you may discuss the obj ection or
action w-ith the FDA representative{s) dwmg the inspection or submit this infonuation to FDA at the address above. If you have any
questions, please contact FDA at the phone ntllllber and address above.
Specifically , hold t ime studies have not been performed for(b){'f~ in-process stages of testosterone
pell ets and estradiol pellets.
OBSERVATION 2
There are no written procedures for production and process controls designed to assure that the
drug products have the identity, strength, quality, and purity they purport or are represented to
possess.
Specifically ,
1. Process va lidation has not been performed for the any of the four unique hormone pellets drug
products man ufactured on site . No procedu res are established for the ongoing period ic mon itoring
of the drug man ufacturing process .
SEE REVERSE
OF THIS PAGE
Zachary L St amm, I nvestigat or
Zachary A Bogorad, I nvest i gat or
_
X Zadlar( A Bogoracl
.._._..
...
Slgntdi: ZXNryA.IIaglcnd~
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FORM FDA 483 (09/08) PREVIOUS EDmON OBSOLETE INSPECTIONAL OBSERVATIONS PAGE I OF3 PAGES
DEPART!\fi: NT OF HEALTH AND H UMAi' l SERVICES
Testosterone 12 .S, 2S, 37.S, so, 62 .S, 70, 80, 87.S, 100, 112.S, 200
Estrad iol 6, 10, 12.S, 1S, 18, 20, 22, 2S, 37.S, so, 7S
Progesterone 2S, 3S, so, 7S
Anastrozole 6
2. Equ ipment qualifications have not been assessed for the ~15} (4} I
The (t!>:(4 l -(oH4r 1
testosterone as well as estradiol active pharmaceutical
ing red ients . No end point to the I -(b) (4) ,has been identified. You have not collected
data in support of t he efficacy and reprod uci bility of t he I -(b) 4) JThere are no
defined cr iteria for the end point of t he 1 (b (4f J
3. Equipment qualifications have not been assessed f or r -(or<4r l incubators model (o) ( 4)
Incubators are used to store environmenta l monitoring plates. No procedu res are established for
t he ongoing periodic mon itoring of laboratory eq uipment.
IX Zachary L Stamm
Zad>ary l Stanm
lrwestigator
SEE REVERSE
OF THIS PAGE
Zachar y L St amm, I nvestigat or
Zachary A Bogorad, I nvest i gat or
_
X Zadlar( A Bogoracl
.._._..
...
Slgntdi: ZXNryA.IIaglcnd ~
"""'" 9/2/20 1 6
FORM FDA 483 (09/08) PREVIOUS EDmON OBSOLEJE INSPECTIONAL OBSERVATIONS PAGE20F3PAGES