Are You Smarter Than An Ora Inspector? Test Your Knowledge Of Aseptic Cgmps

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Agnesshanley
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How do FDA plant inspectors select the best categories for noting observations on 483's? This quiz focuses on 21 CFR 211.192 and 21 CFR 211.113(b). Choose the best answer to each question. Your test will be graded as you take it. If you receive a perfect score, please write in via the "Comments" section and let us know. You will be sent a prize.


Questions and Answers
  • 1. 

    21 CFR Part 211 only relates to finished drug products

    • A. 

      All of the time

    • B. 

      Some of the time

    • C. 

      Never

    Correct Answer
    B. Some of the time
    Explanation
    21 CFR Part 211, which stands for Code of Federal Regulations Title 21 Part 211, is a set of regulations established by the U.S. Food and Drug Administration (FDA) that specifically pertains to Current Good Manufacturing Practice (cGMP) for finished pharmaceutical products. These regulations outline the requirements for the manufacturing, processing, packaging, and holding of drug products. However, it is important to note that there may be instances where certain provisions of 21 CFR Part 211 do not apply to all drug products, such as investigational drugs or certain exemptions provided by the FDA. Therefore, the statement "21 CFR Part 211 only relates to finished drug products" is correct, but it is not applicable in all cases.

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  • 2. 

    Can different sections of 21 CFR Part 211 be cited by an Investigator when issuing a single Observation to a pharmaceutical company?

    • A. 

      Yes, it is possible to interchange many sections within Part 211

    • B. 

      No, only a single section of Part 211 can be used with a specific type of observation (e.g. 21 CFR Part 211.113(b)

    • C. 

      Only in selected instances

    Correct Answer
    A. Yes, it is possible to interchange many sections within Part 211
  • 3. 

    What is the meaning of the phrase "whether or not the batch has already been distributed?"

    • A. 

      The lot at hand would be extensively investigated

    • B. 

      The lots distributed would be extensively evaluated

    • C. 

      Both A and B

    Correct Answer
    C. Both A and B
    Explanation
    The phrase "whether or not the batch has already been distributed" means that the investigation or evaluation process applies to the lot regardless of whether it has been already distributed or not. Both options A and B suggest that the lot at hand will undergo extensive investigation or evaluation, indicating that the meaning of the phrase is encompassed by both options.

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  • 4. 

    Why is there a 21 CFR 211.113(a) and a 21 CFR 211.113(b)?  21 CFR 211.113(a) refers to which of the following?

    • A. 

      Contamination of products not required to be sterile

    • B. 

      Contamination of products required to be sterile

    • C. 

      Both A and B

    Correct Answer
    C. Both A and B
    Explanation
    The reason why there is a 21 CFR 211.113(a) and a 21 CFR 211.113(b) is because they address different aspects of contamination in pharmaceutical products. 21 CFR 211.113(a) refers to the contamination of products that are not required to be sterile, while 21 CFR 211.113(b) refers to the contamination of products that are required to be sterile. Therefore, the correct answer is both A and B, as both types of contamination are addressed separately in the regulations.

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  • 5. 

    Failure to conduct adequate investigations of three media fill failures in the aseptic filling line represents what kind of Observation?  What would the Investigator write?

    • A. 

      21 CFR Part 211.192

    • B. 

      21 CFR Part 211.113(b)

    • C. 

      Neither

    Correct Answer
    A. 21 CFR Part 211.192
    Explanation
    The correct answer is 21 CFR Part 211.192. This regulation states that failure to conduct adequate investigations of media fill failures in the aseptic filling line represents a major observation. The investigator would likely write a report detailing the failure to conduct proper investigations and recommend corrective actions to address the issue.

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  • 6. 

    A "release of batches before the last successful media fill had been performed" represents what kind of observation? 

    • A. 

      21 CFR Part 211.192

    • B. 

      21 CFR Part 211.113(b)

    • C. 

      Neither A nor B

    Correct Answer
    A. 21 CFR Part 211.192
    Explanation
    The correct answer is 21 CFR Part 211.192. This regulation states that a "release of batches before the last successful media fill had been performed" represents an observation related to the production and process control system. It indicates that batches were released without completing the necessary quality control measures, specifically the media fill test, which is used to validate the aseptic manufacturing process. This observation highlights a potential non-compliance with good manufacturing practices and the need for corrective actions to ensure product safety and quality.

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  • 7. 

    "The media fill program does not include all major contamination risk factors in your aseptic process, and, consequently, does not sufficiently demonstrate the state of the process control" represents what kind of observation?

    • A. 

      21 CFR Part 211.192

    • B. 

      21 CFR Part 211.113(b)

    • C. 

      Neither A nor B

    Correct Answer
    B. 21 CFR Part 211.113(b)
    Explanation
    The given correct answer, 21 CFR Part 211.113(b), represents an observation that the media fill program does not adequately demonstrate the state of process control in the aseptic process. This means that the program does not include all the major contamination risk factors, which could potentially compromise the integrity and safety of the process. Therefore, it is necessary to address this observation and make improvements to ensure proper control and minimize contamination risks.

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  • 8. 

    "You failed to perform adequate unidirectional airflow pattern studies (i.e., smoke studies for the aseptic filling line used for the production of (b) (4) injections" represents what kind of observation?

    • A. 

      21 CFR Part 211.192

    • B. 

      21 CFR Part 211.113(b)

    • C. 

      Neither A nor B

    Correct Answer
    B. 21 CFR Part 211.113(b)
    Explanation
    The given correct answer, 21 CFR Part 211.113(b), represents a specific observation related to the failure to perform adequate unidirectional airflow pattern studies for the aseptic filling line used for the production of (b) (4) injections. This observation indicates a violation of the regulation that requires the performance of such studies to ensure the proper functioning of the aseptic filling line and maintain the sterility of the injections.

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