FDA WARNING_LETTER - Luitpold Pharmaceuticals, Inc. - March 15, 2011

The FDA issued a Warning Letter to Luitpold Pharmaceuticals, Inc. following a February 9 to March 15, 2011 inspection of their Shirley, NY facility, identifying significant Current Good Manufacturing Practice (CGMP) violations, rendering their drug products adulterated. The firm's April 5, 2011 response was deemed insufficient.

Key violations include: 1. **Inadequate Production and Process Controls (21 C.F.R. § 211.100(a)):** * SOP 103.14's (b)(4) reject threshold for investigations is not scientifically justified and contradicts investigation needs. The firm's commitment to review and apply statistical criteria was inadequate as it lacked assessment of different particulate types and interim controls. * Sample sizes for sub-visible particulate testing via (b)(4) method (SOP 302.11) were not adequately justified, leading to incorrect acceptance/rejection criteria and inconsistent sampling plans. * SOP 103.05 lacked adequate instructions for root cause analysis, failing to extend investigations to other lots, examine trends, or evaluate limits, contributing to persistent particulate contamination issues (e.g., (b)(4) lots in 2009, over (b)(4) lots since 2010). The firm's proposed new