WARNING LETTER Teligent Pharma, Inc. MARCS-CMS 587592 — NOVEMBER 26, 2019

1. Your firm failed to thoroughly investigate any unexplained discrepancy or failure of a batch or any of its components to meet any of its specifications, whether or not the batch has already been distributed (21 CFR 211.192).
Your investigations into out-of-specification (OOS) test results were inadequate. You failed to investigate OOS results in a timely manner, appropriately justify potential root causes, expand investigations to all potentially affected lots, implement corrective and preventive actions (CAPA), and evaluate CAPA effectiveness.
A. During release testing you obtained OOS individual impurity results for clobetasol propionate finished drug product lot 8922 in June 2017. Re-analysis of the original samples confirmed the OOS result. You then obtained passing results after (b)(4) your samples. Your investigation concluded, without adequate supporting evidence, that the root cause was "most likely due to lot-specific sample interaction with the (b)(4) during sample preparation." Despite the lack of supporting evidence, you released the lot.
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