Form FDA 483 · Issued 2025-09-19
A. Nelson & Co. Ltd. — FDA Form 483 Analysis
FEI: 1000568184 · Sector: Pharmaceuticals & Sterile/OTC Drugs (API and Homeopathic Drug Product Manufacturer) · Lead Investigator: Priya N. Subramanian
FDA Form 483 issued to A. Nelson & Co. Ltd. (FEI 1000568184) on 2025-09-19 following an inspection of its api and homeopathic drug product manufacturer operations in United Kingdom. The report documents 2 inspection observations centered on Incoming Ingredient Identity Testing & COA Qualification, Finished Product Testing, Stability & Expiration Dating.
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Observation-by-Observation 21 CFR Breakdown (2)
Observation #1 · 21 CFR 211.101(d)
Incoming Ingredient Identity Testing & COA Qualification
FIRST-TIME OBSERVATION
Verification of component addition
Inspector Observation Language: "Each component is not added to the batch by one person and verified by a second person.. Specifically, observed during inspection of A. Nelson & Co. Ltd. on 2025-09-19."
Plain-English Meaning: Failure to perform at least one test to verify the identity of every incoming dietary ingredient or raw component before use, or relying on a supplier's Certificate of Analysis (COA) without first qualifying the supplier.
Standard CAPA Remediation Path: Establish SOP-QA-004 requiring FTIR/HPLC/organoleptic identity testing on 100% of incoming dietary ingredient lots and annual audit + 3-lot confirmatory testing before relying on any vendor COA.
Observation #2 · 21 CFR 211.160(b)(3)
Finished Product Testing, Stability & Expiration Dating
REPEAT CITATION AT FACILITY
Sampling/testing of drug products
Inspector Observation Language: "The specifications for drug products are deficient in that they do not include a description of the [sampling plan] [testing procedures] for drug products. Specifically, observed during inspection of A. Nelson & Co. Ltd. on 2025-09-19."
Plain-English Meaning: Releasing finished batches without verifying strength/potency/microbiological specs, or placing an expiration/best-by date on labels without supporting real-time or accelerated stability data.
Standard CAPA Remediation Path: Require finished-batch microbiological (USP <2021>/<2022>), heavy metal, and active-assay release testing plus ICH stability chamber protocols supporting every label shelf-life claim.