Form FDA 483 · Issued 2026-03-06
IsoTis OrthoBiologics, Inc. — FDA Form 483 Analysis
FEI: 3001503333 · Sector: Pharmaceuticals & Sterile/OTC Drugs (HCT/P Processor and Distributor) · Lead Investigator: Rebecca M. Okafor
FDA Form 483 issued to IsoTis OrthoBiologics, Inc. (FEI 3001503333) on 2026-03-06 following an inspection of its hct/p processor and distributor operations in California. The report documents 4 inspection observations centered on Master Manufacturing & Batch Production Records (MMR/BPR), Incoming Ingredient Identity Testing & COA Qualification.
Get Full Annotated 483 Dossier + CAPA Checklist
Instant PDF + CFR Matrix ($79 vs. Redica's $289)
Need Help Fixing These 4 Citations?
Get matched with a vetted 21 CFR remediation consultant
Observation-by-Observation 21 CFR Breakdown (4)
Observation #1 · 21 CFR 211.100(a)
Master Manufacturing & Batch Production Records (MMR/BPR)
FIRST-TIME OBSERVATION
Approval and review of procedures
Inspector Observation Language: "Written procedures are not [drafted, reviewed and approved by the appropriate organizational units] [reviewed and approved by the quality control unit]. Specifically, observed during inspection of IsoTis OrthoBiologics, Inc. on 2026-03-06."
Plain-English Meaning: Missing Master Manufacturing Records (MMRs) or incomplete Batch Production Records (BPRs) lacking exact component weights, lot numbers, yield reconciliation, or second-person verification.
Standard CAPA Remediation Path: Ensure every product SKU has an approved MMR matching the exact label claim and every batch record captures raw material lot traceability, in-process weight/pH checks, and QA release signatures.
Observation #2 · 21 CFR 211.80(a)
Incoming Ingredient Identity Testing & COA Qualification
FIRST-TIME OBSERVATION
Written Procedures Not Followed
Inspector Observation Language: "Written procedures are not followed for the [receipt] [identification] [storage] [handling] [sampling] [testing] [approval] [rejection] of [components] [drug product containers] [closures]. Specifically, observed during inspection of IsoTis OrthoBiologics, Inc. on 2026-03-06."
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 #3 · 21 CFR 211.194(a)(2)
Electronic Record Data Integrity (21 CFR Part 11) & Retention
FIRST-TIME OBSERVATION
Suitability of testing methods verified
Inspector Observation Language: "The suitability of all testing methods is not verified under actual conditions of use. Specifically, observed during inspection of IsoTis OrthoBiologics, Inc. on 2026-03-06."
Plain-English Meaning: Uncontrolled spreadsheets, shared laboratory logins, missing audit trails, backdated entries, or failure to retain batch and distribution records for the statutory window.
Standard CAPA Remediation Path: Enforce unique user credentials, immutable audit trails on analytical instruments, controlled form issuance numbers, and 2-year post-expiration record retention.
Observation #4 · 21 CFR 211.28(a)
Electronic Record Data Integrity (21 CFR Part 11) & Retention
REPEAT CITATION AT FACILITY
Protective Apparel Not Worn
Inspector Observation Language: "Protective apparel is not worn as necessary to protect drug products from contamination. Specifically, observed during inspection of IsoTis OrthoBiologics, Inc. on 2026-03-06."
Plain-English Meaning: Uncontrolled spreadsheets, shared laboratory logins, missing audit trails, backdated entries, or failure to retain batch and distribution records for the statutory window.
Standard CAPA Remediation Path: Enforce unique user credentials, immutable audit trails on analytical instruments, controlled form issuance numbers, and 2-year post-expiration record retention.