FDA Records Requests
When FDA asks for your records instead of visiting, we help you decide what to send, organize it so it reads well, meet the deadline, and fix the gaps the request exposes before they turn into an inspection finding.
"Keep it Simple. Keep it Real."
What you get
A remote regulatory assessment is an inspection conducted on paper. What you send, and how it is organized, is the only thing FDA sees. This is how we help.
What FDA is actually asking for, what the regulation requires you to provide, the deadline, and what it suggests about why FDA asked.
Records gathered, checked for completeness and consistency, indexed, and accompanied by a cover letter that explains what each item is and where to find it.
The weaknesses the request exposed, such as missing records, procedures that do not match practice, or registrations that are out of date, ranked by risk.
The fixes to make before the inspection that often follows a records request, so the investigator finds them already closed.
How It Runs
Send us the request the day it arrives. We confirm the scope, the deadline, and the legal basis for the request.
We work with your team to collect, review and organize the records, and draft the cover letter for your signature.
After the package goes, the gap list and a plan to close each item before FDA's next contact.
Scope
FDA uses remote regulatory assessments to evaluate facilities without, or before, an on-site inspection. For drug manufacturers, including OTC drug sites, section 704(a)(4) of the Federal Food, Drug, and Cosmetic Act lets FDA require records in advance of or in place of an inspection, and refusing or delaying can carry the same consequences as refusing an inspection. Other product types may receive voluntary requests, and FDA has published guidance describing how it conducts them.
A records request is often the first sign that FDA is looking closely at a site. We have helped clients through exactly this situation: a request that was answered, closed out, and still showed the company that its system was not ready for an inspection. The request is worth treating as a free look at where FDA will start.
For an on-site inspection, see FDA inspection readiness and support. For OTC drug quality systems in general, see OTC drug GMP.
Price And Terms
Every engagement is priced in writing after a free 30-minute call and before any work starts. On-site work is scheduled in full days; travel from Salt Lake City is billed at cost, with no markup, after the visit. You own every report and record we produce.
Fees depend on how many records are requested and how fast they are due. Because these requests come with deadlines, we quote the same day you send the request.
From $3,500, depending on how many records FDA asked for and how soon they are due. Because these requests come with deadlines, we quote the same day you send the request.
An evaluation of a facility that FDA carries out without being on site, by requesting and reviewing records, and sometimes through video calls or livestreamed walk-throughs. Some are mandatory, such as records requests to drug establishments under section 704(a)(4), and some are voluntary.
For drug establishments, yes. The law lets FDA require the records, and delaying, limiting or refusing a request can be treated like refusing an inspection, which can make your products adulterated. Respond within the time FDA gives, and ask for clarification early if the scope is unclear.
Not always, but often. FDA uses records reviews to decide where to inspect and what to look at when it does. It is sensible to assume the investigator will arrive having read everything you sent.
You can, but you usually should not. Send what was requested, complete and organized, with a short explanation where context helps. Extra material can widen the review without helping you.
Your Consultant
Jared Clark, our principal consultant, leads every engagement. He has spent his career in quality systems, FDA liaison work and regulatory affairs for pharmaceutical, dietary supplement, OTC drug, cosmetic and medical device manufacturers, and founded Certify Consulting in 2016. He holds the ASQ Certified Quality Auditor (CQA), Certified Manager of Quality/Organizational Excellence (CMQ/OE) and Certified Pharmaceutical GMP Professional (CPGP) certifications, and has worked through certification and surveillance audits alongside NSF, UL, Intertek, SGS and ANAB-accredited registrars. His full credentials and their verification links are on the About page.
Related Services
Ready before FDA arrives, and an experienced hand in your back room while the investigator is there.
Drug GMP under 21 CFR 210/211 for cosmetic and personal care makers moving into OTC products.
A Form 483 or warning letter response with real root causes and evidence, inside 15 business days.
Book a free 30-minute call, or call 858-240-4353 if a deadline is close. We will read the request with you and quote the same day.
Or email us at support@certify.consulting