FDA inspections in laboratory animal facilities or
preclinical research labs are stringent, and even minor oversights can delay
approval or trigger critical findings. To ensure a smooth and successful
inspection, several key areas—ranging from personnel records to
infrastructure—must be thoroughly prepared and documented. Here's a detailed
guide on what you must have in place before an FDA inspection.
1. Training Records: Keep Your
Team Audit-Ready
Ensure that training records for all attendants
and staff are updated and available for at least the past one year.
These records serve as proof that the staff is well-versed in standard
procedures, animal handling, and emergency protocols. Arrange training by two
external experts before inspection. Make sure their visit is scheduled and
documented.
Each staff member and animal attendant must possess
a valid health certificate issued by a qualified MBBS or MD physician.
The certificate should include:
- Tetanus
injection status
- Recent
Chest X-ray findings
Keep both physical and digital copies ready
for review.
3. Qualified Microbiologist: No
Lab is Complete Without One
The facility must have a designated
microbiologist who understands and can demonstrate:
- Fecal
microbial load count during animal quarantine
- Pre-
and post-UV feed microbial testing methods
- Water
microbial testing protocols
- Maintenance
of internal microbial records
Absence of a microbiologist is a major FDA red
flag.
4. Veterinarian Onboard:
Regulatory Requirement
A veterinarian is a mandatory position
in any laboratory animal facility. Ensure that:
- A licensed
vet is recruited
- Their
training records and health certificate are part of the
institutional archive
Include details in the personnel folder.
5. Histopathology Department:
Skilled Technician Required
If your facility includes histopathology
services, a trained technician must be available and capable of
handling tissue preparation and analysis.
Be ready to demonstrate procedures if asked.
6. Pharmacy Background Staff:
Non-Negotiable
At least two individuals with a pharmacy
background (preferably in QA/QC roles) should be part of the team.
Their role is crucial in ensuring the integrity of drug storage, documentation,
and quality assurance practices.
7. Study-Based Approval: Sample
Availability Matters
As the FDA inspects facilities for study-based
approvals, be prepared to present:
- At
least 10 marketed product samples
- Results
of Pyrogen testing, abnormal toxicity, and LDPE (Low-Density
Polyethylene) testing
Keep raw data and reports accessible.
8. First Aid Kit: Simple but
Essential
A well-stocked and easily accessible first aid
kit is mandatory. Check expiry dates and replace used or expired items.
9. Cold Storage Facilities: For
Ethical & Practical Compliance
Make available:
- A deep
freezer for storing dead animals until proper disposal
- Liquid
nitrogen storage for
sensitive biochemical samples
10. Hot Air Oven: Pyrogen Testing
Needs It
Ensure your Hot Air Oven is functional
and calibrated, as it is required for pyrogen testing. If it’s under
repair, expedite the process.
11. Water Distillation Assembly:
Functionality is Key
The distillation unit should be operational.
Clean it, test it, and document its working condition.
12. Avoid Multifunctional Staff
Roles
Do not present multifunctional roles (e.g.,
one person acting as animal handler, technician, and QA). FDA prefers clear
role segregation.
Small But
Critical: Miscellaneous Requirements
Before inspection, make sure you’ve stocked these
items:
Lab Supplies:
- 500 tissue
containers
- 30 rabbit
cage trays
- 5 kg
chana (gram)
- Gloves,
masks, head covers
- 100 water
bottle tips
- 6
bags rabbit feed & 3 bags rat feed
- 2
vials (10 ml each) Ketamine injection
- 2 ×
100 pcs EDTA tubes
- 3
rolls aluminum foil
Emergency:
- First
Aid kit (stocked and labeled)
Instrumental
& Infrastructure Requirements
- Stainless
steel table
(approx. 4 ft × 3 ft) – fixed and clean
- Ensure
all major lab equipment (oven, freezers, distillers, etc.) are operational
and maintenance logs are up-to-date
Final Thoughts
FDA inspections are detailed, but they’re also predictable when
you know what to expect. By ensuring proper documentation, role segregation,
qualified staff, and functional infrastructure, you make your facility audit-ready
and compliant.
Prepare once, stay ready always.
Let me know if you’d like a checklist version or this content converted into a printable SOP/poster.
END OF THE DOCUMENT
You may like to read these links:
1. Check Out the Tricks and Tips with Some Trouble Points While Conducting in OECD 407 and 408
2. List of OECD Guidelines or Toxicological Studies
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