US FDA
21 CFR 600.12 - Records - Biological Products
Plain-language explanation, inspection context and common violation patterns.
What it says
Records relating to the manufacture of biological products must be maintained in a manner that allows accurate and ready identification of the manufacturing history of each lot, retained for a defined period, and made readily available to FDA for inspection and copying upon request.
Paraphrased for plain-language clarity. Always verify against the current published regulation text.
What it means in practice
- The readily available standard means records must be organized and accessible in practice, not merely retained somewhere, since a biologics manufacturer that cannot promptly produce lot history records during an inspection can itself become a finding.
- Because biological products carry inherent lot-to-lot variability, complete and traceable manufacturing records are relied on more heavily than in many small-molecule contexts to reconstruct exactly what happened to a specific lot.
- Record retention periods for biologics are tied to product-specific factors such as expiration dating, so a manufacturer must track retention obligations per product rather than applying one blanket retention rule.
What FDA inspectors look for
- Whether requested lot manufacturing records can actually be retrieved and produced promptly during the inspection, not just confirmed to exist somewhere.
- Whether retained records are complete enough to reconstruct the full manufacturing history of a specific lot, including materials, in-process testing and deviations.
- Whether record retention periods applied match the specific requirements tied to that product's expiration dating and use.
Most common violation
Lot manufacturing records that exist but cannot be promptly retrieved and produced during an inspection due to poor organization or incomplete archiving.
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