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  1. Warning Letters

WARNING LETTER

Jabil Inc. MARCS-CMS 731037 —

Delivery Method:
VIA UNITED PARCEL SERVICE
Reference #:
320-26-120
Product:
Drugs
Recipient:
Recipient Name
Mr. Michael Dastoor
Recipient Title
Chief Executive Officer and Director
Jabil Inc.

10800 Roosevelt Blvd. N.
St. Petersburg, FL 33716
United States

(b)(4)
Issuing Office:
Center for Drug Evaluation and Research (CDER)

United States

August 27, 2026

WARNING LETTER
Reference number: 320-26-120

To Mr. Michael Dastoor:

This warning letter advises you of significant violations observed during a U.S. Food and Drug Administration (FDA) inspection of your products and facilities. Promptly address the violations described herein without delay, including ensuring that appropriate resources are allocated to fully address the violations and prevent their recurrence. This is not intended to be an all-inclusive list of the violations that exist at your facility. It is your responsibility to ensure that your firm complies with all requirements of federal law, including FDA regulations. Failure to adequately address violations may result in regulatory action without further notice including, without limitation, seizure and injunction.

FDA Inspection

Violations were observed and documented during an inspection of your drug manufacturing facility, Pharmaceutics International, Inc. (a Jabil Company), FDA Establishment Identifier (FEI) 3006503102, at 103 Beaver Court, Cockeysville, MD, from February 23 to March 6, 2026. This inspection was conducted under FDA’s statutory authority and public health responsibilities to protect the public from unsafe, ineffective, and poor quality drugs.

This warning letter summarizes significant violations of Current Good Manufacturing Practice (CGMP) regulations for finished pharmaceuticals. See Title 21 Code of Federal Regulations (CFR), parts 210 and 211 (21 CFR parts 210 and 211).

Because your methods, facilities, or controls for manufacturing, processing, packing, or holding do not conform to CGMP, your drug products are adulterated within the meaning of section 501(a)(2)(B) of the Federal Food, Drug, and Cosmetic Act (FD&C Act), 21 U.S.C. 351(a)(2)(B).

We reviewed your March 27, 2026, response to our Form FDA 483 in detail and acknowledge receipt of your subsequent correspondence.

Violations of the Federal Food, Drug, and Cosmetic Act

The following are violations identified during our inspection and review. As a reminder, this is not an all-inclusive list of violations at your facility.

1. Your firm failed to thoroughly investigate any unexplained discrepancy or failure of a batch or any of its components to meet any of its specifications, whether or not the batch has already been distributed (21 CFR 211.192).

Your firm operates as a contract manufacturer of sterile injectables for (b)(4). You failed to adequately investigate a sterility test failure as well as recurring mold recoveries in the ISO 5 (Grade A) filling area.

Sterility Failure

You did not adequately investigate a failed sterility test result for your aseptically filled (b)(4) mg/(b)(4)ml. Your firm identified Ustilago spermophora, a fungi, in (b)(4) medium. Your investigation’s root cause finding of “undetermined” was inadequate. Although your firm rejected this batch, your investigation did not thoroughly examine all possible root causes including but not limited to potential routes of fungi migration through your classified areas (e.g., personnel/material flow hazards, HVAC hazards, inadequate disinfection). Additionally, your investigation lacked adequate corrective action and preventive action (CAPA) responses.

In your response, we acknowledge your intentions to strengthen investigation requirements, perform a retrospective review of investigations, and review the facility’s contamination control strategy. However, your response does not specifically address the sterility failure investigation.

Environmental Monitoring (EM) Action Level Excursions

Your firm’s investigations into multiple instances of fungi contamination on and below the (b)(4) of aseptic processing lines have been inadequate. For example:

  • On March 20, 2024, Chaetomium globosum was recovered below the (b)(4) of the (b)(4) vial machine in suite (b)(4) after filling a batch of (b)(4) mg/(b)(4)ml. Your investigation was inadequate as it did not adequately evaluate potential root causes, including whether the mold was introduced during filling operations. You released the product without sufficient investigation.
  • On May 16, 2025, fungi was recovered in two locations within the (b)(4) filling line in suite (b)(4). The passive air sample recovered Didymella glomerata during the filling of (b)(4) injection. You attributed the mold recovery to a power failure that occurred during filling. Notably, surface monitoring below the (b)(4) also recovered Mycosphaerella africana after the power was restored. The investigation lacked sufficient CAPA.
  • On June 4, 2025, Chaetomium cruentum/globosum was recovered from the (b)(4) of the (b)(4) vial machine in suite (b)(4) after filling a batch of (b)(4) mg/(b)(4)ml. Your firm rejected the batch but failed to adequately investigate likely root causes. You stated within the investigation, “historically there has never been a mold hit isolated on the grade A space on the (b)(4) filling Line,” however the same mold, Chaetomium globosum, had been recovered, on March 20, 2024, on the same line. The investigation lacked CAPA.

Overall, trends of fungal recoveries within your suites (b)(4), and supporting cleanrooms, have significantly increased since 2023. Your firm has closed investigations without implementing robust CAPA. Your firm also has not adequately evaluated the ongoing trend of adverse findings of fungi within your aseptic production area, directly within product, and on product contact surfaces over time.

In your response you commit to revise your procedures to perform routine trend analysis and strengthen your investigations. Your response is inadequate because you indicate that product impact conclusions in investigations were appropriate based on a lack of sterility failures, adverse environmental monitoring trends, and complaints, but fail to sufficiently address contamination sources. Your firm has not demonstrated that you have remediated your investigational capabilities to ensure scientifically rigorous investigations to effectively identify root causes so that appropriate CAPA can be implemented.

To ensure proper root cause analysis and appropriate CAPA implementation, investigations must be thorough, well-documented, scientifically sound, and timely. Procedural updates and training alone do not address the systemic failures that allowed deficient investigations to persist undetected by quality unit (QU) oversight.

In response to this letter, provide:

  • A comprehensive, independent assessment of your overall system for investigating deviations, discrepancies, complaints, out-of-specification results, and failures. Provide a detailed action plan to remediate this system. Your action plan should include, but not be limited to, significant improvements in investigation competencies, scope determination, root cause evaluation, CAPA effectiveness, QU oversight, and written procedures. Address how your firm will ensure all phases of investigations are appropriately conducted.
  • An independent assessment and remediation plan for your CAPA program. Provide a report that evaluates whether the program includes effective root cause analysis, ensures CAPA effectiveness, analyzes investigation trends, improves the CAPA program wherever needed, ensures final QU decision authority, and is fully supported by executive management.
  • A comprehensive, independent risk assessment of all contamination hazards with respect to your aseptic processes, equipment, and facilities, including but not limited to, the following:
    o All human interactions within the ISO 5 area (e.g., risk reduction or elimination of manual interventions wherever possible)
    o Equipment suitability (e.g., reliability, capability, ergonomics, placement) and sufficient cleanroom space
    o Air quality in the ISO 5 area and surrounding room including, but not limited to, air volume and flow
    o Facility layout
    o Personnel Flow and Material Flow (movement throughout all rooms used to conduct and support sterile operations, and all material transfers)
    o Specific CAPA recommendations that will comprehensively address the design and control hazards identified in the risk assessment
  • A detailed remediation plan with timelines to address the findings of the contamination hazards risk assessment. Describe specific tangible improvements to be made to aseptic processing operation design and control at your facility and explain how this CAPA plan will robustly remediate your deficient sterile manufacturing operations. Include comprehensive changes to the design of both your aseptic processing lines and cleanrooms. Also, describe your plans for qualification and validation of your extensively remediated operations.
  • An independent, comprehensive review of your EM program to ensure vigilant, timely detection and response to potential product contamination hazards in your manufacturing environment. This assessment should include, but not be limited to:
    o establishing appropriate limits,
    o sampling methods,
    o sampling locations and frequencies,
    o trend analysis,
    o appropriate investigation of deviations and adverse trends,
    o and a comprehensive CAPA plan based on the findings of the assessment.

2. Your firm failed to establish adequate written responsibilities and procedures applicable to the quality control unit (21 CFR 211.22(d)).

Your QU did not provide adequate oversight for the manufacture of your drug products. For example, your QU failed to ensure:

  • Documentation of all interventions during filling of sterile drug products. Our investigators observed multiple batch records in which operators failed to document most aseptic interventions. For example, the batch record for (b)(4) injection (b)(4) mg/(b)(4)ml, on February 6, 2026, documented that 12 interventions had occurred during filling. However, records indicated approximately 200 interventions were conducted. Notably, critical interventions, including but not limited to removing vials from the filling zone and removing fallen vials from (b)(4), were not documented. (21 CFR 211.188)
  • Performance of adequate disinfectant efficacy studies. You failed to adequately evaluate your environmental isolates for inclusion in your disinfectant efficacy studies. Studies failed to adequately represent the full spectrum of microbes in your facility. (21 CFR 211.42(c)(10)(v))
  • Reproducible manufacturing processes in the production of sterile (b)(4) drug products. You did not perform a process validation study after implementing a new production step nor provide stability data within your response. (21 CFR 211.100(a)).

In your response, you state you will ensure the QU has a role in verifying intervention documentation in batch records and establish a procedure to periodically evaluate disinfectant efficacy. Your response is inadequate because you fail to provide sufficient details on how interventions in your aseptic process simulations will be captured, simulated, and verified. You also do not describe the QU's oversight of the disinfection practices or identify the environmental isolates to be challenged in the disinfection efficacy studies.

Complete and accurate batch production and control records are necessary to ensure that manufacturing processes are consistently followed and are reproducible. Additionally, incomplete manufacturing records fundamentally compromise your ability to reliably conduct batch record review, to adequately investigate deviations and batch failures, and to ensure a continued state of control.

Your firm’s quality systems are inadequate. You may refer to FDA’s guidance document Quality Systems Approach to Pharmaceutical CGMP Regulations for help implementing quality systems and risk management approaches to meet the requirements of CGMP regulations 21 CFR, parts 210 and 211 at https://www.fda.gov/media/71023/download.

In response to this letter, provide:

  • A comprehensive assessment and remediation plan to ensure your QU is given the authority and resources to effectively function. The assessment should also include, but not be limited to:
    o A determination of whether procedures used by your firm are robust and appropriate
    o Provisions for QU oversight throughout your operations to evaluate adherence to appropriate practices
    o A complete and final review of each batch and its related information before the QU disposition decision
    o Oversight and approval of investigations and discharging of all other QU duties to ensure identity, strength, quality, and purity of all products
  • A CAPA plan, based on the retrospective assessment of your disinfection program, that includes appropriate remediations to your disinfection processes and practices, and timelines for completion. Include the following as part of the assessment and CAPA plan:
    o a detailed summary of vulnerabilities in your process for lifecycle management of equipment disinfection
    o a list of improvements, with an explanation how each will enhance disinfection effectiveness
    o improved ongoing verification of proper disinfection execution for all products and equipment
    o and, any other needed remediations.
  • A detailed summary of your validation program for ensuring a state of control throughout the product lifecycle, along with associated procedures. Describe your program for process performance qualification, and ongoing vigilant monitoring of both intra-batch and inter-batch variation to ensure a continuing state of control. Also, describe your equipment and facility qualification program.
  • A timeline for performing appropriate process performance qualification for each of your marketed drug products. Also provide a risk assessment and any follow up actions to be taken for the distributed drug products produced prior to performing any process validation studies.
  • A comprehensive review of your complaints received for (b)(4) injection, including a retrospective review of all complaints for the last three years from the initial date of the inspection, with an assessment that includes but is not limited to evaluating and comparing the (b)(4) complaints received before and after the (b)(4) step.
  • Appropriate improvements to your cleaning validation program, with special emphasis on incorporating conditions identified as worst-case in your drug manufacturing operation. This should include but not be limited to identification and evaluation of all worst-case:
    o drugs with higher toxicities
    o drugs with higher drug potencies
    o drugs of lower solubility in their cleaning solvents
    o drugs with characteristics that make their manufacturing equipment difficult to clean
    o swabbing locations for areas that are most difficult to clean
    o maximum hold times before cleaning
  • A description of the steps that must be taken in your change management system before introduction of new manufacturing equipment or a new product.
  • A summary of updated SOPs that ensure an appropriate program is in place for verification and validation of cleaning procedures for products, processes, and equipment.

3. Your firm failed to establish and follow appropriate written procedures that are designed to prevent microbiological contamination of drug products purporting to be sterile, and that include validation of all aseptic and sterilization processes. Your firm also failed to maintain buildings used in the manufacture, processing, packing, or holding of drug products in a good state of repair (21 CFR 211.113(b) and 21 CFR 211.58).

Airflow Visualization (AFV) Smoke Study Deficiencies

Our inspection noted deficient smoke studies. Our investigators determined you did not perform AFV smoke studies after modifying your (b)(4) Restricted Access Barrier Systems ((b)(4)RABS) unit by removing the (b)(4) and remounting the nonviable particulate probe in suite (b)(4) of the (b)(4) filling line. Your validation department determined smoke studies were not necessary after the modification, despite your engineers proposing smoke studies be conducted.

As another example, two interventions, including product spillage cleaning at the filling station and (b)(4) adjustment lacked adequate smoke to visualize unidirectional airflow. It is not clear whether airflow is adequate to protect the aseptic processing line.

In your response, you state you will re-execute AFV studies, develop a standardized AFV protocol template, and revise the change control procedure. Your response is inadequate because you do not explain how you will ensure satisfactory conduct of smoke studies in the future.

Thorough smoke studies are essential to evaluate the effects of such interventions on unidirectional airflow and suitability of design modifications. We also note that your Grade A suites (b)(4) are described as (b)(4)RABS. Although your firm characterizes these processing lines as (b)(4)RABS, their design and operation involve an excessive number of interventions and do not meet the minimum standards of a restricted access barrier system.

The Grade A area is critical because sterile products are exposed during aseptic production and therefore are vulnerable to contamination if operations are not well designed and diligently controlled. Your aseptic processes should be designed, and operations executed, to prevent contamination hazards to your sterile product. Flaws in the design of cleanrooms and aseptic processing lines, or improper execution of operations, can promote influx of contamination into the critical processing area in which sterile drugs are exposed.

Inadequate Environmental Monitoring

We observed inadequate EM technique and insufficient EM locations. Our investigators observed the surface swabbing of the (b)(4) did not include the (b)(4). Additionally, the analyst did not swab the maximum accessible area of the (b)(4) of each (b)(4).

In your response, you state the procedures will be updated and a retrospective EM review will be performed. You also performed a historical review of your EM data since 2024 which you indicate has no adverse trends. Your response is inadequate because the quality of the data was compromised by insufficient technique and locations.

Environmental monitoring is only as meaningful as the quality of its sampling technique and locations. The purpose of environmental monitoring in an aseptic processing facility is to apply a risk-based approach to reliably detect routes of contamination.

Facility Maintenance Deficiencies

Your firm did not properly maintain classified areas used in the manufacture of drug products. Our inspection noted peeling paint on the walls and plastic debris on the floors within your Grade C hallway and product transfer room (b)(4) in Suite (b)(4).

In your response, you commit to implement post-cleaning visual inspection, require cleaning verification in the cleaning logs, and repair the facility. Your response is inadequate because your product impact evaluation states “…types of debris observed (e.g., paint, plastic) are non-viable particulates...” However, you do not explain the basis for the assertion that paint debris could not harbor microorganisms. In addition, your response does not adequately evaluate the cause of the paint bubbling and peeling from the walls and whether this has contributed to mold identified throughout all your classified areas.

Deteriorating surfaces such as peeling paint are potential sources of particulate and microbial contamination. It is critical that the building is maintained to prevent exposure of sterile articles to potential contamination hazards in the manufacturing operation.

In response to this letter, provide:

  • Your systematic plan to assure adherence to appropriate aseptic practices, cleanroom behavior, and written procedures, including but not limited to an independent assessment of the following with accompanying CAPA:
    o suitability of actual practices based on extensive retrospective review and prospective observation of aseptic processing operations
    o deficiencies in production management oversight, and identification of specific improvements to ensure effective and routine supervisory oversight for all batches
    o frequency and depth of quality unit oversight (e.g., audit, ad hoc, daily interactions) of aseptic processing and its support operations
    o adequacy of written procedures
    o evaluate how poor aseptic technique and cleanroom behavior may have affected the quality and sterility of your drugs
  • A thorough, independent evaluation of airflow unidirectionality in your aseptic process. Ensure smoke studies are conducted under dynamic conditions, with thorough and complete evaluations of aseptic processing line airflow unidirectionality, including the impact of dynamic interactions and aseptic interventions. These thorough smoke studies should be performed after you remediate your aseptic operation and be conducted using proper practices (e.g., neutrally buoyant media) to appropriately visualize airflow.
  • Your CAPA plan to implement routine, vigilant operations management oversight of facilities and equipment. This plan should incorporate oversight from a qualified independent consultant and ensure, among other things, prompt detection of equipment/facilities performance issues, effective execution of repairs, adherence to appropriate preventive maintenance schedules, timely technological upgrades to the equipment/facility infrastructure, and improved systems for ongoing management review.

Additional Guidance on Aseptic Processing

See FDA’s guidance document Sterile Drug Products Produced by Aseptic Processing—Current Good Manufacturing Practice to help you meet the CGMP requirements when manufacturing sterile drugs using aseptic processing at https://www.fda.gov/media/71026/download.

Quality Systems

Significant findings in this letter demonstrate that your firm does not operate an effective quality system in accord with CGMP. In addition to the lack of effective management oversight of your laboratory and production operations, we found your quality unit is not enabled to exercise proper authority and/or has insufficiently implemented its responsibilities. Executive management should immediately and comprehensively assess your company’s global manufacturing operations to ensure that your systems, processes, and products conform to FDA requirements.

CGMP Consultant Recommended

Based upon the nature of the violations we identified at your firm, you should engage a consultant qualified as set forth in 21 CFR 211.34 to evaluate your operations and to assist your firm in meeting CGMP requirements if your firm intends to resume manufacturing drugs for the U.S. market. The qualified consultant should also perform a comprehensive six-system audit of your entire operation for CGMP compliance and evaluate the completion and efficacy of your CAPA before you pursue resolution of your firm’s compliance status with FDA.

Your use of a consultant does not relieve your firm’s obligation to comply with CGMP. Your firm’s executive management remains responsible for resolving all deficiencies and systemic flaws to ensure ongoing CGMP compliance.

Request for a Meeting with FDA

After receiving this letter, we recommend that you reach out to arrange for a teleconference to discuss your corrective and preventive actions in detail. Direct your request to Kathryn Hall at CDER-OC-OMQ-Communications@fda.hhs.gov.

Conclusion

You are responsible for investigating and determining the root causes of any violations and implementing corrective and preventative measures to ensure future and sustained compliance so that these violations and any others do not occur.

Unresolved violations may prevent other Federal agencies from awarding contracts. Failure to address violations may also cause FDA to withhold issuance of Export Certificates. FDA may withhold approval of new applications or supplements listing your firm as a drug manufacturer until any violations are completely addressed and we confirm your compliance with CGMP. We may re-inspect to verify that you have completed corrective actions to address any violations.

If you are considering an action that is likely to lead to a disruption in the supply of drugs produced at your facility, FDA requests that you contact CDER’s Drug Shortages Staff immediately, at drugshortages@fda.hhs.gov, so that FDA can work with you on the most effective way to bring your operations into compliance with the law. Contacting the Drug Shortages Staff also allows you to meet any obligations you may have to report discontinuances or interruptions in your drug manufacture under 21 U.S.C. 356C(b). This also allows FDA to consider, as soon as possible, what actions, if any, may be needed to avoid shortages and protect the health of patients who depend on your products.

Send your written response to CDER-OC-OMQ-Communications@fda.hhs.gov within fifteen (15) business days of receipt of this letter1. Identify your written response with FEI 3006503102 and ATTN: Compliance Officer Barbara Wilimczyk-Macri in the letter or/in the subject line of the email.

If you have information that you believe demonstrates that your products are not in violation of the FD&C Act and FDA regulations, include that information for our consideration.

FDA posts warning letters on www.FDA.gov.

Sincerely,
/S/

Francis Godwin
Director
Office of Manufacturing Quality
Office of Compliance
Center for Drug Evaluation and Research
U.S. Food and Drug Administration

cc: Mr. Devan Patel, Site Manager
(b)(4)

___________________________

1 Under program enhancements for the Generic Drug User Fee Amendments (GDUFA) reauthorization for fiscal years (FYs) 2023-2027, also known as the GDUFA III Commitment Letter, your facility may be eligible for a Post-Warning Letter Meeting to obtain preliminary feedback from FDA on the adequacy and completeness of your corrective action plans.

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