What does an FDA or state board inspector look for in a USP <797> inspection?
Inspectors verify that the facility can demonstrate, with records, that it meets USP <797>: viable air and surface sampling on the cadence for its category, temperature, humidity, and pressure documented at least daily on compounding days, cleaning and sporicidal logs, personnel garbing, gloved fingertip, and media-fill competencies current, engineering controls certified within the interval, calibrated equipment, current SOPs, and a working deviation and CAPA process. The most common observations are missing or incomplete records rather than missing activities.
How often must personnel be requalified under USP <797> (2023)?
Hand hygiene and garbing observation, gloved fingertip and thumb sampling, and media-fill testing are performed initially and then at least every 6 months for Category 1 and Category 2 compounding, and at least every 3 months for Category 3. Personnel whose role is oversight only requalify at least every 12 months. This is a change many facilities missed in the 2023 revision, which shortened the Category 1 and 2 interval from annual.
How often must viable air and surface sampling be performed?
Category 1 and Category 2 facilities perform viable air sampling at least every 6 months and viable surface sampling at least monthly. Category 3 facilities perform viable air sampling at least monthly and viable surface sampling at least weekly, and also sample PEC surfaces at the end of every batch before cleaning. Both categories sample again after any event that could affect air quality. Action levels are ISO 5 >1 · ISO 7 >10 · ISO 8 >100 CFU/m³ for air and ISO 5 >3 · ISO 7 >5 · ISO 8 >50 CFU/plate for surfaces.
How often must a PEC or cleanroom be certified?
Primary and secondary engineering controls are certified initially and at least every 6 months, and again whenever a change is made that could affect air quality, such as relocating a hood, replacing a HEPA filter, or modifying the HVAC. Non-viable particle counts are performed at least every 6 months as part of that certification.
How is this self-assessment scored?
Each of the 12 questions carries equal weight. A "Yes" earns full credit, "Partial" earns half, and "No" earns none. The total is scaled to 0 to 100 and mapped to a letter grade using the same thresholds CompliRx uses in the product: A at 90 or above, B at 80, C at 70, D at 60, and F below 60. It is a screening tool, not a regulatory determination.