FDA Investigators Have Already Formed an Opinion About Your Facility Before They Ask for a Single Document.

Most pharmaceutical companies prepare for FDA inspections by preparing their documents. That is the wrong starting point – and experienced Investigators know it the moment they arrive.

Here is something the pharmaceutical industry does not talk about enough: an FDA inspection does not begin when the Investigator sits down and requests your batch records.

It begins before that. Sometimes well before that.

By the time your quality director says good morning, the Investigator has already observed things about your facility that are shaping how the rest of the inspection will unfold. None of those things are in your document control system. None of them will be improved by spending the week before an audit pulling records.

I spent 14 years as an FDA Investigator and issued more Form 483s than I care to count. For the 13 years afterwards, I was directly responsible for FDA 483s received at multiple companies. What I know – from both sides of that table – is that the companies that struggle in inspections are almost never undone by their documents. They are undone by things they never thought to prepare for.

The full list of what Investigators notice – and what it signals about your quality culture before a single document changes hands – is published on The Investigator’s Lens. It is the kind of insider knowledge that does not appear in any FDA guidance document, because it was never written down. It was learned.

Is Your Facility Ready for an Unannounced FDA Inspection – Today? Inspection readiness is not a document exercise. FD-AID LLC conducts mock FDA inspections and pre-inspection assessments grounded in 14 years of real investigator experience. Most gaps are found and fixed before FDA finds them – if you look in the right places. Contact devaughn@fdaid.org to schedule a pre-inspection readiness assessment.

Read the full article – seven specific things FDA Investigators notice before they touch a single document, and what each one tells them about your facility:

The Investigator’s Lens: https://devaughnedwards.substack.com/p/221

DeVaughn Edwards is a former FDA Investigator with 14 years of federal service and 13 years as a pharmaceutical quality executive. He is the founder and Principal Consultant of FD-AID LLC (fdaid.org).

devaughn@fdaid.org | devaughn@gmail.com

Copyright FDAID LLC 2026

Leave a comment