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[November 2025] Alternative Facility Assessment Tools, Computer Software Assurance + Warning Letter Breakdown

FDA's guidance on alternative assessment tools for drug facilities, the new risk-based software validation framework, and a warning letter that reveals what happens when teams stop asking why.

Originally published November 2025.

Welcome to Insider issue #43.

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This month brings guidance that reshapes how drug facilities prepare for pre-approval assessments. Alternative tools—remote regulatory assessments, foreign partner inspections, remote subject matter experts—aren’t just emergency options anymore. They’re becoming business as usual.

For medical device and combination product companies, the September 2025 Computer Software Assurance guidance finally provides clarity on risk-based software validation.

The one-size-fits-all approach is officially dead. And our warning letter analysis covers Creative Essences, an OTC manufacturer whose citation illustrates what happens when curiosity fades and compliance becomes a reactive posture.

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