Tom - I've recently printed and shown FDA document ORA-LAB.5.4.5 including the attachments to our famous QA department (of which I'm not a member), and have gotten some concessions for a current validation project (the first one they've ever stuck their noses into, and insisted we validate the existing USP procedure because we don't make the active-just the finished dosage form). But my QA seems reluctant most times to accept the written FDA word, especially if that word doesn't agree with their pointyhaired boss'. Interestingly, though: my QA seems to pick and choose certain aspects of cGMP to follow, and ignores others......my new boss just says to do what they want, they're paying......I need to write a book someday....just submitted were 4 four-month freeze-thaw samples (all same lot) - all had leaked, and there were no control/ambient samples, so how will anyone know if any active loss is from freeze-thaw or from aging (they looked around yesterday, couldn't find any samples from that lot anywhere to use as a control)? Too bad they didn't spend time on a two-minute phone call to me four months ago or they could have had an ambient control sample...the QA arrogance here is beyond belief, like they never feel they need to ask for anyone's opinion or help.