No program is in place AND a product has been The responsibility could be shared corporate, See finding severity definition Not applicable subject to regulatory action. and the facility then complete the relevant section 1 and/or 2 a. If the implementation is done at a corporate level, then verify 1), if not complete then “Major” b. if the implementation at the facility level, then verify 2) c. If the implementation at both levels, then verify 1) and 2), then the highest of both ratings apply Remote Verification Acceptable: Yes