Author: Brandon Miller

Remediation Consulting Services

Posted on by Brandon Miller

About RCA’s Remediation Services

Regulatory Compliance Associates has significant quality and regulatory compliance consulting experience and a proven regulatory framework for managing FDA  483’s, Warning Letters, and Consent Decrees. Our pharmaceutical consultants know how to partner with executive, legal, and communication teams at all levels of a life science company. RCA’s remediation consulting experts can assist your management with a remediation strategy that is accepted by the regulatory agency and realistic to execute internally.  Finally, RCA can partner with your leadership team to develop a long-term risk management plan to help your team stay in compliance going forward.

 

Regulatory Compliance Associates can assist with answering FDA 483 observations, FDA Warning Letters and developing strategies to help your organization maintain regulatory compliance through continuous improvement.

 

RCA can help with remediation activities in both manufacturing operations & quality management systems.  RCA’s regulatory consultants have completed many projects assisting our clients to evaluate what is needed, collaboratively determine action plans & help execute.  We have also performed post-implementation audits to ensure regulatory compliance.

 

Follow the links below to learn more about our remediation services in Pharmaceuticals and Medical Devices. 

 

Pharmaceuticals

Medical Device

 

 

To begin the Regulatory Compliance Associates scoping process today, please enter your information in the blue form below and click the submit button at the bottom of the webpage. You may also email us at [email protected].

Compliance Consulting Services

Posted on by Brandon Miller

About RCA’s Compliance Assurance Services

Increasingly, life science companies are feeling the pressure of greater scrutiny by regulators and responding by developing sustainable compliance strategies. Whether it’s preparing for an audit or developing a response to an FDA finding, Regulatory Compliance Associates® team of compliance consultants can help. Our business consultant Experts are internationally known in the regulatory compliance consulting industry.

 

The regulations process surrounding life science companies can be tricky for even the most experienced compliance veteran. If you’re consistently unable to comply with regulations, any notified body can deliver devastating consequences for your business. At RCA®, we offer the management consulting resources necessary to guide you in regulatory compliance.

 

Follow the links below to learn more about our compliance assurance services in Pharmaceuticals and Medical Devices. 

 

Pharmaceuticals

Medical Device

 

 

To begin the Regulatory Compliance Associates scoping process today, please enter your information in the blue form below and click the submit button at the bottom of the webpage. You may also email us at [email protected].

FDA Guidance on Postmarket updates to AI-enabled devices

Posted on by Brandon Miller

What is a pre-determined change control plan (PCCP)?

The FDA recently released a final guidance on regulating AI-enabled medical devices that focuses on how manufacturers can modify these devices after they are authorized. The agency introduced a new regulatory framework called pre-determined change control plans (PCCPs), which allows certain post-market changes to devices using AI or machine learning. PCCPs were first mentioned in a 2019 discussion paper, and the FDA has since issued draft and final guidance on them.

 

PCCP Required Information

This final guidance outlines the required information for PCCPs, which includes;

  • Description of Modifications – The specifications for the characteristics and performance of the planned modifications to the device;
  • Modification Protocol – The associated verification and validation testing activities that will support the planned modifications and acceptance criteria to assure the device remains safe and effective across the intended use populations
  • Impact Assessment – The assessment of the benefits and risks of implementing a PCCP, as well as the plan for risk mitigation.

Need help establishing a PCCP for your medical device?

Contact Us Now!

Manufacturers can propose updates to AI models, such as re-training to improve accuracy, without needing new submissions, as long as the changes stay within the device’s intended use. However, significant modifications outside the scope of the PCCP, like altering a device’s function or user base, would require new FDA submissions.

 

How do you establish a pre-determined change control plans (PCCPs) for my medical device?

Premarket authorization for AI-enabled devices with a PCCP must be established through the PMA pathway, 510(k) pathway, or De Novo pathway as a PCCP must be reviewed and established as part of a marketing authorization.

 

Follow the link to learn more about RCA’s Medical Device Product Approval Support and Submission Services.

 

 

To begin the Regulatory Compliance Associates scoping process today, please enter your information in the blue form below and click the submit button at the bottom of the webpage. You may also email us at [email protected].

 

 

Leveraging Outsourced Staff

Posted on by Brandon Miller

 

In this soundbite from RCA Radio, Erika Porcelli, CEO of Regulatory Compliance Associates® (RCA), provides examples of how different size companies leverage the stage of business they’re in to accelerate development with outsourced staff.

 

Start ups vs Large Companies

 

Using Staff augmentation to bring in SMEs gives companies the ability to scale up and scale down quickly without taking away people from other projects.

Start-ups are typically not ready to bring on a full-time employee. In cases like these, we can bring in a subject matter expert (SME) that can help work through any regulatory, compliance, or quality problem and assist on an as-needed base.

 

Larger companies typically need help when they are performing a project such as adding a new manufacturing line into a facility. They don’t do this all of the time and only need the extra resources for this particular project. In cases like these, we will put together a team with the right skillsets that can complete the particular project. Once completed, RCA perform a hand-off with the client, and our team steps away from the project. 

Listen to the full episode “Outsourcing and Staff Augmentation” now!

All companies experience staffing support issues whether they are transient and short-lived, chronic and unplanned, or intrinsic to your business model. RCA has consultants that develop a solution to your specific needs; we can help “right-size” your team when and where you need it most.

 

Outsourcing has become an increasingly common practice in the life science industry. The quality assurance (QA) and regulatory affairs (RA) functions create extra complexity for large and small life science companies because needs may vary greatly depending on the life cycle of the organization. These companies turn to outsourcing to manage operations and tactical skills, and also help adopt best practices.

 

Successful execution comes through project monitoring, issue resolution, and risk management of the process through clear leadership. RCA’s team of experienced project management professionals organize and manage resources to ensure that projects are completed successfully, on time, and within budget.

 

RCA Outsourcing Services

 

Project Management

outsourced staffTo be successful in the field of manufacturing, you must have a proper project management plan in place. Not only do project management procedures keep your projects on time and on schedule, but they also ensure your devices’ compliance with stringent national and international regulations. RCA can help you develop an effective plan, and we can even lead these tasks so that you can run more projects at one time more efficiently.

 

Our outsourced staff capabilities for project management capabilities include:

 

  • On-site Project Leadership or Project Management Support
  • Design and Implementation of a Project Management Office
  • FDA Workshops
  • Project Assessment, Remediation, and Follow-up
  • Advanced Schedule Optimization and Management
  • Development and Implementation of Compliant Methods
    • Risk Management
    • Issues Resolution and Decision Tracking
    • Change Management
    • Performance Measurement and Tracking
  • Tool Selection for Program Portfolio and Resource Management

 

Staff Augmentation

Many companies need the assistance of a professional with specific skills and expertise when completing a project but might not have the need or resources to hire this expert as a full-time employee. Instead, you can add experienced professionals to your staff for a short- or long-term project through our medical device staffing support capabilities. RCA’s outsourcing solutions can help you manage even your most complex projects with experts trained in areas such as:

 

  • Quality Assurance
  • Regulatory Affairs
  • Validation
  • Operations
  • Product Development

 

Consulting Support

Maybe your company is struggling to complete projects on time, or perhaps you often face challenges associated with product compliance. Whatever your situation, our consultants will work with you to ensure your business’ success with consulting support services. By getting to know more about your business and goals, we’ll tailor our approach to best meet your particular needs.

 

Advantages of Outsourcing

 

When you hit a snag in your project’s development, you need to design and develop the best solution to create a timely, quality finished product. RCA’s quality assurance and regulatory affairs consultants can help you define the specific problem, generate ideas for a potential solution, and implement that solution for the utmost success in your project’s completion.

 

Our goal is to help you get your projects to completion on time and on budget — all while outsourced staff keeps superior quality at the forefront of your every task. And with a team of more than 500 pharmaceutical consultants and industry experts with an average of 25 years of experience in the life science industries, we have the extensive resources and expertise needed to meet this goal.

 

Strategic Outsourcing

 

Medical device manufacturers face the challenging task of creating top-quality products quickly with minimal personnel and growing compliance regulations to adhere to. With these increasing challenges, it’s no wonder so many local startups and Fortune 100 companies alike choose RCA for outsourced staff and strategic outsourcing services.

 

 

To begin the Regulatory Compliance Associates scoping process today, please enter your information in the blue form below and click the submit button at the bottom of the webpage. You may also email us at [email protected].

 

 

FDA ISO13485 Harmonization

Posted on by Brandon Miller

Click now to hear from Jordan Elder, RCA’s Director of Regulatory Affairs, regarding the latest info on Quality System Regulation (QSR) regulations and FDA harmonization efforts:

 

 

When developing a quality management system (QMS), it is important to understand any pitfalls that could arise as well as understand what each notified body looks for in a compliant quality system. Recently, one of the US Food and Drug Administration’s (FDA’s) top medical device regulators said harmonizing the agency’s current Quality System Regulation with the International Organization for Standardization (ISO) 13485:2016 is a “high priority”.

 

Click to learn about the latest updates to the QMSR File Rule.

 

QMS Harmonization

 

Currently, the US Food and Drug Administration (FDA) does not enforce ISO’s 13458:2016 standards set in place for Quality Management Systems, but uses its own Quality System Regulation (QSR) guidelines that do include parts of the 13458 standards. But this is set to change for the better. The FDA has recently proposed plans to align its quality system requirements with ISO 13485:2016, creating a new regulation dubbed the Quality Management System Regulation (QMRS). This shift came four years after the agency first proposed the regulatory alignment.

 

Quality Management System

 

Manufacturers who already conform to the ISO standard should not see much change and this move should help create efficiencies for them in the long run. The FDA proposed the alinement by incorporating the 2016 edition of the international standard specific for medical device quality management systems ISO13485. Through this rulemaking, the FDA is also proposing additional requirements that help connect and align ISO13485 with existing requirements in the FD&C Act and its implementing regulations. This will include making conforming edits to 21 CFR Part 4 to clarify the device CGMP requirements for combination products as well.

 

Risk Management

 

The most noticeable difference between the current quality systems regulation and ISO13485 is that the risk management requirements are integrated throughout the aspects of the quality management system in ISO13485. This differs from 21 CFR 820, in that the only risk-specific requirement in the QS regulation is listed in §820.30(g), as it relates to risk analysis as a part of design validation.

 

These revisions are intended to supplant the existing ISO13485 requirements with the specifications of an international consensus standard for medical device manufacturers. The revisions are expected to reduce device manufacturers’ burdens, specifically aspects of compliance and recordkeeping through the harmonization of domestic and international requirements.

 

ISO Standard

 

With a membership of 168 national standards bodies, ISO is an independent, non-governmental international organization that brings together experts from around the world to share knowledge and develop voluntary, consensus-based, market-relevant International Standards that support innovation and provide solutions to global challenges.

 

Although the standers set by ISO are recognized by organizations around the world, ISO compliance itself isn’t a legal requirement, the standards naturally align with different regulations across the industries. ISO compliance means using ISO standards as guidelines for aligning your policies, processes, and operating procedures to adhere to the standard.

 

ISO 13485:2016

 

ISO 13485:2016 specifies requirements for medical device quality management systems where an organization needs to demonstrate its ability to consistently meet customer and applicable regulatory requirements. This includes one or more stages of the product life cycle, including:

 

  • Design controls and development
  • Production and manufacturing
  • Storage and distribution
  • Installation
  • Servicing a medical device
  • Technical support

 

ISO13485:2016 can also be used by suppliers or external parties that provide products, including quality management system-related services to such organizations.

 

 

To begin the Regulatory Compliance Associates scoping process today, please enter your information in the blue form below and click the submit button at the bottom of the webpage. You may also email us at [email protected].

 

Artificial Intelligence and the FDA

Posted on by Brandon Miller

As Artificial intelligence (AI) continues to grow, the health care industry is beginning to explore the benefits it can bring. With the potential to advance medical product development, improve patient care, and augment the capabilities of health care practitioners. The US Food and Drug Administration’s (FDA’s) Center for Biologics Evaluation and Research (CBER), Center for Drug Evaluation and Research (CDER), Center for Devices and Radiological Health (CDRH), and Office of Combination Products (OCP) are jointly collaborating to safeguard public health while fostering responsible and ethical innovation medical devices and pharmaceuticals. 

 

AI management requires a risk-based regulatory framework built on robust principles, standards, and best practices. With the use of state-of-the-art regulatory science tools the risk-based framework can be applied across AI applications and be tailored to the relevant medical product. Do to the complex and dynamic processes involved in the development, deployment, use, and maintenance of AI technologies. They benefit from careful end-to-end management of AI applications throughout the product life cycle. The process starts from ideation and design and progresses through data acquisition; preparation; model development and evaluation; deployment; monitoring; and maintenance. This approach can help address ongoing model performance, risk management, and regulatory compliance of AI systems in real-world applications.

 

The US FDA CBER, CDER, CDRH, and OCP divisions have identified four areas of focus regarding the development and use of AI across the product life cycle to help meet the FDA GMP guidelines that are already established.

 

The Focus Areas

  1. Foster Collaboration to Safeguard Public Health – Cultivate a patient-centered regulatory approach that emphasizes collaboration and health equity.
    • Collect input from interested parties to consider critical aspects such as transparency, governance, bias, cybersecurity, and quality assurance.
    • Promote the development of educational initiatives to support regulatory bodies, health care professionals, patients, and researchers to ensure safe and responsible use of AI in medical product development.
    • Work closely with global collaborators to promote international cooperation on standards, guidelines, and best practices to encourage global consistency.
  2. Advance the Development of Regulatory Approaches That Support Innovation – FDA intends to develop policies that provide regulatory predictability and clarity for the use of AI.
    • Monitor and evaluate trends and emerging issues to detect potential knowledge gaps and opportunities in the current FDA guidelines.
    • Supporting efforts for evaluating AI algorithms for robustness and resilience against current FDA regulations.
    • Build upon existing initiatives for the evaluation and regulation of AI use in medical product development, including in manufacturing.
    • Issuing guidance regarding the use of AI in medical product development and in medical products.
  3. Promote the Development of Standards, Guidelines, Best Practices, and Tools for the Medical Product Life Cycle. – Upholding safety and effectiveness standards across AI-enabled medical products. As well as building on Good Machine Learning Practice Guiding Principles.
    • Refine and develop considerations for evaluating the safe, responsible, and ethical use of AI in the medical product life cycle.
    • Identify and promote best practices for long-term safety and real-world performance monitoring.
    • Best practices for documenting and ensuring that data used to train and test AI models are fit for use.
    • Develop a framework and strategy for quality assurance of AI-enabled tools or system.
  4. Support Research Related to the Evaluation and Monitoring of AI Performance. – To gain valuable insights into AI’s impact on medical product safety and effectiveness.
    • Identify projects that highlight different points where bias can be introduced in the AI development life cycle and how it can be addressed.
    • Support projects that consider health inequities associated with the use of AI to promote equity and ensure data representativeness, leveraging ongoing diversity, equity, and inclusion efforts.
    • Support the ongoing monitoring of AI tools in medical product development within demonstration projects to ensure adherence to standards and maintain performance and reliability.
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CBER, CDER, CDRH and OCP plan to tailor their regulatory approaches for the use of AI in medical products to protect patients and health care workers and ensure the cybersecurity of medical products in a manner that promotes innovation.

 

To begin the Regulatory Compliance Associates scoping process today, please enter your information in the blue form below and click the submit button at the bottom of the webpage. You may also email us at [email protected].