Author: Brandon Miller

Audit & Internal Control

Posted on by Brandon Miller

While audits are not being conducted in the same way they were before the global pandemic, they continue to take place. New procedures adopted to deal with the coronavirus outbreak may have the unintended consequence of creating compliance gaps. An audit will identify these gaps so that you can address the issue. Understanding how the audit process has changed and what you may need to do differently can help your company navigate more smoothly.

 

Internal Control: What Processes Will Change?

 

Advance planning and proactive execution of your plan will put your company on track to conduct and complete internal, supplier and due diligence audits. Many of the processes you’re used to will change. Here’s how to prepare.

 

Auditboard: Did you Complete Advance Work?

 

You can complete some tasks off-site and in advance, such as reviewing standard operating procedures and the auditboard. You can also conduct teleconferences in advance to discuss any questions that will come up, or email ahead of time to find answers.

 

Certified Internal Auditor: Did you Hire an Expert?

 

Apply social distancing to the audit process by using video to substitute for certified internal auditor in-person visits when you can. Live streaming allows the certified internal auditor to view a facility instead of going there and possibly introducing new germs into the environment. Whenever possible, avoid walking around your employees during this process.

 

Acknowledge that the situation is not ideal. Giving auditors firsthand experience in your plant is preferable, but for the time being, it’s not always practical. Discuss what will happen to the tapes after the audit is over too so that your management team stays on the same page regarding disposal or preservation.

 

Audit Office: Are you Prepared for Virtual Interviews?

 

Interviews play a critical role in the audit process, and they will continue to serve auditors’ interests. Migrate audit office interviews to a virtual platform, and use teleconferencing apps to schedule and conduct them.

 

Audit Report: Increase the Transparency

 

The world has changed in a very short time due to the pandemic. This has led companies like yours to adopt new policies to curb the potential spread of COVID-19 or other infectious conditions. An audit offers the perfect opportunity to reexamine the audit report and increase the transparency of results. More departments and individuals should receive leeway to report deviations they see in the production process. Clarify your expectations for reporting in all aspects of production, including:

 

  • Manufacturing operations
  • Quality control
  • Compliance assurance
  • Supplier quality

 

Internal Control: Are you Building Trust?

 

Building trust with employees within a new internal control structure will put you on the path toward solving any audit issues uncovered. The goal of giving the public a reliable supply of needed products will become an achievable aim as a result. Continuing the audit process and running it smoothly is critical to public health. Companies must continue to uphold the supply chain for essential resources so that people receive the provisions they need.

 

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].

Biocompatibility Testing

Posted on by Brandon Miller

 

In this soundbite from RCA Radio, Dr. Helin Raagel and Dr. Matthew Jorgensen from Nelson Labs explain biocompatibility testing. This includes the risk-based biocompatibility evaluation that medical devices go through before they receive regulatory approval.

 

This biocompatibility risk-based approach evaluates the risk of the device through consideration of the device’s cytotoxicity, irritation, and sensitization. 

  • Cytotoxicity – Will the device kill or harm the cells it comes in contact with?
  • Irritation – Will the device make contact with the patient and cause skin irritation? (Redness and/or Swelling)
  • Sensitization – Will the device cause an allergic reaction?

 

Listen to the full episode “Intro to Pre-Clinical Testing and Biocompatibility” now!

 

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].

US FDA Consultants

Posted on by Brandon Miller

Comprehensive Regulatory & Quality Compliance Solutions

At Regulatory Compliance Associates® (RCA), we specialize in providing tailored quality and regulatory solutions for companies of all sizes — from early-stage innovators to established global manufacturers. Our consultants are more than advisors; they’re problem-solvers who deliver practical, actionable strategies to meet your business goals while ensuring compliance every step of the way.

 

Why Work with Former FDA Consultants?

Our team is a strategic blend of former FDA Inspectors and Reviewers, seasoned industry veterans, and experienced technical specialists. With their insider knowledge, RCA helps you anticipate agency expectations, address compliance challenges before they escalate, and develop robust systems that hold up to real-world regulatory scrutiny.

 

Working with ex-FDA consultants means gaining a deep understanding of how the agency operates — from inspection processes to submission reviews — so you can make informed, confident decisions that reduce risk and streamline compliance.

 

GMP Compliance Support Tailored to Your Needs

Whether you’re establishing a new facility or evaluating an existing quality system, RCA provides expert Good Manufacturing Practice (GMP) support. Our consultants help assess current practices, implement corrective actions, and ensure your manufacturing operations are fully aligned with FDA and global regulatory requirements.

 

Medical Device Data Integrity and cGMP Services

Pharmaceutical cGMP Consulting

 

Be Inspection Ready — Before the FDA Arrives

FDA inspections are often high-stakes events. Being prepared is critical. RCA’s experts help ensure your team, documentation, and systems are inspection-ready. Our former FDA inspectors bring a unique advantage — they know what investigators look for and how to position your organization for a successful outcome.

 

From mock inspections and gap assessments to remediation planning and ongoing support, we help you avoid surprises and stay ahead of compliance risks.

 

Medical Device Compliance Training & Inspection Readiness

Pharmaceutical Compliance Training & Inspection Readiness

 

Full Lifecycle Support — From Product Development to Post-Market

From new product development, regulatory submissions, and risk management to post-market surveillance, remediation, and agency response, RCA can assemble the right team to deliver results — on time and within budget. Whether you’re launching a new product or responding to a warning letter, we have the expertise to support you at every phase.

 

Medical Device Regulatory Consulting

Pharmaceutical Regulatory Consulting

 

Partner with RCA for Proven Compliance Results

Ensure you’re inspection-ready, GMP-compliant, and strategically aligned with FDA expectations. Contact Regulatory Compliance Associates® today to put our team of former regulators and industry experts to work for your business.

 

 

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].

Data Integrity

Posted on by Brandon Miller

Data integrity is the reliability, consistency, and accuracy of data at rest and in transit. Quality data adheres to several standards, beginning with integrity, confidentiality and availability.

 

Data integrity is a process to ensure consistent and accurate data over its life cycle. Requirements specify that data records need to be attributable, legible, contemporaneous, original, and accurate (ALCOA). In addition to the ALCOA, there is ALCOA+ which also requires data to be complete, consistent, enduring, and available.

 

Good Practices for Data Management and Integrity

 

Compromised data can lead to poor business decisions. Any decisions based on inaccurate data are suspect during inspections. To ensure the integrity of your company’s data:

 

  • Implement access controls. Locking and securing sensitive records and restricting unauthorized users from accessing data can reduce loss and corruption. 
  • Make backups. Once lost, raw data is irreplaceable. Backups must include original, raw data creates a duplicate in an alternate location. 
  • Validate the data. Automate digital validation by organizing and filtering data using scripts. Validation checks the quality of the data to be secure, meaningful and correct. 
  • Have a quality system in place. Having a quality system in place and ensuring procedures can be completed on- or off-site will help solve any issues. 
  • Think through changes. If you’re going to change processes to adapt to a more virtual environment where employees work from home, think about all necessary steps or procedures.
  • Organize files and systems. Systemically arranging your files helps you easily pass off or explain data to others such as auditors and inspectors.
  • Validate input. You can use input validation to block cyberattacks, such as structured query language (SQL) injection prevention. Checking input at the time it is recorded is crucial.

 

Does your team need help with Data Integrity? Talk to our Experts→

 

New Guidance From the Food and Drug Administration (FDA)

 

The best way to maintain a supply of safe and effective products and prevent a drug shortage is to comply with data integrity concepts to prevent batch rejection/recall and monitor sites and stay up to date on FDA guidelines. You can do this by: 

 

  • Reviewing the staff manual guide. This guide covers FDA internal procedures for requesting records in advance of or in place of a drug inspection. 
  • Ensuring your company has a quality culture. Complications during the COVID-19 pandemic have only made processes more complicated, so establishing procedures around quality culture can help deter issues. 
  • Building quality into your operations: make sure you have a strong training program and it’s importance to the organization and the product.
  • Having a solid risk management plan. A solid risk management strategy can save you money, time, and unnecessary manufacturing disruptions and establish a process to deal with potential risks that may arise.

 

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].

Pharmaceutical Manufacturing

Posted on by Brandon Miller

Whether building a new facility (greenfield) or upgrading a pharmaceutical manufacturing site (brownfield), it is important to understand the regulations governing facilities and inspection readiness. The Code of Federal Regulations Part 211 governs the United States, Eudralex Volume 4 governs the European Union, and the Ministry of Health, Labour, and Welfare govern Japan.

 

GMP Pharmaceutical

 

Knowing the pharmaceutical manufacturing requirements for these regions is important information needed to assist your decision on whether it is more feasible and economical to build a new facility or upgrade an existing facility. Whatever decision you decide to make, Regulatory Compliance Associates Inc. can help you achieve a successful outcome.

 

Need help upgrading or building a new facility? Talk to our Experts →

 

The pharmaceutical industry has been trying to become more efficient from both manufacturing and regulatory perspectives. The challenge is to improve processes, quality systems, and manufacturing capabilities while operating efficiently and in a manner. Core to the belief of quality culture is developing pharmaceutical active ingredients that ensure safe, effective, and cost-efficient medicines to patients.

 

Pharma Manufacturing

 

Many pharma manufacturing and quality system updates can be easily and readily implemented with little or no impact on regulatory filings. When a change impacts regulatory filings, it has the potential to disrupt the supply chain if it is not handled appropriately and as efficiently as possible. FDA seems to recognize these situations and has been working to help lessen the regulatory filing burden to companies while not affecting the quality of the products.

 

Regulatory Filing

pharmaceutical manufacturing

 

If you are a contract manufacturer the first step in the process of upgrading your facility is to get the agreement, or at least, an acknowledgment from your clients that they are aware that you intend to upgrade the facility and that it may affect their regulatory filing.

 

Quality Agreement

 

Both your pharmaceutical factory and your client(s) may have responsibilities outlined in the quality agreement regarding maintaining and upgrading the facility and the decision to upgrade an existing Pharma facility should be made with the knowledge and input of your client(s).

 

Pharmaceutical Production

 

Using a comparability protocol is a great way to communicate your intended upgrades to your client. Employing the use of a comparability protocol you are, in essence, making sure your client understands the pharmaceutical production change you will be implementing and the data you will be collecting and reviewing to assess that the upgrade was successful and did not affect product quality. The comparability protocol is a nice compromise when you are dealing with multiple clients who have different regulatory filing strategies.

 

FDA Regulation

 

The best way to upgrade a facility in a timely manner is to make sure you have a robust quality agreement in place that gives you the responsibility for maintaining your facility, become familiar with FDA regulations and use them to justify your recommendation, and finally, use a comparability protocol for medicine production like-to-like equivalency. These steps should help you implement a facility upgrade promptly while reducing your downtime to improve.

 

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 Harmonization

Posted on by Brandon Miller

The FDA harmonization team has recently announced it is no longer going to be a member of the Global Harmonization Working Party (GHWP). This comes as an eye-opener for many life science industry employees since FDA harmonization has been a visible priority since the agency joined GHWP in 2021.

 

The FDA stated that it will continue to work with global regulatory experts on international harmonization, with the primary partner being the International Medical Device Regulators Forum (IMDRF).

 

Food and Drug Administration

 

Some industry executives have asked the question why take this type of action now? One primary reason many life science industry experts believe the time is right is based on the Center for Devices and Radiological Health (CDRH) strategic plan launched in late 2023. Inside the details of the document, the Food and Drug authority laid out a four-year example timeline for working towards greater international harmonization.

 

These are a few of the initiatives listed to be achieved by FY 2027:

 

FDA Timeline

 

Each fiscal year, CDRH will now evaluate different types of opportunities to increase engagement across international harmonization programs. Further, it is anticipated that CDRH will receive additional funding and resources to help accelerate this engagement. These additional resources will be designed to allow the FDA to expand international harmonization and convergence programs already in progress. 

 

Best Practices

 

The second phase of the strategic plan is designed to increase discussions about the implementation of harmonized policies. Further, this new mechanism may require FDA to develop additional confidentiality agreements to increase the efficiency of research analysis & discussion under confidentiality commitments. CDRH will review the current list of approved regulatory partners and confidentiality protocols in place to align regulatory strategies across international agencies. 

 

Medical Research

 

Per the strategic plan, FDA will identify and begin engaging with regulatory authorities by the end of 2023. The primary objective is to create a database of regulatory bodies with whom sharing medical research could be most helpful toward the global harmonization of standards. Finally, CDRH has committed to creating this information-sharing mechanism to communicate best practices in medical device evaluation by the end of 2024. 

 

Technical Documents

 

The strategic plan goes on to elaborate on how CDRH’s regulatory policy compares to widely accepted IMDRF policies. Furthermore, technical specifications of IMDRF documents that include policies and practices approved by all regulatory authorities in the IMDRF Management Committee will be assessed and evaluated by FDA.

 

One goal of this regulatory process is to increase the understanding of technical description and technical report writing of international regulatory agencies. This will directly help CDRH with their internal assessment of international harmonization efforts, and how FDA’s process may differ in comparison to regulators around the world.

 

FDA Analysis

 

Based on the technical specification data listed in the strategic plan, these are the proposed timelines for CDRH to make advances toward global harmonization:

 

  • CDRH will publish an assessment of at least nine IMDRF technical documents by the end of 2025.
  • CDRH will publish an assessment of at least 18 IMDRF technical documents by the end of FY 2026.
  • CDRH will publish an assessment of all remaining IMDRF technical documents by the end of FY 2027

 

Regulatory Authority

 

The strategic plan continues to elaborate on the life science community and the impact non-FDA employees can have on future regulatory approval. These specific stakeholders may have a unique perspective based on their current occupation or the types of therapy a patient receives. Finally, the following audiences are specifically mentioned for providing first-hand experiences that FDA can leverage based on another regulatory authority’s approach to medical therapy. 

 

  • Healthcare patients
  • Life science manufacturers
  • Conformity assessment bodies
  • Standards development organizations

 

Patient Engagement

 

Finally, an annual communication plan is proposed to begin in 2024 that includes developing a forum to assess and report on harmonization program efforts in progress. This forum will be designed to connect with each of the audiences mentioned above to help FDA identify opportunities for learning. Furthermore, this forum would be dependent on the level of interest and considerations of other stakeholders, including the life sciences industry specifically. 

 

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].