Recent News Carousel Archives - Regulatory Compliance Associates

FDA Updates Supply Chain Security Guidance

Posted on by Joby Semmler

The U.S. Food and Drug Administration (FDA) recently published multiple new guidance documents to help accelerate supply chain security and new product tracing requirements in the pharmaceutical industry. While most countries have implemented firmer regulations over the last decade, this new guidance is timely as domestic industry executives are reexamining security protocols in the wake of prominent cyberattacks.

The Drug Supply Chain Security Act (DSCSA) was originally designed as a framework for manufacturers, wholesalers, and dispensers to comply with laws that accomplish a safer, secure, and entrusted drug supply chain. A primary objective of DSCSA is to develop models and strategies to reduce the distribution of counterfeit, stolen, contaminated, or otherwise harmful drugs. These new FDA guidances include protocols for developing data architecture systems and how industry executives can optimize interoperability during the design and build phase.

Need help with your Supply Chain? Talk to our Experts →

Drug Packaging

As part of the DSCSA, pharmaceutical manufacturers and repackagers are required to add a product identifier on drug packaging. The product identifier includes the product national drug code (NDC), serial number, lot number and expiration date for each package. It must be in both human- and machine-readable form (e.g. two-dimensional data matrix barcode). This is designed to help downstream partners (e.g. repackagers, wholesale distributors, and dispensers) associate the information encoded in the barcode with readable text used by Logistics teams. The updated human-readable format includes:

NDC: [insert product’s NDC]
SERIAL: [insert product’s serial number]
LOT: [insert product’s lot number]
EXP: [insert product’s expiration date]

Expiration Date

For select products where an expiration date includes only year and month due to space limitations, the drug’s actual expiration date is recommended to be the last day of the calendar month included in the human-readable expiration date on the drug package label.

Product Identifier

Each finished or unfinished drug is subject to regulatory listing requirements. The product identifier is a standardized graphic composed of an alphanumeric serial number (up to 20 characters) that helps identify the product and package configuration. Product identifiers must be affixed or imprinted on the smallest individual saleable unit of a product, which also includes all product sold to a dispenser.

National Drug Code

Each product identifier has a unique NDC. The NDC is a FDA-assigned 3-segment format (10 or 11-digit number) to identify its labeler, product, and package size and type. In select instances, the linear barcode requirements from 21 CFR 181 201.25 will stay in effect for additional FDA-regulated products and packaging. This digital fingerprint of data will be used to accelerate the regulatory learning process.

Suspect/Illegitimate Products

The revised FDA guidance documents also now provide increased clarity regarding the FDA’s current interpretation of “suspect” and “illegitimate” products. “Suspect” and “illegitimate” products are defined as:

“counterfeit”
“diverted”
“stolen”
“fraudulent transaction”
“unfit for distribution”

Artificial Intelligence

As artificial intelligence and machine learning modernize the supply chain over time, it’s not unreasonable to imagine the new bar codes could detect medication errors in real time for healthcare professionals and pharmacists. This could provide alerts to validate industry professionals are:

Giving the right drug,
Via the right dose,
Via the right route of administration,
To the right patient,
At the right time.

Regulatory Agency Response

Specific scenarios designed for risk management of a suspect product entering the pharmaceutical supply chain are also referenced. The guidance provides examples of when manufacturers should notify the FDA of a high risk product that may be or is illegitimate. Industry executives are also encouraged to collaborate with the Agency to help refine existing processes for terminating notifications.

This new clarity provides pharmaceutical executives a further glimpse into the FDA’s interpretation of system attributes necessary for secure product tracing inside the marketplace. The language is noticeably more detailed at the package level and provides supporting commentary for avoiding supply chain disruptions and enhanced drug distribution security.

About RCA’s Pharmaceutical Consulting Services

Regulatory Compliance Associates (RCA) has helped thousands of pharmaceutical companies meet regulatory, compliance, quality assurance, and remediation challenges. With more than 20 years of experience with FDA, Health Canada, EU and global regulatory agencies worldwide, Regulatory Compliance Associates^® offers leading pharmaceutical consultants. We’re one of the few pharma consulting companies that can help you navigate the challenges associated with industry regulations.

Our pharmaceutical consulting firm includes over 500 seasoned FDA, Health Canada & EU compliance consultants and regulatory affairs experts who understand industry complexities. It’s a pharma consultancy founded by regulatory compliance executives from the pharmaceutical industry. Every pharmaceutical industry consultant on the Regulatory Compliance Associates team knows the unique inner workings of the regulatory process.

Client Solutions

Whether you’re in the product planning, development or pharmaceutical lifecycle management stage or need a remediation strategy for a compliance crisis, Regulatory Compliance Associates will guide you through every pharmaceutical consulting step of the regulatory process and create a customized approach depending on your product and your pharma company’s individual needs. Our regulatory compliance clients include:

Companies new to FDA, Health Canada or EU regulations and regulatory compliance
Start-up organizations with novel submissions to 510(k) submissions from multi-national corporations
Investment firms seeking private equity due diligence for pre-acquisition and post-deal research
Law firms seeking pharmaceutical consulting firm expertise in the remediation of warning letters, consent decrees, 483’s or import bans

Regulatory Affairs

Regulatory affairs is Regulatory Compliance Associates backbone. We exceed other pharma consulting companies with industry experts experienced in complexities of the pharmaceutical and biopharmaceutical industries. Our pharma consulting expertise spans all facets and levels of Regulatory Affairs, from Regulatory Support for New Products to Life Cycle Management, to other services like Outsourced Regulatory Affairs, Submissions, Training, and more.

As your partner, we can negotiate the potential assessment minefield of regulatory compliance services with insight, hindsight, and the clear advantage of our breadth and depth of knowledge and regulatory compliance consulting. We offer the following pharma consulting regulatory affairs services for pharmaceutical companies.

New Product Support
Product Lifecycle
Other Regulatory Services
Combination Products

Compliance Assurance

The regulations process surrounding pharmaceutical companies can be tricky for even the most experienced industry veteran to understand. Just one misstep could mean significant and lasting consequences for your business. At Regulatory Compliance Associates, we offer the pharma consulting experience and pharma consultants necessary to guide you through the quality compliance process.

Assessments
Audits
Regulatory Agency Response
Preparation and Training
Inspection Readiness
Data Integrity

Quality Assurance

Regulatory Compliance Associates Quality consulting includes assessments, strategy, implementations, staff augmentations, and identification of quality metrics to ensure continuous improvement. Our pharma consultants understand the strategic thinking needed to align your business needs and goals. Regulatory Compliance Associates quality assurance services include quality experts with experience spanning major corporations and start-ups looking for FDA guidance support. Our pharmaceutical consulting firm knows firsthand how to achieve, maintain, and improve quality, and we excel in transferring pharma consulting knowledge to your organization.

21 CFR Part 11
Data Integrity
Manufacturing Support
Facility Support
Quality Metrics

Remediation Services

Regulatory Compliance Associates has a proven remediation services approach to managing FDA Warning Letters, Consent Decrees, Remediation and other serious regulatory situations. Our pharma consultants know how to partner with executive, legal, and communication teams. Each RCA pharma consulting Expert will develop a response that will be accepted by the regulatory agency and be realistic to execute.

Regulatory Compliance Associates pharma regulatory consultants will develop a comprehensive proof book of documented evidence demonstrating the corrective action taken to remediate non-compliant issues. In addition, each Regulatory Compliance Associates pharma consulting Expert understands compliance enforcement and FDA guidance. We’ll prepare a comprehensive pharma consulting strategy to assist in your remediation efforts, drive continuous improvement, and maintain regulatory compliance with the regulations.

Regulatory Action
Regulatory Compliance
Regulatory Enforcement
Warning Letter
483 Observation
Oversight Services
Risk Management Plan

About Regulatory Compliance Associates

Regulatory Compliance Associates^® (RCA) provides FDA guidance consulting to the following industries for resolution of life science challenges:

We understand the complexities of running a life science business and possess areas of expertise that include every facet of R&D, operations, regulatory affairs, quality, and manufacturing. We are used to working on the front lines and thriving in the scrutiny of FDA, Health Canada, MHRA and globally-regulated companies.

As your partners, we can negotiate the potential minefield of regulatory compliance and regulatory due diligence with insight, hindsight, and the clear advantage of our unique expertise and experience.

Founded in 2000
Headquartered in Wisconsin (USA)
Expertise backed by over 500 industry subject matter experts
Acquired by Sotera Health in 2021

About Sotera Health

The name Sotera Health was inspired by Soteria, the Greek goddess of safety, and reflects the Company’s unwavering commitment to its mission, Safeguarding Global Health^®.

Sotera Health Company, along with its three best-in-class businesses – Sterigenics^®, Nordion^® and Nelson Labs^®, is a leading global provider of mission-critical end-to-end sterilization solutions and lab testing and advisory services for the healthcare industry. With a combined tenure across our businesses of nearly 200 years and our industry-recognized scientific and technological expertise, we help to ensure the safety of over 190 million patients and healthcare practitioners around the world every year.

We are a trusted partner to 5,800+ customers in over 50 countries, including 40 of the top 50 medical device companies and 9 of the top 10 pharmaceutical companies.

Commitment to Quality

Our Certificate of Registration demonstrates that our Quality Management System meets the requirements of ISO 9001:2015, an internationally recognized standard of quality.

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.

FDA Harmonization

Posted on by Joby Semmler

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.

About RCA’s Pharmaceutical Consulting Services

Client Solutions

Whether you’re in the product planning, development or pharmaceutical lifecycle management stage or need a remediation strategy for a compliance crisis, Regulatory Compliance Associates will guide you through every pharmaceutical consulting step of the regulatory process. Our pharmaceutical consulting Experts will create a customized approach depending on your product and company’s individual needs. Our regulatory compliance clients include:

Companies new to FDA, Health Canada or EU regulations and regulatory compliance
Start-up organizations with novel submissions to 510(k) submissions from multi-national corporations
Investment firms seeking private equity due diligence for pre-acquisition and post-deal research
Law firms seeking pharmaceutical consulting firm expertise in the remediation of warning letters, consent decrees, 483’s or import bans

Regulatory Affairs

Regulatory affairs is Regulatory Compliance Associates backbone. We exceed other pharma consulting companies with industry experts experienced in complexities of the pharmaceutical and biopharmaceutical industries. Our pharma consulting expertise spans all facets and levels of Regulatory Affairs. Additionally, we specialize in Regulatory Support for New Products to Life Cycle Management, Outsourced Regulatory Affairs, Submissions, Training, and more.

New Product Support
Product Lifecycle
Other Regulatory Services
Combination Products

Compliance Assurance

Assessments
Audits
Regulatory Agency Response
Preparation and Training
Inspection Readiness
Data Integrity

Quality Assurance

Regulatory Compliance Associates Quality consulting includes assessments, strategy, implementations, staff augmentations, and identification of quality metrics to ensure continuous improvement. Our pharma consultants understand the strategic thinking needed to align your business needs and goals. Regulatory Compliance Associates quality assurance services include quality experts with experience spanning major corporations and start-ups. Our pharmaceutical consulting firm knows firsthand how to achieve, maintain, and improve quality. Finally, our regulatory compliance services team excels in transferring continuous improvement knowledge to your organization.

21 CFR Part 11
Data Integrity
Manufacturing Support
Facility Support
Quality Metrics

Remediation Services

Regulatory Compliance Associates pharma regulatory consultants will develop a comprehensive proof book of documented evidence demonstrating the corrective action taken to remediate non-compliant issues. In addition, each Regulatory Compliance Associates pharma consulting Expert understands compliance enforcement. We’ll prepare a comprehensive pharma consulting strategy to assist in your remediation efforts, drive continuous improvement, and maintain regulatory compliance with the regulations.

Regulatory Action
Regulatory Compliance
Regulatory Enforcement
Warning Letter
483 Observation
Oversight Services
Risk Management Plan

About Regulatory Compliance Associates

Regulatory Compliance Associates^® (RCA) provides pharmaceutical consulting to the following industries for resolution of life science challenges:

As your partners, Regulatory Compliance Associates can negotiate the potential minefield of regulatory compliance and regulatory due diligence with insight, hindsight, and the clear advantage of our unique expertise and experience.

Founded in 2000
Headquartered in Wisconsin (USA)
Expertise backed by over 500 industry subject matter experts
Acquired by Sotera Health in 2021

About Sotera Health

The name Sotera Health was inspired by Soteria, the Greek goddess of safety, and reflects the Company’s unwavering commitment to its mission, Safeguarding Global Health^®.

We are a trusted partner to 5,800+ customers in over 50 countries, including 40 of the top 50 medical device companies and 9 of the top 10 pharmaceutical companies.

Commitment to Quality

Our Certificate of Registration demonstrates that our Quality Management System meets the requirements of ISO 9001:2015, an internationally recognized standard of quality.

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.

US FDA Inspection

Posted on by Joby Semmler

Amanda Pedersen, senior editor for MD+DI magazine, interviewed Susan Schniepp, Troy Fugate, and Steven Niedeleman to discuss “some of the craziest things FDA investigators hear during a US FDA inspection”. Below is an excerpt of her widely circulated column.

One pearl of wisdom I often hear from regulatory and quality experts on the subject of managing FDA inspections is to answer the investigator’s questions and then zip it – do not offer more information than what is asked. For this reason alone, I would be a terrible “front room” person during an FDA inspection.

While I typically work best under pressure, uncomfortable silence is my kryptonite. I can easily see myself getting nervous and word-vomiting all over the investigator. There’s been a rash of medical device recalls and regulatory snafus in recent weeks, so it seems like a good time for some tried and true tips for interacting with FDA.

1. “You don’t know what you’re talking about.”

It should go without saying, but never argue with the FDA investigator or insult their intelligence. It’s not going to lead anywhere good. If you do happen to find yourself in a disagreement during the inspection, do your best to de-escalate the situation. Whatever you do, don’t choose violence.

Troy Fugate, co-founder and vice president at Compliance Insight, recently shared a wild story from the field about an FDA inspection at a foreign site that went horribly wrong. The plant manager didn’t like that the investigator was finding problems and a heated argument ensued. The plant manager became so angry that he punched the investigator in the face.

2. “During the last inspection, the FDA investigator saw the same thing and did not put it on the Form 483.”

That would be like telling a police officer that you’ve been pulled over before for the same violation, but you got off with a warning. Don’t expect the investigator to second-guess their FDA 483 observation just because you got away with the same issue in the past.

3. “The last investigator was crazy.” Or “The last investigator did not know what they were doing.”

Best case scenario, the FDA investigator agrees with you, but wonders if you’ll badmouth them during your next US FDA inspection. Worst case, you just insulted their favorite colleague.

4. “I told them not to do it this way…”

Don’t be that person. Present a united front as a company and simply acknowledge the issue and express a willingness to address it. Don’t throw your colleagues under the bus in front of FDA because you’re only going to make yourself look bad.

5. “The management of this firm is only concerned with profits and does not take quality seriously.”

Even if this is true, nothing good will come from sharing the company’s dirty laundry with FDA. If you have legitimate concerns about your firm’s quality assurance, there is surely a more appropriate time and place to bring it up than during an FDA inspection. If your concerns get brushed off, maybe consider going the whistleblower route.

6. “We don’t have enough people or time to review all those complaints…”

Manufacturers must prioritize their resources. Being a small or understaffed company is no excuse to turn a blind eye to quality complaints, especially in medtech where people’s lives may be at stake. Don’t waste time during an FDA inspection trying to justify poor handling of complaints.

7. “That is the way we have always done it.”

If I was an FDA investigator, this sad excuse for any FDA observation, however big or small, would make me wonder what other procedures the manufacturer has “always” done the wrong way.

8. “That’s not my fault. It was the previous person who did that…”

Don’t point fingers. It’s childish and annoying. The investigator doesn’t care whose fault something is, they just want it fixed.

9. Don’t lie to FDA … but that doesn’t mean you should have to put such a statement in writing anywhere that an FDA investigator might see it.

This one comes from an embarrassing story Susan Schniepp of Regulatory Compliance Associates shared with Medtech Insight a few years back. She had just started working as VP of a small company when FDA came knocking. The company’s director of quality handled the audit while Schniepp observed. The director proudly handed the investigator the company’s standard operating procedure (SOP) document on how the firm handled inspections. That seemed like a great first step until she saw the line on the SOP that read: Don’t lie to the FDA.

As Schniepp said, surely the FDA investigator wondered exactly what the firm is doing the rest of the time that it needs to remind its employees not to lie to FDA. So, she said, FDA inspections are all about perception and putting the company’s best foot forward, so to speak. Don’t write SOPs like you’re reading them, she advised, but like someone else is going to read them. But it wouldn’t be fair to point out all the ways manufacturers have screwed up during FDA audits without acknowledging that FDA inspectors are human too and have been known to act inappropriately and even downright creepy at inspection sites.

Click now to read the full article here.

About RCA’s Pharmaceutical Consulting Services

Client Solutions

Whether you’re in the product planning, development or pharmaceutical lifecycle management stage or need a remediation strategy for a compliance crisis, Regulatory Compliance Associates will guide you through every pharmaceutical consulting step of the regulatory process. Our pharmaceutical consulting Experts will create a customized approach depending on your product and company’s individual needs. Our regulatory compliance clients include:

Companies new to FDA, Health Canada or EU regulations and regulatory compliance
Start-up organizations with novel submissions to 510(k) submissions from multi-national corporations
Investment firms seeking private equity due diligence for pre-acquisition and post-deal research
Law firms seeking pharmaceutical consulting firm expertise in the remediation of warning letters, consent decrees, 483’s or import bans

Regulatory Affairs

Regulatory affairs is Regulatory Compliance Associates backbone. We exceed other pharma consulting companies with industry experts experienced in complexities of the pharmaceutical and biopharmaceutical industries. Our pharma consulting expertise spans all facets and levels of Regulatory Affairs. Additionally, we specialize in Regulatory Support for New Products to Life Cycle Management, Outsourced Regulatory Affairs, Submissions, Training, and more.

New Product Support
Product Lifecycle
Other Regulatory Services
Combination Products

Compliance Assurance

Assessments
Audits
Regulatory Agency Response
Preparation and Training
Inspection Readiness
Data Integrity

Quality Assurance

Regulatory Compliance Associates Quality consulting includes assessments, strategy, implementations, staff augmentations, and identification of quality metrics to ensure continuous improvement. Our pharma consultants understand the strategic thinking needed to align your business needs and goals. Regulatory Compliance Associates quality assurance services include quality experts with CAPA experience spanning major corporations and start-ups. Our pharmaceutical consulting firm knows firsthand how to achieve, maintain, and improve quality. Finally, our regulatory compliance services team excels in transferring continuous improvement knowledge to your organization.

21 CFR Part 11
Data Integrity
Manufacturing Support
Facility Support
Quality Metrics

Remediation Services

Regulatory Compliance Associates pharma regulatory consultants will develop a comprehensive proof book of documented evidence demonstrating the corrective action taken to remediate non-compliant issues. In addition, each Regulatory Compliance Associates pharma consulting Expert understands compliance enforcement. We’ll prepare a comprehensive pharma consulting strategy to assist in your remediation efforts, drive continuous improvement, and maintain regulatory compliance with the regulations.

Regulatory Action
Regulatory Compliance
Regulatory Enforcement
Warning Letter
FDA 483 Observation
Oversight Services
Risk Management Plan

About Regulatory Compliance Associates

Regulatory Compliance Associates^® (RCA) provides pharmaceutical consulting to the following industries for resolution of life science challenges:

Founded in 2000
Headquartered in Wisconsin (USA)
Expertise backed by over 500 industry subject matter experts
Acquired by Sotera Health in 2021

About Sotera Health

The name Sotera Health was inspired by Soteria, the Greek goddess of safety, and reflects the Company’s unwavering commitment to its mission, Safeguarding Global Health^®.

We are a trusted partner to 5,000+ customers in over 50 countries, including 40 of the top 50 medical device companies and 9 of the top 10 pharmaceutical companies.

Commitment to Quality

Our Certificate of Registration demonstrates that our Quality Management System meets the requirements of ISO 9001:2015, an internationally recognized standard of quality.

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.

Medical Device Cybersecurity Guidance

Posted on by Joby Semmler

The International Medical Device Regulation Forum (IMDRF) recently published updated cybersecurity guidance for the medical device industry. The medical device cybersecurity working groups at IMDRF have been busy lately, publishing multiple final documents about medical devices & software as medical device (SaMD).

Regulatory Compliance

IMDRF’s medical device guidance provides steering assumptions for both regulatory compliance & medical device cybersecurity, which are appropriate for sponsors developing medical devices. Further, a primary objective of the guidance is simultaneously increasing patient safety & reducing external threats for providers and HCPs.

Global Harmonization

The guidance begins with harmonization concepts that could affect multiple departments inside a medical device manufacturer. Additionally, key areas for harmonization programs highlighted by the cybersecurity guidance include:

Product design
Risk management activities
Device labelling
Regulatory submission
Information sharing
Post-market activities

Product Life Cycle (PLC)

IMDRF’s cybersecurity guidance continues on with a deeper evaluation of risks associated across the product life cycle. It is recommended for potential vulnerabilities to be considered for any product life cycle stage, especially considering legacy devices that may be vulnerable to strategic risk.

Product Design

Product design considerations include the initial phases of medical device development and continues until the end of support (EOS) once a product is discontinued. The four product design stages the cybersecurity guidance refers to when it comes to total product life cycle:

Development Stage
Support Stage
Limited Stage
End of Support

Development Stage (Stage 1)

The Development Stage occurs during the pre-commercialization phase before a medical device is approved by a regulatory body. This is when medical device manufacturers begin to incorporate security into the product concepts being designed. Design controls are critical in this stage for medical device manufacturers to leverage when considering how to mitigate risks.

Finally, an important deliverable of the Development Stage is product-related security documentation. The documentation is designed to help unfamiliar users to understand how to securely operate the medical device.

Support Stage (Stage 2)

The Support stage is during the initial post-launch phase and may continue for many years. Medical devices in this stage are:

Currently used for providing patient care
Available for purchase on the open market
Contain major software, firmware, or programmable hardware components
Support for software, firmware or components is provided by the medical device manufacturer

Additionally, medical devices in the Support stage should receive full cybersecurity support. This support often includes software patches, software updates, hardware updates, and incremental support the manufacturer considers appropriate.

Limited Support Stage (Stage 3)

Medical device manufacturers continue to provide cybersecurity support during Stage 3. However, as product development transitions to a more current medical device design, different constraints are involved with the transition. Medical devices in Stage 3 often require additional network controls compared to medical devices in Stage 2:

Third-party components or software may be used more frequently than internally developed updates or patches
Cybersecurity best practices integration is often governed by the ease of following support practices outlined in the Stage 2
Medical device manufacturers must explain to users the existing limitations that are now recognized in the devices and services affected
Healthcare providers using the medical device should begin to take more of an active role in unmitigated features of security defense.

End of Support Stage (Stage 4)

Medical devices in Stage 4 are considered more vulnerable than any of the other stages. They may still be in use for providing patient care, but they have been publicly identified as no longer being supported by the medical device manufacturer. Each of these scenarios result in a medical device that cannot be consistently defended against modern cybersecurity dangers.

Critical facets healthcare information technology departments should look for include:

Medical devices that have been declared EOS by the medical device manufacturer
Medical devices that are not actively marketed or sold by the medical device manufacturer
Medical devices that contain software, firmware, or programmable hardware components no longer supported by software developers
Medical devices with known risks to device safety and effectiveness that are unmitigated

Risk Management

Further, the guidance calls for a risk management approach to product lifecycle management featuring:

Security risk analysis
Security risk evaluation
Security risk control
Security risk acceptability

The cybersecurity guidance expands on product design and how security is incorporated and maintained through the product life cycle. This can be accomplished through using risk control and a secure development framework.

Risk mitigation recommendations for medical device manufacturers include:

Security design and controls based on intended use of the medical device
Security risk assessments across the risk management process
Threat modelling to help determine operational risk

Security testing and communication for medical device manufacturers include:

Customer facing product security documentation & communication
Post-market monitoring of cybersecurity vulnerabilities
Identification of vulnerabilities in third party risk management
Vulnerability risk identification based on the device security design, controls, and mitigations

Ensuring availability of security patches & mitigations based on device risk:

Coordinated and clear communication to all affected users
Description related to the vulnerability and its corresponding mitigations
Identification of other mitigation options when a security patch is unavailable

Data Integrity

One of the core principles the guidance stresses is cybersecurity information, data integrity and the importance of information sharing. IMDRF encourages medical device industry stakeholders to implement a proactive pre- and post-market approach to cybersecurity information sharing.

Moreover, timely information can help the industry recognize threats, evaluate associated risks, and react quickly as needed. An increase in industry transparency could directly benefit healthcare providers, medical device users and medical device companies.

Security Updates

An important section of the medical device cybersecurity guidance details stakeholder responsibilities related communications, risk management, and transfer of responsibility. Specifically, it is important that medical device manufacturer communications are comprehensive & identify types of documentation needed and when the medical device user may need it.

Product Security Documentation

Medical device manufacturers should ideally provide PLC documentation about security or support changes early in the Support stage. This helps HCP risk management during both the procurement & deployment of medical devices. Types of life cycle support for product security documentation includes:

Manufacturer disclosure statement for medical device security
Software Bill of Materials (SBOM)
Security test report summaries
Third-party security certifications
Customer security documentation

Product Life Cycle Documentation

Medical device companies should communicate the strategic life cycle milestones to their customers. Further, these interactions would include cybersecurity EOL and EOS dates if available. This helps to support HCPs during both the procurement & installation process.

Additionally, medical device manufacturers should provide this information as far in advance as possible. The goal is at least 2 years in advance to best support healthcare professionals with the following information:

Affected medical devices
Medical device operating system(s)
Version of medical device deployed
Medical device software components
Expected date of medical device service changes
Extent of medical device maintenance after a service change occurs
Additional design controls that help all involves parties

Vulnerability & Patching Information

If a vulnerability is uncovered, medical device companies should provide related vulnerability information. Further, the guidance specifically mentions the importance of both the appropriate mitigation or available software patch. Additionally, the guidance stresses an elevated priority be placed on high-risk vulnerabilities where timely communication is required. This communication is designed to help prevent both patient injury or device interruption.

Finally, the mitigation method and implementation instructions should be provided to the medical device operators. These security updates include both an over-air update or deployment of service personnel to help install the remedy.

Proactive Communications for Third-Party Components

Medical device software and other digital components within a medical device will reach EOL/EOS before the product itself does. In these cases, risk can increase based on the lack of support for these elements. To help compensate for these security risks, the cybersecurity guidance suggests medical device companies should:

Validate the list of third-party components used in medical devices
Track support status updates of third-party components used within their device
Assess the risks that exist when third-party components become unsupported
Communicate new risks and available risk mitigations to healthcare providers

About RCA’s Medical Device Consulting Services

The regulatory compliance process surrounding the medical device industry involves a strict adherence to pre/post market information throughout a device’s life-cycle. Even a single compliance issue you have can turn into a significant effect on your business. Regulatory Compliance Associates medical device consultants can help guide you through any stage of this strategic process, with capabilities during product development through the regulatory clearance/approval of your product.

Our team of over 500 medical device consulting Experts — including former FDA officials and regulatory compliance leaders in the field of medical device regulation — will work with your company to create a quality assurance and regulatory compliance approach tailored to your products and regulatory needs. Regulatory Compliance Associates works with international Fortune 100 companies, venture capital start ups, and companies of all sizes and shapes. our compliance enforcement solutions for law firms include remediation for warning letters, FDA 483’s, import bans or consent decrees. Very few regulatory compliance services have the same regulatory compliance expertise in a variety of medical fields.

Cybersecurity

For medical device manufacturers, technology can be a double-edged sword. The innovative technologies that elevate the quality of life for patients can also be used to potentially undermine the organization using the device. The consequences can affect the device itself if Regulatory Compliance Associates medtech consultants do not implement good IoT cybersecurity and FDA cybersecurity protocols.

At Regulatory Compliance Associates, we offer a wide variety of services for medical devices security to help ensure that your product is protected from cyber-attacks. With a well-planned design, along with full visibility of product development and the supply chain, Regulatory Compliance Associates medical device consultant Experts can help strengthen your device’s cybersecurity. We partner with medical device companies in each phase of the design cycle, including protecting inputs from threat exposure and hardening outputs for regulatory compliance & FDA submission approval of your medical technology.

Regulatory Affairs

Regulatory affairs is Regulatory Compliance Associates^® backbone, and we handle more submissions in a month than many manufacturers do in a lifetime. Our regulatory compliance consulting Experts have experience working with the FDA, global regulatory bodies and / or agencies, and notified bodies worldwide. Therefore, you can count on us for in-depth and up-to-date insights which increase speed-to-market.

As a trusted regulatory affairs consultant, our FDA veterans and industry experts represent Regulatory Compliance Associates^® as one of the top medical device consulting firms. We’re here to help you navigate the difficulties associated with new product submissions. Regulatory Compliance Associates^® medical device consulting company has expertise in both the approval process and post-approval support.

New Product Approval
Post-Approval Support
Outsourced Staffing
EU MDR
Combination Products

Compliance Assurance

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, developing a response to an FDA finding, or remediation to an adverse event, Regulatory Compliance Associates^® can help.

Our network of over 500 medical device consultant & FDA, MHRA & EMA veterans are industry professionals offers a unique blend of expertise. This allows Regulatory Compliance Associates^® to handle both simple and complex regulatory compliance challenges within medical device consulting companies.

Gap Assessments
Internal Audits
Employee Training
Notified Body Response
Data Integrity

Quality Assurance

Regulatory Compliance Associates^® Quality Assurance consulting includes quality system assessments, strategy, implementations, and identification of quality metrics to ensure continuous improvement, aligning with your business needs and goals. Each Regulatory Compliance Associates^® medical device consultant is a quality expert with experience spanning major corporations and start-ups. We know firsthand how to achieve, maintain, and improve quality, and we excel in transferring this knowledge to your organization.

In the medical devices field, quality assurance (QA) is more than merely ensuring the quality of a finished product. You need the tools to monitor and regulate every process from the design of a new product to continued quality compliance as the device is sent to market. At Regulatory Compliance Associates^®, we offer you the quality assurance services you need to monitor these processes and ensure quality compliance every step of the way.

With more than 20 years experience working with medical device consulting companies, Regulatory Compliance Associates^® trusted medical device quality assurance consultant team is fully equipped to handle your unique QA needs.

ISO13485
21 CFR 210
21 CFR 211
Outsourced Staffing
MDSAP
Facility Validation
Equipment Validation
Quality Metrics

Remediation Services

Regulatory Compliance Associates^® is widely recognized within medical device consulting companies & the life science industry for remediation services & support. Regulatory Compliance Associates^® ability to help companies successfully resolve complex regulatory challenges have a proven track record of success. Our medical device consulting services include significant experience with the development of responses to 483 Observations, Warning Letters, Untitled Letters and Consent Decrees.

Regulatory Action
Regulatory Compliance
Regulatory Enforcement
Warning Letter
483 Observation
Oversight Services

Our value goes beyond the initial response by helping companies successfully execute their action plans, develop an improved compliance culture tailored to the needs of their business, and ultimately move beyond the regulatory action to emerge as a stronger business. We negotiate difficult demands of remediation with insight and the clear advantage of our medical device consultant expertise and experience that makes partnering with Regulatory Compliance Associates^® a competitive differentiator in the remediation space.

Quality System
Technical File
Design History File
Data Integrity
cGMP

Strategic Consulting

Whether it’s a strategy, a technical plan, or project, Regulatory Compliance Associates^®medical device consultancy can help ensure a successful project. Regulatory Compliance Associates^® medical device strategy consulting can deliver your project on time, on budget, and you’re never embroiled in a costly mistake.

Our medical device consultant Experts are industry Experts are here to provide the unique insight you need before an M&A deal, through a staffing crisis and in every area of your product’s development and life cycle. As the trusted medical device manufacturing consultants of thousands of companies around the world, we have the knowledge and expertise needed to deliver exceptional results to your business — no matter your size or unique needs.

Manufacturing Optimization
Product Lifecycle Management
Mergers & Acquisitions (M&A)
Due Diligence
Device Vigilance
Risk Management Plan
Product Complaints
Medical Information

About Regulatory Compliance Associates

Regulatory Compliance Associates^® (RCA) provides medical device consulting to the following industries for resolution of life science challenges:

Founded in 2000
Headquartered in Wisconsin (USA)
Expertise backed by over 500 industry subject matter experts
Acquired by Sotera Health in 2021

About Sotera Health

The name Sotera Health was inspired by Soteria, the Greek goddess of safety, and reflects the Company’s unwavering commitment to its mission, Safeguarding Global Health^®.

We are a trusted partner to more than 5,800 customers in over 50 countries, including 40 of the top 50 medical device companies and 8 of the top 10 pharmaceutical companies.

Commitment to Quality

Our Certificate of Registration demonstrates that our Quality Management System meets the requirements of ISO 9001:2015, an internationally recognized standard of quality.

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.

FDA Guidance: Continuous Manufacturing

Posted on by Joby Semmler

The U.S. Food and Drug Administration (FDA) recently updated its pharmaceutical manufacturing guidance on Continuous Manufacturing (CM), including elaborating on established industry best practices.

Examples of new insights provided by FDA include clarification of the differences between continuous manufacturing modes and manufacturing approaches. The intended purpose behind the guidance is to continue industry harmonization efforts between ICH guidance and FDA regulatory & statutory requirements.

Continuous Manufacturing

Continuous manufacturing involves the process of uninterrupted materials being steadily added into the manufacturing process. The in-process ingredients are then manufactured and simultaneously developed into output materials during manufacturing. The updated FDA guidance focuses on facets of a continuous manufacturing system where multiple steps of operation are connected as continuous flow manufacturing.

The intended seamless procedure is considered by many industry experts as more efficient and helps reduce human error. By comparison, batch manufacturing lines may not use the same types of automated monitoring nor leverage as many predictive maintenance data points.

Factors of Production

The FDA guidance provides a deeper explanation of the underlying continuous manufacturing factors of production. A description of these characteristics by the Agency expands upon continuous flow production themes, including types of technology, options for dosage form, or molecule type.

Topics that are broadly applicable to a continuous production system and batch manufacturing are not included in the updated guidance scope. FDA recommends to the reader to revisit other existing ICH Q7 guidance as needed and appropriate for the medical manufacturer.

Control Strategy

Continued process performance and product quality are two primary elements described in the scientific approach to continuous manufacturing. State of control relies on the continuous production process and unique parameters (e.g. process parameters, quality attributes, etc.) that are designed to stay within an appropriate pre-set range.

Further, the guidance specifically calls out the importance of identifying the root cause of drift. FDA continuous manufacturing examples highlighted for employees to closely monitor include variation of inputs, equipment fatigue, and aging of materials.

Process Dynamics

Understanding transient events and the various impacts they can have on the continuous production system is a critical facet of FDA Control Strategy. Further, the FDA guidance elaborates that this includes transient events that are both planned (e.g., process start-up, process shutdown or a manufacturing pause) and unplanned (e.g. production disturbance).

Residence Time Distribution (RTD)

One key takeaway from the FDA guidance for industry is understanding how process dynamics are characterized when output material quality is affected. Additionally, using measures like residence time distribution can help medical manufacturers differentiate between the time available for material transport and transformation.

This type of quality metric strategy is specific to the continuous manufacturing process an often includes:

Product composition
Product formulation
Material properties
Equipment design
Equipment configuration

Operating Range

Each planned operating range should be based on the process dynamics and characterized by the planned over the planned ranges and anticipated input. Further, the FDA clearly states that material variability should use scientifically justified approaches for measuring quality against process dynamics that illustrate the variation during material transport and transformation.

Material Characterization

The FDA guidance goes on to list material feeding, process dynamics and output material quality as crucial continuous manufacturing elements that negatively impact material characterization. The FDA guidance lists a materials characterization facility as important to increasing production quality. Finally, realizing the predictability of material attribute variability on process performance and product quality is significant to the control strategy.

Solid Dosage Form

While analyzing the continuous manufacturing material flow process in a solid dosage form, the FDA guidance lists the following considerations that can impact powder feeding:

Particle size
Cohesiveness
Adhesiveness
Hygroscopicity
Static charge
Surface area of drug substances and excipients

Chemically Synthesized

While analyzing the material flow process in a chemically synthesized drug substance, the continuous manufacturing FDA guidance lists the following considerations that can impact flow properties:

Viscosity
Concentration
Multi-phase feed

Monoclonal Antibody

While analyzing the material flow process in a therapeutic protein (e.g. monoclonal antibody) substance, the FDA guidance lists the following continuous manufacturing considerations that can impact cell culture performance, process performance, or process consistency:

Lot-to-lot variability
Cell culture media
Different types of feed components

System Integration

The FDA guidance goes into depth about integrated systems characteristics and how equipment design can influence continuous manufacturing performance:

Design configuration
- Maximum run time compatibility
- Parts geometry impacting transformation
- Integration and transfer steps
Design interface
- Surge tanks
- Mass flow rate
Material diversion and sampling
- Diverter valve
- Sampling probe
- Material flow
- Material transformation

The guidance continues to elaborate on equipment selection and how the equipment design, if executed properly, can help with process simplification.

Process Monitoring

Process monitoring and maintaining a state of control during production increases the understanding of real-time system performance. The FDA guidance states that these common approaches to process monitoring and control are also applicable to continuous manufacturing:

Established target setpoints
Established control limits
Design space
Measurement specifications

Process Analytical Technology

The FDA guidance also elaborates on why process analytical technology is suitable for continuous manufacturing. Examples provided by the agency for industry employees include:

In-line ultraviolet (UV) flow cells
Monitoring therapeutic protein concentration
In-line near-infrared spectroscopy
Assessing blend uniformity or water content
High-performance liquid chromatography
Monitoring the conversion of chemical reactions

About RCA’s Pharmaceutical Consulting Services

Client Solutions

Whether you’re in the product planning, development or pharmaceutical lifecycle management stage or need a remediation strategy for a compliance crisis, Regulatory Compliance Associates will guide you through every pharmaceutical consulting step of the regulatory process. Our pharmaceutical consulting Experts will create a customized approach depending on your product and company’s individual needs. Our regulatory compliance clients include:

Companies new to FDA, Health Canada or EU regulations and regulatory compliance
Start-up organizations with novel submissions to 510(k) submissions from multi-national corporations
Investment firms seeking private equity due diligence for pre-acquisition and post-deal research
Law firms seeking pharmaceutical consulting firm expertise in the remediation of warning letters, consent decrees, 483’s or import bans

Regulatory Affairs

Regulatory affairs is Regulatory Compliance Associates backbone. We exceed other pharma consulting companies with industry experts experienced in complexities of the pharmaceutical and biopharmaceutical industries. Our pharma consulting expertise spans all facets and levels of Regulatory Affairs. Additionally, we specialize in Regulatory Support for New Products to Life Cycle Management, Outsourced Regulatory Affairs, Submissions, Training, and more.

New Product Support
Product Lifecycle
Other Regulatory Services
Combination Products

Compliance Assurance

Assessments
Audits
Regulatory Agency Response
Preparation and Training
Inspection Readiness
Data Integrity

Quality Assurance

Regulatory Compliance Associates Quality consulting includes assessments, strategy, implementations, staff augmentations, and identification of quality metrics to ensure continuous improvement. Our pharma consultants understand the strategic thinking needed to align your business needs and goals. Regulatory Compliance Associates quality assurance services include quality experts with experience spanning major corporations and start-ups. Our pharmaceutical consulting firm knows firsthand how to achieve, maintain, and improve quality. Finally, our regulatory compliance services team excels in transferring continuous improvement knowledge to your organization.

21 CFR Part 11
Data Integrity
Manufacturing Support
Facility Support
Quality Metrics

Remediation Services

Regulatory Compliance Associates pharma regulatory consultants will develop a comprehensive proof book of documented evidence demonstrating the corrective action taken to remediate non-compliant issues. In addition, each Regulatory Compliance Associates pharma consulting Expert understands compliance enforcement. We’ll prepare a comprehensive pharma consulting strategy to assist in your remediation efforts, drive continuous improvement, and maintain regulatory compliance with the regulations.

Regulatory Action
Regulatory Compliance
Regulatory Enforcement
Warning Letter
483 Observation
Oversight Services
Risk Management Plan

About Regulatory Compliance Associates

Regulatory Compliance Associates^® (RCA) provides pharmaceutical consulting to the following industries for resolution of life science challenges:

Founded in 2000
Headquartered in Wisconsin (USA)
Expertise backed by over 500 industry subject matter experts
Acquired by Sotera Health in 2021

About Sotera Health

The name Sotera Health was inspired by Soteria, the Greek goddess of safety, and reflects the Company’s unwavering commitment to its mission, Safeguarding Global Health^®.

We are a trusted partner to 5,800+ customers in over 50 countries, including 40 of the top 50 medical device companies and 9 of the top 10 pharmaceutical companies.

Commitment to Quality

Our Certificate of Registration demonstrates that our Quality Management System meets the requirements of ISO 9001:2015, an internationally recognized standard of quality.

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.

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

To 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.

About RCA’s Pharmaceutical Consulting Services

Client Solutions

Companies new to FDA, Health Canada or EU regulations and regulatory compliance
Start-up organizations with novel submissions to 510(k) submissions from multi-national corporations
Investment firms seeking private equity due diligence for pre-acquisition and post-deal research
Law firms seeking pharmaceutical consulting firm expertise in the remediation of warning letters, consent decrees, 483’s or import bans

Regulatory Affairs

New Product Support
Product Lifecycle
Other Regulatory Services
Combination Products

Compliance Assurance

Assessments
Audits
Regulatory Agency Response
Preparation and Training
Inspection Readiness
Data Integrity

Quality Assurance

Regulatory Compliance Associates Quality consulting includes assessments, strategy, implementations, staff augmentations, and identification of quality metrics to ensure continuous improvement. Our pharma consultants understand the strategic thinking needed to align your business needs and goals. Regulatory Compliance Associates quality assurance services include quality experts with experience spanning major corporations and start-ups. Our pharmaceutical consulting firm knows firsthand how to achieve, maintain, and improve quality, and we excel in transferring pharma consulting knowledge to your organization.

21 CFR Part 11
Data Integrity
Manufacturing Support
Facility Support
Quality Metrics

Remediation Services

Regulatory Compliance Associates pharma regulatory consultants will develop a comprehensive proof book of documented evidence demonstrating the corrective action taken to remediate non-compliant issues. In addition, each Regulatory Compliance Associates pharma consulting Expert understands compliance enforcement. We’ll prepare a comprehensive pharma consulting strategy to assist in your remediation efforts, drive continuous improvement, and maintain regulatory compliance with the regulations.

Regulatory Action
Regulatory Compliance
Regulatory Enforcement
Warning Letter
483 Observation
Oversight Services
Risk Management Plan

About Regulatory Compliance Associates

Regulatory Compliance Associates^® (RCA) provides pharmaceutical consulting to the following industries for resolution of life science challenges:

Founded in 2000
Headquartered in Wisconsin (USA)
Expertise backed by over 500 industry subject matter experts
Acquired by Sotera Health in 2021

About Sotera Health

The name Sotera Health was inspired by Soteria, the Greek goddess of safety, and reflects the Company’s unwavering commitment to its mission, Safeguarding Global Health^®.

We are a trusted partner to 5,800+ customers in over 50 countries, including 40 of the top 50 medical device companies and 9 of the top 10 pharmaceutical companies.

Commitment to Quality

Our Certificate of Registration demonstrates that our Quality Management System meets the requirements of ISO 9001:2015, an internationally recognized standard of quality.

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.

Category: Recent News CarouselDisplay posts for Recent News Carousel on homepage

Need help with your Supply Chain? Talk to our Experts →

Drug Packaging

Expiration Date

Product Identifier

National Drug Code

Suspect/Illegitimate Products

Artificial Intelligence

Regulatory Agency Response

About RCA’s Pharmaceutical Consulting Services

Client Solutions

Regulatory Affairs

Compliance Assurance

Quality Assurance

Remediation Services

About Regulatory Compliance Associates

About Sotera Health

Commitment to Quality

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.

Food and Drug Administration

FDA Timeline

Best Practices

Medical Research

Technical Documents

FDA Analysis

Regulatory Authority

Patient Engagement

About RCA’s Pharmaceutical Consulting Services

Client Solutions

About Regulatory Compliance Associates

About Sotera Health

Commitment to Quality

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.

1. “You don’t know what you’re talking about.”

2. “During the last inspection, the FDA investigator saw the same thing and did not put it on the Form 483.”

3. “The last investigator was crazy.” Or “The last investigator did not know what they were doing.”

4. “I told them not to do it this way…”

5. “The management of this firm is only concerned with profits and does not take quality seriously.”

6. “We don’t have enough people or time to review all those complaints…”

7. “That is the way we have always done it.”

8. “That’s not my fault. It was the previous person who did that…”

9. Don’t lie to FDA … but that doesn’t mean you should have to put such a statement in writing anywhere that an FDA investigator might see it.

About RCA’s Pharmaceutical Consulting Services

Client Solutions

About Regulatory Compliance Associates

About Sotera Health

Commitment to Quality

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.

Regulatory Compliance

Global Harmonization

Product Life Cycle (PLC)

Product Design

Development Stage (Stage 1)

Support Stage (Stage 2)

Limited Support Stage (Stage 3)

End of Support Stage (Stage 4)

Risk Management

Data Integrity

Security Updates

Product Security Documentation

Product Life Cycle Documentation

Vulnerability & Patching Information

Proactive Communications for Third-Party Components

About RCA’s Medical Device Consulting Services

About Regulatory Compliance Associates

About Sotera Health

Commitment to Quality

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.

Continuous Manufacturing

Factors of Production

Control Strategy

Process Dynamics

Residence Time Distribution (RTD)

Operating Range

Material Characterization

Solid Dosage Form

Chemically Synthesized

Monoclonal Antibody

System Integration

Process Monitoring

Category: Recent News Carousel
Display posts for Recent News Carousel on homepage

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.