Segment: Strategic Consulting

Cannabis Business Success

Posted on by Brandon Miller

The cannabis consulting market is moving very quickly to support new businesses and many competitors are seeking the consumer’s attention. Right now, there’s no doubt that CBD-based products are getting plenty of attention. Gummy bears and other edibles are making the news, and the media is filled with stories about the powers of CBD oil.

 

At the same time, there are increasing calls for cannabis regulation from federal and state agencies as well as consumer groups. How can you ensure customers find you, and how can you grow your own successful business? The following cannabis consulting tips can help:

 

  • Know the rules: You cannot be successful if regulatory agencies shut you down or discredit your business model. If you manufacture or market CBD products, familiarize yourself with Current Good Manufacturing Practice (CGMP) regulations, state laws and FDA rules. A cannabis consulting expert can help you determine if the product is a supplement or drug, and follow the general guidelines for that type of product.
  • Offer quality and consistency: Create systems to ensure your products are consistent. Avoid switching vendors, suppliers and partners to allow you to develop a product you can stand behind. A cannabis consulting firm can leverage testing to prove the quality and maintain control of the manufacturing process.
  • Keep it real: Only advertise or market product benefits if you have hard data for that product. The FDA and other agencies have been sending warning letters for non-compliance to CBD and related businesses based on marketing alone. Even if you are creating a quality product, you need to make sure you can stand behind every word of your marketing. Stay consistent in branding and keep providing quality to your customers.
  • Get ready for regulations: Even if you are successful today, you need to stay agile for the upcoming regulatory changes. Keep alert to changes in state bills and new rules created at the federal level. Start documenting and testing now and invest in processes that back up your product. The more transparent and data-focused you can afford to be, the more prepared you may be for coming law changes.
  • Focus on customers: Customers are getting plenty of contrary information about cannabis and CBD. They may hear about the beneficial properties of these products, but they may also be hearing warnings from other sources. Consider how confusing this may be and offer quality information and reassurance about your products, backed up by testing so customers know they can trust you. Arm your audience with the information they need to buy from you.

 

Pave the Road for Cannabis Success

 

Do you need a partner for your business success? Regulatory Compliance Associates helps companies just like yours stay compliant. We help you address regulatory and quality issues and allow you to focus on growth while we stay on top of regulatory and FDA changes. Contact us at Regulatory Compliance Associates to learn what we can do for you.

 

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].

Supply Chain Management: Avoiding Interruptions

Posted on by Brandon Miller

Supply chain management is delicate — it only takes one “broken link” in the chain to significantly impact every aspect of a business’s operations. In a time when a pandemic is raging across the globe and wreaking havoc on manufacturing, maintaining an efficient, avoiding supply chain interruptions is more challenging than ever.

 

Pharmaceutical companies, medical device manufacturing, and a host of other industries are seeking ways to avoid costly interruptions by tightening their supply chains. In this post, we’ll offer some solutions your organization can consider implementing to prevent disruptions.

 

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

 

Manufacturing Location

 

During the last century, businesses started looking to move their manufacturing operations to geographical areas where they could take advantage of lower labor costs. Companies in the U.S., for instance, began shifting production to Mexico, and eventually, India and Asia.

 

Logistics Management

 

While these plant relocations provided substantial cost savings for many years, several factors have conspired to reduce or eliminate the potential benefits. For example, COVID-19 has resulted in multiple plant closures and disrupted logistics management around the world. Growing political unrest in several nations is another contributing factor. It pays to periodically re-evaluate your global supply chain to determine whether it’s still cost-effective or increasing your risk of interruption.

 

Supply Chain Analytics

 

Supply chain interruptions

Are your manufacturing processes compatible with modern supply chain analytics and automation resources? As technology continues to improve, automation can provide a more practical and affordable alternative for a pharma company in many cases.

 

One of the most significant advantages of supply chain automation is the opportunity to integrate your systems with larger suppliers. By partnering with conglomerates that have access to numerous resources and advanced technologies, you’ll reduce the likelihood of a supply chain disruption within your operations.

 

Sourcing Opportunities

 

Relying on a single supplier or limited supplier base can leave you vulnerable if a problem occurs. Proactively seeking global supply chains that can replicate the services of your core suppliers can help you to make a fast, seamless shift if the need arises. It’s a reliable way to safeguard your company against disruptions resulting from unexpected shutdowns and similar issues.

 

Supply Chain Visibility

 

Too many big pharma companies lack end-to-end supply chain visibility. By gaining a better understanding of every aspect of your chain, you can anticipate where a breakdown is likely to occur and take the appropriate corrective measures. The process will also help you develop a contingency plan in case a disruption occurs.

 

Continuous Improvement

 

Even top pharmaceutical companies find it’s not always possible to avoid an interruption, even when leveraging manufacturing automation. When a disruption does occur, conduct a thorough supply chain audit to determine the cause. Use the information you obtain to prevent the situation from happening again. Make sure you document your response procedures based on pharmaceutical industry standards and make them a part of your future contingency plan.

 

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].

Inshoring Strategy

Posted on by Brandon Miller

As with many industries these days, pharmaceutical manufacturers are now reevaluating the structure of their manufacturing operations. A specific focus area is whether returning some or all production processes to American shores (inshoring) is a more practical and cost-effective alternative to the offshoring trend that’s been prevalent for several decades. 

 

Are you Considering In-Shoring your Pharmaceuticals?  Talk to our Experts →

 

Factors That Impact the Inshoring/Off-Shoring Decision

 

Examples of crucial considerations when in-shoring pharma include:

 

Manufacturing

 

If yours is like many pharma operations, you chose to outsource due to the lower production and labor costs available overseas. If it’s been a while since you’ve compared manufacturing abroad vs. at home, consider conducting a comprehensive cost analysis. You might be surprised to learn that you can now produce a pharma product in the U.S. more cheaply than before. In some cases, the costs are now nearly as low as in China.

 

Suppose your manufacturing cost analysis yields favorable results and you determine to move forward with in-shoring. The next step is to decide the type of manufacturing facility that makes the most sense for your operation. Specifically, you should determine whether a brownfield (existing) or greenfield (brand-new) site is the better option. 

 

Technology

 

If you’re evaluating an existing structure, take a look at the current equipment and technology. Are they compatible with your projects’ demands? If not, can you make cost-effective upgrades or modifications to bring them up to speed? If these hurdles are prohibitive, building a greenfield facility will likely provide a more practical and affordable long-term solution. 

 

A greenfield site enables you to customize your manufacturing processes more effectively since you are building and equipping the facility from scratch. On the downside, the costs of a new building, compatible machinery, and hiring and training fresh personnel may not be affordable for some pharma operations. And constructing a new facility from the ground up takes time — a commodity that’s often in short supply in today’s ultra-competitive pharma industry. 

 

Supply Chain

 

Supply chain access is another vital factor when in-shoring pharma operations. Given that many of the raw materials and ingredients used to manufacture pharma products and medical devices come from outside the U.S., finding acceptable substitutes at home can pose a challenge. If you must import them, you’ll need to consider the added transportation and costs of these components.

 

You’ll also need to account for all applicable supply chain qualifications. For instance, if you’re partnering with new suppliers, you must ensure they meet your company’s unique qualification and quality criteria. Transportation concerns are another issue to evaluate. Will you be able to get the materials to your facility reliably on time to accommodate your production schedules? You’ll need to implement a qualified transportation system for certain essential ingredients and finished goods. 

 

Operations

 

From a business/operational perspective, consider how in-shoring pharma will impact your personnel. For instance, if you decide to move into an existing facility, determine if there will be sufficient space for your workers and any new equipment you add. Also, can the facility accommodate essential areas such as clean rooms, warehousing, waste treatment systems, and cold storage spaces?

 

If you’re relying on outdated technology systems, you’ll likely need to make upgrades to meet the changes in demand. Examples of systems that require careful evaluation include ERP, CAPA management, and eDoc, to name a few. 

 

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: Product Lifecycle

Posted on by Brandon Miller

The USA Food and Drug Administration (FDA) recently provided updated regulatory guidance for Product Lifecycle Management in the pharmaceutical industry. The guidance helps pharmaceutical companies and manufacturers better understand the administration of post-approval chemistry, manufacturing, and controls changes.

 

Lifecycle Management

 

The guidance provides new insights into lifecycle management concepts for both new and existing pharmaceutical products, including chemical and biologics. The FDA regulatory team looked to synchronize its updated guidance more closely to ICH guidelines used with other global regulatory agencies.

 

The benefit realized by pharmaceutical companies would be options for reducing duplicate clinical studies and increasing the standardization of safety information reporting. By revising facets of FDA marketing application submissions as well, the Agency appears to be taking a more holistic approach to improving drug development quality and pharmaceutical manufacturing strategy.

 

Looking for help Managing your product’s Life Cycle? Talk to our Experts →

 

Manufacturing Process

 

Changes include language revisions to surrounding regional legal frameworks, an expanded clarification of critical process parameters, and identifying established conditions for manufacturing processes. One important revision for regulatory affairs employees is the new recommended content of the product lifecycle management document and its location within the technical file. Clarity revisions were also made to further expand on the use of available tools described in the guideline for master files.

 

Regulatory Submission

 

The new FDA guidance also expanded its language on post-approval chemistry, manufacturing, and controls changes. With additional tools and principles intended to improve the industry’s management of post-approval changes, FDA leadership is hoping to increase transparency between both industry employees and regulatory authorities.

 

The benefit to pharmaceutical companies should be a deeper understanding of how product and process knowledge will contribute in the real world to post-approval changes that require a regulatory submission. By defining the level of reporting categories, industry experts should experience a deeper understanding of risk compared to product quality.

 

Quality Management System

 

The new tools and principles are designed to improve data input into a company’s quality system. The goal is to enhance the industry’s ability to manage many chemistry, manufacturing, and controls changes that have a lower priority needed of regulatory oversight.

 

At the same time, many at the FDA are hopeful the tools and principles could result in fewer Marketing Authorization Application submissions that increase the associated regulatory burden. The guidance should increase both operational efficiency and regulatory flexibility when implemented with the proper regulatory framework and applied with widely accepted risk management principles in the pharmaceutical industry.

 

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 Machine Learning

Posted on by Brandon Miller

The U.S. Food and Drug Administration (FDA), Health Canada, and the United Kingdom’s Medicines and Healthcare products Regulatory Agency (MHRA) have recently identified 10 guiding principles for the development of Good Machine Learning Practice (GMLP).

 

These guiding software development principles should be used to:

 

  • Adopt good practices that have been proven in other sectors
  • Tailor practices from other sectors so they are applicable to medical technology and the health care sector
  • Create new practices specific for medical technology and the health care sector

 

Need help putting these principles into action? Talk to our Experts →

 

What is Artificial intelligence and FDA machine learning (AI/ML)?

Artificial intelligence and machine learning use software algorithms to learn from real-world use of the device to help improve the product’s performance.

 

Good Machine Learning Practice Guiding Principles

 

  1. Multi-Disciplinary Expertise Is Leveraged Throughout the Total Product Lifecycle. Helps ensure that ML-enabled medical devices are safe and effective and address clinically meaningful needs over the lifecycle of the device.
  2. Good Software Engineering and Security Practices Are Implemented. Implementation with attention to the “fundamentals”: good software engineering practices, data quality assurance, data management, and robust cybersecurity practices.
  3. Clinical Study Participants and Data Sets Are Representative of the Intended Patient Population. Manage bias, promote appropriate and generalizable performance across the intended patient population, assess usability, and identify circumstances where the model may underperform.
  4. Training Data Sets Are Independent of Test Sets. Training and test datasets are selected and maintained to be appropriately independent of one another.
  5. Selected Reference Datasets Are Based Upon Best Available Methods. Using the best available methods for developing a reference dataset ensures that clinically relevant and well-characterized data is collected and the limitations of the reference are understood.
  6. Design Is Tailored to the Available Data and Reflects the Intended Use of the Device. Design is suited to the available data and supports the active mitigation of known risks, like overfitting, performance degradation, and security risks.
  7. Focus Is Placed on the Performance of the Human-AI Team. Human factors considerations and human interpretability are addressed with emphasis on the performance of the Human-AI team.
  8. Testing Demonstrates Device Performance during Clinically Relevant Conditions. Developed and executed statistically sound test plans to generate clinically relevant device performance information independently of the training data set.
  9. Users Are Provided Clear, Essential Information. Users are provided ready access to clear, contextually relevant information that is appropriate for the intended audience.
  10. Deployed Models Are Monitored for Performance and Re-training Risks are Managed. Models have the capability to be monitored in “real world” use with a focus on maintained or improved safety and performance, as well as periodic training after deployment.

 

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].

Waterfall Methodology

Posted on by Brandon Miller

Click now to watch Regulatory Compliance Associates® Dr. Stephen Coulter explain how design controls and risk management play an intricate role in the Waterfall methodology:

 

 

The Waterfall methodology incorporates the usage of FDA design controls into the medical device design process. It serves as the primary connection between quality system requirements (QSR) and current good manufacturing practices (CGMP).

 

Waterfall Method

 

Conceptually, the FDA Waterfall model is designed to provide engineers with the flexibility to mitigate product risk, meet regulatory compliance and satisfy customer needs. It is a sequential process based on the quality assurance and medical device engineering principles listed in 21 CFR 820. The methodology itself is conceptualized in the image below from the Medical Device Bureau of Health Canada. 

 

Waterfall Development

 

To increase risk mitigation during the Waterfall methodology, both risk management & design controls are considered. They often become integrated processes during Waterfall product development. Many unique tools that medical device engineers use to define requirements & meet user needs are shared across these processes, even though each is based on a separate standard.

 

While design controls for FDA approval are referred to in 21 CFR 820, medical device risk management is internationally associated with ISO 14971. Three critical elements of risk mitigation strategies clearly focus on avoiding risk during product development:

 

  • Evaluating an associated risk
  • Controlling an evaluated risk
  • Monitoring risk control effectiveness overall

 

Input Requirements

 

The success of the Waterfall development method depends on early research & assessments conducted about input requirements that include strategic risk. Further, spending time documenting the inputs of user interface, user stories and product epics can help increase positive outcomes and reduce requirement risk overall.  Finally, any inconsistencies during the waterfall methodology between the proposed design & input requirements can be corrected across stages. This aligns with one of the primary motivations behind FDA originally developing 21 CFR 820 (e.g. helping medical device manufacturers find design deficiencies earlier in the process).

 

Risk Management

 

By starting the Waterfall process with this end state in mind, design inputs are more likely to pass failure testing & become a manufacturing output. This risk management strategy during a Waterfall project can begin with identifying the publicly known risks of competitive products. Second, the team is challenged to investigate if similar hazards could be associated with your medical device. When working with a Regulatory Compliance Associates risk management consultant, our clients are reassured that Waterfall development should detail how hazards can impact user needs & potential customers.

 

For example, design inputs should consider current regulations and global standards early in the waterfall process. This helps incorporate a risk management perspective even before verification and validation testing begins. Intended uses should consider predicate devices and if any causes for recalls are related to design, materials, or software. 

 

Waterfall Approach

 

So, does this mean risk management & design controls are connected in the waterfall approach? And if they are, how important is one over the other when leading to marketing approval or regulatory compliance? This process is often measured against a combination of factors, including:

 

  • Regulations & standards for clinical approval
  • Risk class of medical device being manufactured
  • Regulatory body reviewing the marketing submission

 

Enterprise risk management would consider all three of these factors individually and in combination when considering how to eliminate systemic risk. The Waterfall project management team can also use various tools and techniques while developing the risk management plan. These risk identification tools include conducting a risk analysis, performing an FMEA, and charting risk tolerance. 

 

Risk Analysis

 

Existing regulations & standards offer various types of risk tools that can be incorporated into design controls. This can include identifying risk levels and creating severity charts during the user needs & design inputs stages. Additionally, each new product will have different hazards and risk tolerance levels associated with the target patient. Being able to analyze the problem, control the problem, and mitigate the risk is essential to define in your risk analysis. Challenge yourself to reduce and identify hazards by analyzing the known data as much as possible.

 

FMEA

 

Failure Mode and Effects Analysis (FMEA) is a controlled technique to detect & concentrate on budding trouble. Each failure is commonly assigned a rating based on the negative effect it may cause. The Waterfall process would then take each rating and project how the marketplace, healthcare systems, or patients can be impacted. FMEAs are one of many risk mitigation tools that can help your team identify the hazards of your severity chart. Each charted hazard is established based on the severe nature of the hazard to the user and project requirements for design control.

 

Risk Tolerance

 

Further, after the severity is defined, all known or projected hazards can be developed into a risk tolerance chart. The risk tolerance chart can then be shared cross-functionally across the team to help everyone understand which design steps can increase user risk. One of the benefits of a risk tolerance chart is being able to show data visualization. The design team should consider how design controls and user needs can reduce the hazard’s impact. Finally, a waterfall chart could also project the negative consequences of adverse events and what the estimated cumulative impact might be during a product crisis scenario.

 

Risk Management Summary

 

Finally, once your team has evaluated the risks and decided on precautions, a risk management summary is developed. It may include involves multiple failure mode analysis types (e.g. product, process, etc.) and risk ratings. These initial ratings are typically based on the types of failures and the severity of the failure itself. Ranges can also be given to determine the risk management strategy and what is the acceptable level of product risk (e.g. high, medium, low).

 

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].