In an interview withPharmaceutical Technology®, Susan Schniepp, distinguished fellow, Regulatory Compliance Associates®, and co-chair of board of directors, Parenteral Drug Association, expands on the importance of maintaining a robust quality management system (QMS) in bio/pharmaceutical manufacturing.
For advanced therapy medicinal products (ATMPs) in particular, Schniepp emphasizes how fast-moving this sector is. “The regulations don’t keep up with the ATMPs. That technology, and their way of thinking, is turning over quicker than the regulatory standards,” she says.
“The changes in the regulations that are going to come are going to be around quality culture and maintaining a robust quality management system,” she adds. Ensuring documentation and keeping equipment calibrated are important practices to apply to these new fast-moving ATMPs, she states. Schniepp does not necessarily expect to see many changes in the regulations around ATMP development and manufacturing but thinks that there will likely be more guidance documents issued in the future, with one of FDA’s focuses being its quality management maturity model.
“There are some regulations out there that call out quality culture. In particular, the World Health Organization has one on data integrity. It has a definition and standard[s] on what quality culture is,” Schniepp says. She points out that a new aspect of her presentation at INTERPHEX this year is its interactive component, in which she sets up a scenario involving an internal audit where an incident occurs. She gives the audience three potential responses to discuss, but rather than simply asking them which response do they pick or which response is correct, she instead asks what does the chosen response say about that person or that company’s QMS and the maturity of that system?
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.
In this soundbite from RCA Radio, Dr. Helin Raagel and Dr. Matthew Jorgensen from Nelson Labs explain why the Cytotoxicity test during a biocompatibility evaluation is the most important test you will run.
What is Cytotoxicity? – Cytotoxicity is the degree to which a substance can cause damage to a cell. A substance or process that causes cell damage or death is referred to as cytotoxic, “cyto” meaning cell and “toxic” meaning poison. (Will the device kill or harm the cells it comes in contact with?)
There are three reasons why the cytotoxicity test is the most important test you run during a biocompatibility evaluation.
The test can be run quickly.
It is the most cost-effective test in an evaluation.
Most evaluation concerns come from the cytotoxicity results.
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 can help guide you through any stage of the medical device consulting 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.
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 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.
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.
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.
Regulatory Compliance Associates® is widely recognized within medical device consulting companies & the life science industry for our 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.
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:
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, 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
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 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.
In this soundbite from RCA Radio, Dr. Helin Raagel and Dr. Matthew Jorgensen from Nelson Labs explain biocompatibility testing. This includes the risk-based biocompatibility evaluation that medical devices go through before they receive regulatory approval.
This biocompatibility risk-based approach evaluates the risk of the device through consideration of the device’s cytotoxicity, irritation, and sensitization.
Cytotoxicity – Will the device kill or harm the cells it comes in contact with?
Irritation – Will the device make contact with the patient and cause skin irritation? (Redness and/or Swelling)
Sensitization – Will the device cause an allergic reaction?
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 can help guide you through any stage of the medical device consulting 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.
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 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.
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.
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.
Regulatory Compliance Associates® is widely recognized within medical device consulting companies & the life science industry for our 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.
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:
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
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 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.
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 forCannabis 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.
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. 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 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.
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.
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.
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.
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. 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:
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
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.
The US Food and Drug Administration (FDA) is likely going to continue to use remote inspection alternatives in a “hybrid approach” with in-person inspections, supplemented by audit and FDA inspection tools like remote interactive assessments.
In a recent Accessible of Accessible Medicine’s (AAM) conference Elizabeth Miller, Assistant Commissioner in FDA’s Office of Medical Products and Tobacco Operations within the Office of Regulatory Affairs (FDA’s inspectorate) stated “Ideally, inspections supplemented by additional tools, including records requests and remote interactive evaluations, would provide FDA with the greatest depth of information”.
What is an FDA Inspection “Hybrid Approach”?
It is part onsite work and part offsite/remote work to conduct an assessment. The FDA uses tools like video chat for inspection activities like virtual interviews. They also use technology like secure shared online folders for offsite FDA 483 document review.
The FDA audit could start with a record request and then come onsite, or vice versa. Remember, FDA doesn’t consider remote evaluations to be a replacement for inspections. Inspections are onsite and will start with the lead FDA investigator providing the most senior ranking person at the site a Form FDA 482, Notice of Inspection.. The Form 482s is not issued for remote interactive evaluations.
Instead, your company will receive an FDA Form 4003, FDA Inspection Records Request. Having the term “inspection” in the title of the form can be a little confusing, but it is not considered or counts as an inspection. However, the FDA’s remote work will likely inform their onsite work during the actual inspection. Companies who prepare to manage these FDA remote evaluations stand the best chance of success in an inspection. This is for all companies, whether you are conducting remediation because you’re having FDA compliance issues or not.
Signs currently point to these changes moving down the path to permanency. FDA remote inspections and reviews can and do allow for more efficient onsite inspections. Conducting remote records reviews can help the investigators save time on site by not having to sit in a conference room and read. It also reduces their COVID exposure (and yours) by potentially reducing FDA facility inspection onsite time.
It must be pointed out that having a remote review does not immediately equate to a shorter onsite inspection. The onsite time will be dependent on what the investigator is covering and what they are or not finding. For example, an FDA GMP inspection may still take a different amount of time than a FDA surveillance inspection, and so on.
The US Congress has even weighed in on the matter. For example, in a March 2021 Senate Health, Education, Labor and Pensions (HELP) Committee Hearing, Sen. Richard Burr, a member of the HELP Committee, suggested that the technology adoption for FDA virtual inspections should become more permanent in nature.
“The pandemic, I believe, has altered the model at FDA and the agency should not go back to its historical approach,” he said.
Risk-Based Model used to Identify FDA Inspections
The FDA’s risk-based criteria for prioritizing and selecting mission-critical inspections during the pandemic can be found in their Resiliency Roadmap for FDA Inspection Oversight. In the publication, they outline the factors helping to determine whether or not the inspection is mission-critical. These controls help FDA best utilize their already limited resources in protecting public health. The four specific factors the Agency is using are:
The product receiving a breakthrough therapy or regenerative medicine advanced therapy designation;
The product is used to treat a serious disease or medical condition and there is no substitute;
The product requires follow-up due to recall or there is evidence of serious adverse events or outbreaks of a foodborne illness; or
The product is related to the FDA’s COVID-19 response (e.g., drug shortages).
It is expected that this prioritization will be used during the remainder of the pandemic and that some will continue after travel restrictions and other impediments to inspections are eased or lifted.
FDA Inspection Hybrid Approach
Remote evaluations are time-consuming and take time to prepare and facilitate. Partner this with an onsite inspection and the time and effort quickly compound. Because of these activities are so time-consuming nature companies have had to improve how they efficiently and effectively manage these regulatory interactions.
One way to prepare is to look at your overall CGMP and quality system documentation and records to determine what needs to be scanned and uploaded to a secure shared folder prior to the start of the FDA remote review. The scanning process is time-consuming and if done ahead of time helps decrease the cycle time between the investigator’s request and the time you’ll have it ready to present to the investigator.
Another helpful hint is to ensure someone reviews the scanned file to ensure the entire document or record is scanned. With auto feeders on scanners, the dreaded folded page or previously stapled page getting jammed and not scanned properly is a common phenomenon. This can slow down any FDA pre-approval process meetings happening in real-time and can be avoided with focused preparation.
The preparation effort can also assist you in being prepared for, as well as hosting your own hybrid internal audits (ex: corporate quality audits), as well as customer and notified body audits (if you’re in medical devices and deal with ISO 9001 and other ISO certification).
What Our Experts Have to Say
Speculating on what the world might look like in terms of the use of alternative tools, industry representatives seemed in agreement that a hybrid approach would be most effective going forward.
Steven Lynn, RCA’s Executive Vice President of Pharmaceutical said:
“I don’t think the hybrid approach is going away anytime soon. It just makes better sense from a public health efficiency perspective to be able to look at documents and records remotely and then go onsite.”
“If I look at it from an FDA perspective, the hybrid approach gives the Agency a way to ensure investigators can review items prior to putting boots on the ground. The remote reviews also enable the Agency to pull in other scientific disciplines easier than it would be, had the investigator been onsite. From the industry perspective, it means we must spend more time preparing in order to successfully host these remote reviews and onsite inspections.”
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.
The Food and Drug Administration (FDA) recently announced a new guidance program for the life science industry regarding data integrity. This FDA guidance draft is currently open & available for the industry to comment on and provide feedback. Additionally, the FDA regulatory process that looks to be initially targeted by the food and drug authority includes:
Investigational New Drug Application (IND)
New Drug Application (NDA)
Abbreviated New Drug Application (ANDA)
Biologic License Application (BLA)
Code of Federal Regulations
The guidance draft cites several different code of federal regulation (CFR) that are being reviewed and analyzed during this process. Specific CFR federal regulations mentioned include:
21 CFR 11
21 CFR 50
21 CFR 56
21 CFR 58
21 CFR 210
21 CFR 211
21 CFR 312
21 CFR 601
21 CFR 820
Data Integrity
Specific use cases mentioned by FDA include data integrity throughout the clinical data management process in bioavailability (BA) & bioequivalence (BE) studies. Further, the FDA guidance provides initial suggestions to optimize data integrity success by focusing on three specific drivers:
Users or applicants in clinical trial
Site management of clinical trial
Quality management system for clinical trial
Finally, FDA provides best practices & recommendations for risk control and risk management. Understanding how to maintain good lab practice & clinical research success is essential for all participants.
FDA Guidelines
One of the primary objectives of the data integrity draft is to align FDA expectations with the clinical data being submitted in pharmacologic studies. Additionally, clinical data submitted by a drug sponsor for FDA drug approval must be:
“accurate, complete, and reliable, and that industry maintain data integrity throughout the data lifecycle of the product(s) or biologic therapeutic(s).”
Finally, new concerns are being raised about the evaluation of bioequivalence and bioavailability study data submitted during the FDA regulatory process. FDA highlights specific comments about regulatory concerns during in vivo pharmacology studies. The regulatory documentation lists specific areas adding to the erosion of data integrity based on FDA inspection experiences in the field:
Patient testing sites
Clinical testing sites
Analytical testing sites
Legal Regulation
The FDA guidance begins with reminding drug sponsors that they bear the responsibility of quality assurance even if a contact manufacturing organization (CMO) is engaged. Additionally, confirming a contract development and manufacturing organization (CDMO) has confidentiality processes in place is essential.
For drug sponsors who are submitting a FDA new drug application, ICH guidelines and FDA guidance should be followed by external vendors who are conducting the elements of study-related activity. Finally, clinical data being generated through bioavailability and bioequivalence studies must be durable & reliable in nature, and properly documented in a quality management system (QMS).
Testing Site
The regulatory guidance goes on to elaborate about the monitoring and oversight strategy needed for clinical testing. Specific drivers listed for analysis when selecting a drug manufacturing partner include:
Personnel Education
Personnel Experience
Personnel Training
Manufacturing standards and expectations should be documented clearly in a formal agreement. Additionally, FDA highlights that regulatory requirements for clinical study activities should be documented and followed, including:
Clinical study protocol
Clinical study procedure
Clinical study process
Finally, FDA recommends that bioanalytical analysis should include closer oversight and monitoring. Any CMO or CDMO must have documented analytical methods in their quality management system. Further, all analytical methodologies must follow applicable FDA regulations and be included in the QMS standard operating procedures (SOP).
Quality Management System
The FDA guidance transitions to describe database integrity and why any clinical services provider you choose must “use a quality management system to help ensure data integrity”. This includes testing sites managing a quality management system and efficacy of “data governance throughout the data lifecycle”.
Records Management
The operations team supporting the clinical research management should review the QMS using a pre-planned schedule, per the FDA guidance. All data governance used to store and retrieve information in the clinical trial management system should replicate the reliability & durability of the QMS.
Additionally, data integrity across the QMS would focus on each unique phase of the collection process. FDA recommends employees responsible for quality updates consider isolating job responsibilities between the separate data lifecycle phases to help reduce unintentional mishaps.
Clinical Technology
Using modern technology is recommended for all employees who are responsible & can impact data quality. Specific systems mentioned in the regulatory guidance that can improve data integrity include:
Computer hardware or related systems
362 software for security or performance
Peripheral devices, networks or cloud infrastructure for connectivity
Any associated IT documents for usability (e.g. SOP manual)
Metadata
The guidance goes on to explain more about classification & ensuring that metadata is correct. Metadata, as described by FDA, is “data about data” and provides clarifying information to the agency. Common types of metadata quality concerns are listed as examples:
Missing date/time stamp for when data was acquired
Incorrect measurement units or documentation
Missing user ID’s of the team who conducted data testing or data analysis
Sample Analysis
An important facet of the FDA guidance discusses sample analysis & if the clinical evaluation is completed at a location different from the original testing site. Employees conducting the clinical evaluation should be familiar with good clinical practice & fully understand the study protocol, various test methods that were used, and any quality management system SOPs to follow.
Further, different types of instruments & clinical equipment used during the sample analysis should be “calibrated, maintained and serviced” per FDA. The regulatory guidance cites several examples that should follow manufacturer service guidelines, including:
Balances & pipettes
Centrifuges & spectrometers
Liquid chromatographs
Refrigerators & storage freezers
Quality Assurance and Quality Control
Managing the risk associated with a QMS is an important facet of the FDA guidance. A quality assurance program should be implemented, including standard operating procedures that limit access control & processes to isolate a data breach. Further, implementing a quality control program can help find and remedy data integrity flaws. An efficient quality control program should include:
Mapping of standard processes & risk control
Employee training & knowledge gaps
Difference between unintentional & intentionally compromised data
Corrective Action and Preventative Action
If data integrity deviations are identified in a quality control analysis, FDA recommends a corrective and preventative action (CAPA) program be launched. Additionally, the CAPA would look at all relevant processes and tasks as a whole rather than isolating a repeat occurrence. The recommended best practices for a quality control plan include:
Assemble & examine information for review
Identify real & possible problems during the review
Explore problems & create appropriate CAPA
Verify & validate the success of the CAPA
Communicate updated CAPA success to applicable teams
Document activity & intelligence for management review
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].