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P R E P A R I N G F O R A N F D A
I N S P E C T I O N
A D A P T E D B Y L E O J . L A G R O T T E F R O M P E R S O N A L E X P E R I E N C E , P R E S E N T A T I O N S & B Y O T H E R F O R M E R
F D A I N V E S T I G A T O R S .
Florida Medical
Manufacturers Consortium
May 14, 2018
WHY DO WE NEED A SUCCESSFUL INSPECTION?
• Prevent Regulatory action
• Ensures consumer safety
• Your professional reputation
• Freedom from legal problems
• Verify our continuous improvement process
• Increased Customer Response via Sales
2
WHO’S ON THE INSPECTION TEAM?
• All QA/RA
• Engineers/Chemists
• Investigators
• Microbiologists
• Computer Specialist
• Headquarters Reviewer
3
7 SUBSYSTEMS OF THE QUALITY SYSTEM
Material Controls
Records/
Documents/
Change Controls
Design Controls
MANAGEMENT
Corrective
&
Preventive Actions
Production
&
Process Controls
Facility
&
Equipment Controls
Sterilization
Process
Controls
Medical Device
Tracking
Reports of Corrections and
Removals Medical Device
Reporting
WHAT WILL THEY LOOK AT? DEPENDS ON THEIR ASSIGNMENT!
• Complaints/Service/CAPAs/NCRs
• Computers/Software/eMDR
• QM, Procedures and Work Instructions
• Rejected batches
• Validation and Sterile Processes
• Overall facility
• Buildings, equipment, materials, cleaning procedures, HVAC, etc.
• Design Controls and Especially Risk Management
• New High Risk Devices, 510(k), Change Controls
• Labels and Packaging, Are you GUDID Compliant
• Components and Nonconformances reported in
• In-process materials and systems
• Validation processes including Sterilization
• Final Release Activities
• Logbooks, records and documents
• Areas not looked at before-Be Ready
5
WHAT SHOULD YOUR COMPANY BE DOING PRIOR TO THE INSPECTION ?
• Review all new designs; design changes and major NC since last inspection.
• Review your performance since last inspection (Internal Audits and CA).
• Provide continuing verifiable cGMP training to all employees.
• Taking broad steps to communicate the importance of the expected FDA inspection to all management and employees.
• Ensure Resources are available to review QS to ensure regulatory compliance. (continual)
• Identifying inspection coordinators.
• Developing an inspection response plan.
• Establishing communication procedures.
• Designating key personnel responsibilities.
• Establishing written policies-photos; recordings; etc.
• Enhancing your continuous improvement process.
6
WHAT SHOULD I DO PRIOR TO THE INSPECTION?
• Support preparation efforts. • Ensure your work area is neat and orderly. • Ensure your area equipment and instruments are
clean and calibrated. • Ensure your logs and production documents are
filled out completely, accurately and legibly at time of performance.
• Be prepared. • Know your job. • Encourage your fellow workers. • Expect high quality in all your work-accept
nothing less. • Remember: First impressions are lasting
Impressions; Employees, facilities and high quality documents make a lasting impression with the FDA! 7
WHAT CAN I DO DURING THE INSPECTION?
• Listen carefully to questions.
• Don’t assume you know the question.
• Answer only after the question is fully stated.
• Be confident of your answer. If you don’t know, say so.
• Avoid bragging about your area.
• Don’t be nervous.
• Re-review all your procedures.
• Provide only what is asked for.
• Don’t leave documents out on your desk.
• Keep your area clean. Be ready any day!
• Be proud of your area but the best of things are left
unseen.
8
HOW DO I ANSWER AN INVESTIGATOR’S QUESTIONS? • Do’s
• Don’ts
9
DO
• Be prepared. • Be professional. • Provide documents in a timely fashion. • Answer questions directly and honestly. • Recognize“ I Don’t Know” is an acceptable
answer.
Don’t • Guess or estimate. • Volunteer information. • Provide any misinformation. • Provide misleading information. • Show temper or be argumentative 10
R E S P O N D I N G T O
T H E F O R M F D A - 4 8 3
Florida Medical
Manufacturers Consortium
May 14, 2018
7 STEPS TO RESPOND TO FDA 483 INSPECTIONAL OBSERVATIONS
• Respond to the FDA 483 violation(s) in less than 15 business days
– Use New Electronic Format to Appropriate Compliance Division
• Use your CAPA forms instead of a memo
– First Page prepare a Cover Letter backed by all CAPAs and Corrective Actions
• Document the investigation and root cause
• Don’t forget containment and correction
– If a market withdrawal or Recall is planned, demonstrate containment of affected
product before end of inspection with plan to continue if completed.
• Explain the corrective action plans and timelines
– Send all documents corrected, SOPs, Work Instructions, Training Records
• Show the FDA you have already taken action
– Demonstrate initiation of CAPAs or Document corrections before end of inspection
• Follow-up before the FDA does
– At a minimum every 30 days or as corrective actions are completed
12
NEW FDA CONTACT INFORMATION
Florida is under the new reorganization of Office of Regulatory Affairs Office of Medical Devices and Radiological Health Operations (OMDRHO) Division 2 – Central
555 Winderley Place, Suite #200
Maitland, FL 32751
Area Under Division 2- AL; FL; GA; IA; IL; KS; LA; MN; MO; MS; NC; ND; NE; SC; SD; TN; WI; Puerto Rico and Virgin Islands
Send all correspondence via email: [email protected]
Label all attachments and keep each file less than 100MB. If greater send multiple emails
13
THANK YOU
DISCUSSION & QUESTIONS
14
Leo J. Lagrotte Senior Consultant [email protected] 941-920-2645
www.qss-llc.com