The latest computer system industry standards for data [security]

Minimize the validation documentation to reduce costs without increasing regulatory or business risk.

Many companies are outsourcing IT resources and getting involved with Software as a Service (SaaS) and cloud computing. These vendors are not regulated and therefore regulated companies must ensure compliance for both infrastructure qualification and computer system validation. It is the regulated company that wants to avoid FDA form 483s and warning letters. The seminar is intended for regulated companies, software vendors, and SaaS/Cloud providers.

The instructor addresses the latest computer system industry standards for data security, data transfer, audit trails, electronic records and signatures, software validation, and computer system validation.

security

Today the FDA performs both GxP and Part 11 inspections, the Europeans have released an updated Annex 11 regulation that expands Part 11 requirements and companies must update their systems and processes to maintain compliance.

This seminar will help you understand the specific requirements associated with local and SaaS/cloud hosting solutions.

Nearly every computerized system used in laboratory, clinical, manufacturing settings and in the quality process has to be validated.

Participants learn how to decrease software implementation times and lower costs using a 10-step risk-based approach to computer system validation.

Finally, the instructor reviews recent FDA inspection trends and discusses how to streamline document authoring, revision, review, and approval.

Objectives of the Compliant with Part 11:

  • Understand what is expected in 21 CFR Part 11 and Annex 11 inspections
  • Avoid 483 and Warning Letters
  • Learn how to buy COTS software and qualify vendors.
  • Implement a computer system using risk-based validation to gain maximum productivity and reduce cost by as much as two thirds
  • Requirements for local, SaaS, and cloud hosting
  • How to select resources and manage validation projects
  • “Right size” change control methods that allows quick and safe system evolution
  • Minimize the validation documentation to reduce costs without increasing regulatory or business risk
  • Write test cases that trace to elements of risk management
  • Protect intellectual property and keep electronic records safe

21 CFR Part 11/Annex 11 – Compliance for Electronic Records and Signatures:

  • What Part 11 means to you, not just what it says in the regulations
  • Avoid 483 and Warning Letters
  • Explore the three primary areas of Part 11 compliance: SOPs, software product features, and validation documentation
  • How SaaS/cloud computing changes qualification and validation
  • Ensure data integrity, security, and protect intellectual property
  • Understand the current computer system industry standards for security, data transfer, and audit trails
  • Electronic signatures, digital pens, and biometric signatures
  • SOPs required for the IT infrastructure
  • Product features to look for when purchasing COTS software
  • Reduce validation resources by using easy to understand fill-in-the-blank validation documents

Read more at http://bit.ly/2CVLELD_SaaS_Cloud

How the FDA interprets advertising and promotion in principle and in fact

If you go “off label” with advertising and promotion, FDA’s hammer can hit hard and seemingly out of the blue. Advertising and promotion for devices is weak and lacks legal clarity. For drugs, the regulations are prescriptive and guidance documents clamp down on nuances. Marketing and regulatory affairs departments must collaborate to avoid the hammer and penalties of FDA. The roadblock, however is that marketing managers and regulatory affairs managers rarely reach common ground and are loathe to even consult with each other.

FDA’s Center for Devices and Radiological Health (CDRH) has never issued a comprehensive guidance on advertising and promotion. You are on your own. In contrast, FDA’s Center for Drug Evaluation and Research (CDER) uses long-standing regulations and a growing number of guidance documents in its regulatory approach. Policing social media has become a new regulatory responsibility and FDA is still trying to figure out how to deal with it. Bottom line, do you know when you fail to meet FDA’s requirements or are you guessing? Can you afford to guess? The cost to your business and the confusion left in your customers’ mind becomes an unwelcomed nightmare.

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In this seminar, you will learn how to navigate FDA’s numerous legal options and how to interpret them based on basic legal principles. Applying new guidance documents becomes a new test of the FDA’s legal boundaries and enforcement options. The agency is now conducting clinical studies and applies the principles of cognitive psychology to aid in its determination of what a message really conveys. This academic discipline may or may not get to the root of what consumers take away as the message.

Congress and the new FDA Commissioner seem more sympathetic to expanding access to medical treatment before all the conclusive evidence for safety and effectiveness is evaluated by the FDA. Valid off-label information may take the lead in that direction.

This conference will provide insight on how to manage your marketing activity and gauge what regulatory risks your business is willing to accept. You will learn how corporate management requires cooperation between marketing, regulatory affairs, legal counsel, manufacturing, engineering and finance departments. Operating in a stovepipe environment will not work. You need to understand that a weak link in any department leaves the entire corporation vulnerable to FDA enforcement. Most importantly, you will understand the boundaries that FDA uses and how easy it is to cross them. With information from this course, you can step back and rationally evaluate your firm’s regulatory profile for advertising and promotion practices.

  • Sales and Marketing executives and managers
  • Regulatory Managers
  • In-house Legal Counsel and Contract Specialists
  • 3rd party consultants
  • Venture Capitalists
  • Investors
  • Business Acquisition Executives
  • Owners of New or Developing Firms
  • Own label distributors
  • International Trade Managers
  • Product specification developers

How easy it is to cross them

How to Prepare for FDA Submissions and Communicate Them With the FDA

A medical device company making a submission to the FDA on any of these: INDs, NDAs, BLAs, ANDAs, PMAs, 510(k)s, IDEs, and Post-Approval Supplements; needs practice and learning of all the intricate aspects of these activities. The FDA approval is necessary to start legal manufacturing a medical device or a combination product in the US. The FDA drug and device approval system is complex, and this understanding needs to be there on the part of the submitting company.

Of equal importance as the submission is how to communicate with the FDA about these at various stages before, during and after the submission. It calls for a thorough understanding of the regulations in all their detail. This complete understanding is necessary to sail through the filing process. Companies making the filing need to have an effective submission strategy, failing which they could invite enforcement actions from the FDA, not to speak of the waste of resources and time.

Complete learning all the aspects of FDA submission for medical devices and combination products

A two-day seminar from GlobalCompliancePanel, a leading provider of professional trainings for all the areas of regulatory compliance, will be offering complete and clear understanding of these aspects of an FDA submission. David Dills, Global Regulatory Affairs & Compliance Consultant and President, NovaQual, will be the Director at this seminar.

David provides global regulatory affairs, compliance and quality consultative services for early-stage and established Class I/II/III medical device, including combination products, In Vitro Diagnostics, nutraceuticals/supplements, cosmetics and biopharmaceutical manufacturers in multiple medical specialties and therapeutic areas on the global landscape, and has an accomplished record with more than 26 years of experience in the areas of Regulatory Affairs, Compliance and Quality Systems.

Understanding the regulatory requirements

David will explain all the details that need to go into an FDA submission to meet the regulatory requirements. FDA 510(k) submissions for obtaining FDA clearance, FDA Investigational Device Exemption (IDE) submissions for US clinical studies, FDA Requests for Classification and Requests for Determination, FDA Pre-Submission (Pre-sub) meetings, the PMA and its various submissions such as e.g. traditional, modular, streamlined, etc., the advantages and disadvantages of each, the Summary of Safety and Effectiveness Data (SSED) and the way in which to use it, determining when an IDE is required, and IDE, PMA and 510(k) submission management activities  are some of these.

This detailed session on FDA submissions and communicating with the FDA is of value to personnel in the pharmaceutical, biopharmaceutical, biologics and generic drug industry who are involved in preparing FDA submissions (INDs, NDAs, BLAs, ANDAs, post approval supplements). David has tailored the course content to suit the needs of those who interact with FDA staff, including Project Managers, Regulatory Affairs, Clinical, Nonclinical, Manufacturing, and Quality personnel.

Know more

 

 

200+ followers. WOWWWWWW…

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Hello Everyone,

Today we have the pleasure of celebrating the fact that we have reached the milestone of 200+ followers on WordPress. Since we started this blog, we have had such a great time connecting with everyone.  we never expected to actually to connect with other people in the blogging community.

we are so incredibly thankful for each and every one of you who follows and comments on my blog posts. Please know that!

we would continue our blogging in these areas FDA Regulation, Medical Devices, Drugs and Biologics, Healthcare Compliance, Biotechnology, Clinical Research, Laboratory Compliance, Quality Management ,HIPAA Compliance ,OSHA Compliance, Risk Management, Trade and Logistics Compliance ,Banking and Financial Services, Auditing/Accounting & Tax, Packaging and Labeling, SOX Compliance, Environmental Compliance, Microsoft Excel Spreadsheet, Geology and Mining, Human Resources Compliance, Food Safety Compliance and etc.

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The FDA Export Reform and Enhancement Act of 1996 – a brief understanding

The FDA Export Reform and Enhancement Act of 1996 - a brief understanding 3

The FDA Export Reform and Enhancement Act of 1996 is a landmark Act passed by the American Congress. A landmark legislation in that it instilled and reinforced the concept of free global trade; the FDA Export Reform and Enhancement Act of 1996 removed the need for American pharma companies to obtain FDA approvals for the products that they export to select markets. Following the passage of the FDA Export Reform and Enhancement Act, American companies need to only get approval of the respective countries regulatory authorities.

One of the highlights of the FDA Export Reform and Enhancement Act of 1996 is that it was one of the very few Acts that were put into effect almost immediately after being passed into law. This perhaps reflected the immediacy of the benefit the Act wanted to bestow on American companies.

The overriding highlight of this legislation is that it almost totally obviated the need for FDA approval for products that were being exported to a few select countries. American pharmaceutical companies saw this as a great concession that they got to export their products, as it completely helped them bypass the tedious FDA approval process.

The FDA Export Reform and Enhancement Act of 1996 allowed the following categories of non-FDA regulated products to be exported to any country of the world:

The Listed Countries

 

The FDA Export Reform and Enhancement Act of 1996 - a brief understanding 1Subject to marketing approval by the respective regulatory bodies of the 25 developed nations; American companies can market their products to what the FDA Export Reform and Enhancement Act of 1996 considers “Listed Countries”:

  • Australia
  • Canada
  • Israel
  • Japan
  • New Zealand
  • South Africa
  • Switzerland, and
  • The European Economic Area

Requirements of the FDA Export Reform and Enhancement Act of 1996The FDA Export Reform and Enhancement Act of 1996 prescribes vastly liberalized general requirements which pharma companies need to adhere to in order to be able to export non-FDA approved medical products to the Listed Countries. The following core components have been greatly relaxed or exempted for export approval:

Requirement from receiving countriesFinally, the FDA Export Reform and Enhancement Act of 1996, upon the insistence of the Listed Countries, ruled that manufacturers who wanted to benefit from this legislation had to obtain clearance from the FDA that there were no regulatory or legal actions pending on these companies.

 

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Effective Complaint Handling Guidelines serve as a basis for improvements in medical devices

Effective Complaint Handling Guidelines serve as a basis for improvements in medical devices1Far from being frowned upon, complaints should serve as an opportunity for medical device manufacturers to understand the customer’s expectations better and lead to improvements in the product quality.

The FDA describes a complaint as “any written, electronic, or oral communication that alleges deficiencies related to the identity, quality, durability, reliability, safety, effectiveness, or performance of a device after it is released for distribution”.

FDA’s complaint handling guidelines are critical for ensuring that an organization maintains safety with regard to the medical devices they manufacture. Errors in medical devices can result in complaints, and improper handling of complaints can lead to problems for the patient, ranging from injury to fatality.

It is to prevent these problems that the FDA has issued complaint handling guidelines. FDA’s thinking is based on the reasoning that a complaint may be an indicator of serious safety, but implementing effective complaint handling guidelines can greatly mollify the gravity of the issue. It is also the first step to initiating new product development, which in turn has the potential to greatly reduce risks associated with noncompliance.

Regulations in place

Provisions relating to effective complaint handling provisions are contained in FDA 21 CFR Part 820 and GxP regulations.

Firstly, these complaint handling guidelines require medical device manufacturers to maintain complaint files. Manufacturers have to make this the first step towards establishing a sustainable complaint management system.

Secondly, Section 198 of Part 820 warrants the following:

effectiveComplaintHandlingGuidelinesThirdly, FDA 21 CFR Part 820 requires the manufacturer to establish and maintain procedures for the receipt, review, and evaluation of complaints.

What should records of investigation contain?

Records of investigation should contain the following:

  • Identifiers related to the device and reported event
  • If Medical Device Reporting is made, it should investigate the following:
    • Whether there were any specifications the device failed to meet
    • Whether it was for treatment or for diagnosis that the device was being used
    • In what way the device was related to the reported event, if applicable

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Aspects of Regulatory History in the US

The beginnings of all that the USFDA regulates can be traced right to the early decades of the founding of the nation. In a sense, the FDA, even if came to be called by that formal name much later; embodies the discipline and value set that the new created nation sought to represent. Regulation of all aspects of American life was deeply ingrained very early in the nation’s history, and the FDA was one of prime institutions that played a part in making this happen.

How has the FDA evolved and shaped up over the years? What are the important milestones of this history? This makes interesting reading, because the USFDA has had the kind of history whose colorfulness is matched by few other regulatory agencies around the world.

aspectsOfRegulatoryHistoryAn indication of the extent to which the FDA attaches importance to ensuring the wellbeing of the American people can be gauged from the fact that the food and other products that this agency regulates account for a fifth of the total money that the nation’s consumers spend. Just its budget – well over four billion in 2014 – is a good indicator to the way in which the FDA has spread its influence in the various spheres of American life. It regulates almost all food items with the exception of meat and poultry.

This situation has not been reached accidentally or overnight. The FDA has by and large kept pace with the developments in the areas it regulates. This was largely true till the advent of very recent technology-led areas such as biotechnology and the social media, where too, the FDA has been trying to put its best foot forward.

The start of formal regulation 
aspectsOfRegulatoryHistoryA look at the history of the FDA points to the year 1848 as the start of the first formal aspects of regulatory history. That was the year in which Lewis Caleb Beck took his appointment with the Patent Office. His mandate was to chemically analyze agricultural products. This is considered as the first task that was aimed at regulating a product that people consumed. This function rolled over to the Department of Agriculture, which was created in 1862.

The Act of 1906The next step in solidifying the regulatory aspects of life in the US was taken in 1906, with the promulgation of the Pure Food and Drugs Act in 1906. Stretching to some two decades of wrangling between the American Congress and the food industry to formulate, the Act of 1906 sought to prohibit adulterated and misbranded food and drugs from interstate commerce.

The 1938 Food, Drug, and Cosmetic ActThe next major milestone in the aspects of regulatory history in the US took place in 1938. The 1938 Food, Drug, and Cosmetic Act prescribed and detailed the legal requirements for products the FDA – which this Act created – regulated. In this Act, one can trace the earliest tidings of a major activity that the FDA has been carrying out since then: Prescribing the requirements for ensuring quality by prohibiting false claims by manufacturers and advertisers.

aspectsOfRegulatoryHistoryPresident Franklin D. Roosevelt signing the 1938 Food, Drug, and Cosmetic Act.

Over time, the 1938 Act expanded to include more areas such as cosmetics, devices and veterinary medicines, thus strengthening the foundation for regulation and making it more expansive. Since the passage of the 1938 Food, Drug, and Cosmetic Act; two major events happened on the regulatory scene. The outbreak of tetanus and diphtheria diseases in the 1960’s compelled the FDA to take a more proactive approach to vaccinations.

Another major, earthshaking event was the tragedy that thalidomide unleashed on Europe in the 1960’s, which stunted the growth of hundreds of children, which was mainly due to regulatory lapse. This did not happen in the US, mainly because of the efforts and diligence shown by Frances Kelsey, in her role as FDA reviewer. Frances plainly refused to approve thalidomide because she was not convinced about its safety, an act which made her a cult figure in FDA and American and Canadian medicinal history till her death in 2015.

aspectsOfRegulatoryHistory

Aspects of regulatory history in the US in the 1990’sFollowing the 1960’s, the next major milestone in the aspects of regulatory history in the US happened in 1990, when the Nutrition Labeling and Education Act was passed. This law was important because it changed the American perspective of labeling of products in the food and pharmaceutical industries. The Nutrition Labeling and Education Act requires manufacturers to provide nutritional information about products on their labels, with the caveat that false labeling information will lead to consequences.

 

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