Understanding the FDA’s GMP Expectations for Phase I and First-in-Man Clinical Trials

The establishment of the initial safety of a drug is the primary reason for which early clinical trials are conducted. Phase I of drug development consists of:

o  Research and drug discovery

o  Preclinical development, of which initial IND, or first in humans (also called first in man), is part

o  Clinical development, which consists of Phase I, Phase 2 and Phase 3 clinical pharmacology studies

Phase I studies are designed mainly for investigating the following qualities of an investigational drug in humans:

o  The extent to which it is safe and tolerable: (if possible, identify its Maximum Tolerated Dose (MTD)

o  Pharmacokinetics

o  Pharmacodynamics of an investigational drug in humans.

The ultimate goal of these Phase I and later studies is to ensure that the right drug is given to the right patient in the right dose, at the right time. These clinical studies are carried out to determine which dose or dosing regimen of the target drug achieves all its objectives for all the populations groups for which it is being developed.

Rationale for a small sample

Generally, these studies are carried out on a small sample of subjects of normal health. These early clinical trials normally use lower doses of the drug product. On account of this, the organization or laboratory carrying out these early stage clinical studies uses only small amounts of investigational material.

This is because of two reasons: The small sample is chosen in such a fashion that it is a representation of the whole study in relation to various parameters, and two, choosing a small sample substantially reduces the costs associated with a largescale study. It also reduces the regulatory burden during these early stages. Keeping in mind these factors, the FDA has established guidelines by which early stage investigational products can be allowed to be manufactured under less stringent GMPs.

Not meeting regulatory requirements makes the exercise futile

Without an understanding of the FDA’s guidelines for these GMPs, the whole exercise of early or Phase I studies becomes wasteful and meaningless. All along, the FDA’s guidelines have to be consistently and accurately adhered to in order to meet compliance requirements, without which the clinical trial and its results do not get approved.

What are the steps that a clinical or pharmaceutical organization need to take in order to ensure that these GMPs for Phase I clinical trials are being met? All the aspects of this topic will be covered in depth over two days of intense learning that will be imparted at a seminar from GlobalCompliancePanel, a leading provider of professional trainings for the areas of regulatory compliance.

Peggy Berry, the President and CEO at Synergy Consulting where she provides consulting services to companies in all aspects of drug development, will be the Director of this seminar. All that is needed to gain from the rich wealth of Peggy’s experience is to register for this seminar by logging on to Good Manufacturing Practices . This course has been pre-approved by RAPS as eligible for up to 12 credits towards a participant’s RAC recertification upon full completion.

A complete explanation of the FDA’s GMP requirements

This seminar is being organized to help participants gain an understanding of the requirements for advancing drugs from research into early clinical development and the minimum FDA requirements for Phase I GMPs. She will help them learn practical applications for implementing Phase I manufacturing strategies to meet FDA requirements.

Towards this end, Peggy will discuss these topics to lay the foundation and basis for advancing drugs into clinical development from research and providing required information to the FDA regarding these products on Day 1:

o  Moving a Product out of R&D

o  CMC Requirements for an IND Study

o  Good Manufacturing Practices: Basics for Beginners

o  Raw Material Management

Taking off from these topics, Peggy will focus on the topics relating to the requirements for early stage products of different types and for vendor selection and management on Day 2, which include:

o  GMPs for Phase I IND products

o  GMPs for Combination Products and 505(b)(2) Products

o  Process Validation for Early Stage GMP

o  Outsourcing Early Stage Manufacturing.

Technical training in the life sciences

It is accepted that Training and Development is a highly developed area that bring its own body of knowledge. It uses a wide variety of techniques and approaches that are designed to meet the unique and complex challenges associated with training. Training and development is a great tool for helping a professional or a lay person alike understand the tenets of their profession.

In the absence of the right professional training and development, many employees place themselves at a disadvantage vis-à-vis their colleagues. They need to keep upgrading their knowledge and skills and keep closing the gaps, so that they do not get left out in their career. Training and development also helps employees understand how they need to meet the regulatory requirements the organization is required to comply with.

Difficulties associated with training and development in the life sciences

While this is accepted, a great deal of attention is yet to be paid to the need for technical training in the area of life sciences. Applying technical Training & Development skills to the field of life sciences is very crucial, as it helps professionals in that important area take a fresh perspective of the regulations in the areas of life sciences and benefit from them.

Technical training in the life sciences applications is fraught with a few problems. This is because two important factors come into play: The activities involved in the life sciences, such as formulating Standard Operating Procedures (SOPs), work instructions, the ways of carrying out tests and clinical trials, and the exact science behind the topics in this subject are all very complex. Secondly, regulations are equally difficult to understand and implement. This however, is no excuse to skip their implementation, something that is unthinkable for this industry.

A thorough learning session on technical training for the life sciences

It is to help professionals in the life sciences become more familiar with training and development, and to ease the complexity of their training needs that GlobalCompliancePanel, a leading provider of professional trainings for all the areas of regulatory compliance, will be organizing a two-day seminar.

Charles H. Paul, who is the President of C. H. Paul Consulting, Inc., a regulatory, manufacturing, training, and technical documentation consulting firm that is celebrating its twentieth year of existence in 2017, will be the Director. To understand the importance of technical trainings for the life sciences and to get to know how to implement legally compliant life sciences training programs for your organization, please enroll for this seminar by visiting http://www.globalcompliancepanel.com/control/globalseminars/~product_id=900920SEMINAR?wordpress-SEO. This course has been pre-approved by RAPS as eligible for up to 12 credits towards a participant’s RAC recertification upon full completion.

Arousing the interest in training for the life sciences

The purpose of this seminar is to help kick start the training and learning needs of talented and technically competent training professionals who may need more focused instruction and direction in the area of technical training in the Life Sciences. Charles will offer guidance to all training professionals at all skill levels in how to truly build and sustain a training organization in today’s difficult corporate environment, and how to effectively identify gaps in workforce training and compliance documentation and build effective and inexpensive training materials with the tools that are available.

A very important benefit participants of this seminar will take away from here is that they will learn how to integrate Training & Development with compliance, so that they can leverage the benefits of compliance to improve the performance of the workforce and the overall performance of technical operations.

Important personnel in the life sciences industries that are associated with training, such as Directors of Training, Training Supervisors, Training Coordinators, Training Developers, Instructional Designers and Instructors will derive high benefits from this seminar. Over the two days, Charles will cover the following:

o  Introduction to Training and Development in the Life Sciences and the Relationship between Training and Regulatory Compliance

o  Training and Development Basics

o  The Building Blocks of Human Performance

o  Building a Training and Development Organization – Leverage what you have and Negotiate for What You Don’t

o  Perform a Documentation and Training Analysis – Discover the Gaps

o  Training Materials – SOPs and Work Instructions as Training Materials – It’s not as easy as you think! Leverage the Opportunity!

o  Working with Subject Matter Experts and Outside Consultants

o  Case Study Review and Discussion – This Approach Works!

Wrong hiring and ways of avoiding it

A perfect hire is a boon to any organization. At the other extreme, a bad hire can bring the inverse result to the organization: It can not only impede productivity; it can even result in drawing the organization into legal issues associated with wrong hiring. Problem employees create employee problems, which is why HR professionals need to be aware of what steps to take and what scenarios to avoid if they have to take hiring decisions that are legally defensible. A hire that is weak from the legal perspective is the stepping stone for troubles for the organization.

As if the legal troubles of wrong hiring are not enough; organizations have to also deal with the financial burden it brings. Many organizations have realized that in the absence of the right precautions, there is a near certainty that could end up hiring someone with a wrong background.

Facing embarrassing lawsuits

If an organization’s HR overlooks areas such as the candidate’s criminal record, or fails to take note of a falsified background, all that it is going to see is workplace violence, not to speak of lawsuits for negligent hiring and all the loss of time spent on finding the unsuited person.

Employers have to also face the prospect of inviting lawsuits for initiating screening methods that either violate the law or fail to take into account the changes in civil rights legislation and the new EEOC Guidance on the use of criminal records. This makes the screening process more complex than it ever was. It adds a new layer of woes for the organization, which has to bear the brunt of a wrong decision in hiring.

Get to understand all the aspects of legally compliant hiring practices

The way out is to gain familiarity with legally compliant best practices. This is the only truly proven antidote to not only keep the business productive; but to also make sure the organization will not be taken to court. Want to explore the ways of putting legally compliant hiring practices in place? Then, you need to enroll for a highly engaging and valuable two-day seminar from GlobalCompliancePanel, a leading provider of professional trainings for the areas of regulatory compliance.

At this seminar, Lester S. Rosen, who is CEO and Attorney at Law at Employment Screening Resources, a national background screening company accredited by the National Association of Professional Background Screeners (NAPBS), will be the Director. To gain the benefit of the rich experience Lester brings into hiring best practices, please register for this seminar by visiting Wrong hiring and ways of avoiding it .

Touching upon all aspects of legally safe hiring and background checks

Over these two days, which will see a high level of interactivity, Lester will equip the participants with cutting edge tools, the latest legal developments and practical advice on the challenges of recruiting, background screening and hiring the best people for their organization. All those related to hiring practices, such as Human Resources professionals, Employers, Business Owners, Hiring Managers, Staffing Directors, Risk Management and Security Processionals, Staffing Professionals, Recruiters, and Background Screening Professionals will gain immensely from this session.

This seminar will help participants with the ways of obtaining and utilizing criminal records and background information on job applicants. The Director will update them on recent legal developments, and describe a few case studies which will help them understand the steps employers should take and the mistakes they should avoid. He will also familiarize them with the critical issues relating to hiring, such as the use of social networking sites, new technology and the EEOC approach to the use of criminal records and credit reports. Also taken up for discussion is the topic of why class action lawsuits are rising exponentially against employers and how to effectively comply with the federal Fair Credit Reporting Act (FCRA), as well as the many state laws that are in place for regulating background checks.

The Director will help participants understand with the immediate steps they can take to avoid a bad hire by putting in place a screening policy that withstands legal scrutiny. He will also traverse a variety of topics related to background checks such as:

o  The process employers should use in hiring to minimize the chance of a bad hire

o  The ways of adapting a background screening system

o  The ways of selecting the rightly suited screening partner

o  The most judicious ways of using social media, international background checks and drug testing.

Validation in accordance with ICH guidelines

Chemical

Professionals in the field of statistical analysis need a clear and perceptive insight into how to understand and interpret statistical concepts used to investigate quantitative ICH Guidelines such as analytical methods validation, procedures and acceptance criteria in calibration limits. Along with these, process and quality controls, as well as ICH Q8 and Q9 also need to be properly and thoroughly understood.

The ICH tripartite-harmonized ICH Guideline on Text, which was previously coded as Q2A, finalized in October 1994 under Step 4, is the guideline the ICH has set out for analytical methods validation. The aim of this guideline is to identify the validation parameters that are required for a number of analytical methods. This guideline also lays down the characteristics and parameters that need to be taken into consideration when validating the analytical procedures that are included in the registration applications.

Likewise, the ICH tripartite-harmonized ICH Guideline on Methodology, which used to be previously coded as Q2B, finalized in November 1996 under Step 4, is the ICH guideline on procedures and acceptance criteria in calibration limits. This guideline extends the ICH guideline on Text, or what is called Q2A (mentioned above) to comprise the actual experimental data required, along with the statistical interpretation, for the validation of a variety of analytical procedures.

Current Step 4 for process and Quality Control

For process and Quality Control, the extant guideline is the Current Step 4 version of the ICH-harmonized Tripartite Guideline. The final draft of this guideline has been recommended for adoption to the regulatory bodies of the three biggest pharmaceutical markets in the world, namely the US, the EU and Japan.

In order to achieve harmonization in Quality, professionals have to meet critical milestones. These include conducting stability studies, the way the studies define relevant limits for the testing of impurities, and following a more malleable approach to pharmaceutical quality that is based on the principles of Good Manufacturing Practice (GMP) risk management. ICH’s Quality guidelines on harmonization relating to Quality cover the following areas:

Get professionally trained on the areas of Validation in accordance with ICH guidelines

Considering the complexity and the breadth of the issues associated with these techniques, which cover both the pharmaceutical and clinical applications, and considering that these techniques apply to a number of area such as stability testing, outlier analysis and risk management; it is necessary and important to undergo professional trainings with which professionals in these areas can clarify a number of doubts.

This is the learning a two-day seminar from GlobalCompliancePanel, a leading provider of professional trainings for the areas of regulatory compliance, will be imparting. This training will be led by Dr. Alfred Bartolucci, who serves as Emeritus Professor of Biostatistics at the University of Alabama. To enroll for this seminar, please register by logging on to Validation in accordance with ICH guidelines . This seminar has been pre-approved by RAPS as eligible for up to 12 credits towards a participant’s RAC recertification upon full completion.

A clear and deep understanding of statistical concepts

Depth and clarity of understanding of the statistical concepts used for investigating quantitative ICH Guidelines such as analytical methods validation, procedures and acceptance criteria in calibration limits, and process and Quality Control, along with ICH Q8 and Q9 will be the main thrust of this seminar.

This seminar is not a course in statistics, but offers an introduction to an applied approach to the statistical techniques used, and how to reasonably interpret them. This learning will help participants address the various challenges facing pharmaceutical and biotechnology companies when they have to quantify results in a meaningful interpretable manner through tabulations and graphical presentations.

In addition, Dr. Bartolucci will also focus on another important area: What the different regulatory agencies expect of the quantification and development of a sound statistical monitoring of a properly utilized, effective, and efficient process control. He will familiarize the participants with the critical aspects of the statistical methods and explain to them the practical application of these guidelines.

 

The ingredients of a truly effective internal audit program

 

AFirst Sliden internal audit program of an organization’s Quality Management Systems is a core requirement from both the ISO and the FDA. At its barest, an internal audit system can be understood to be an assessment or inspection of an organization’s Quality System. Audits are a very beneficial and positive tool for continually ensuring that an organization’s internal management systems are up to the mark and keep meeting regulatory requirements on a consistent basis.

An internal audit program is the most effective and useful tool in helping an organization discover its loopholes and deficiencies in the Quality System, which is absolutely essential to help it pass regulatory hurdles. The purposes of an internal audit, as set out by ISO 9001, which describes Quality Management Systems audits, are to ensure that:

  • The Quality Systems of the organization comply with the requirements of ISO 9001 and its latest versions
  • They show compliance with the requirements of other regulatory bodies such as the FDA
  • They comply with the quality requirements the organization has
  • The organization makes effective implementation and maintenance of the QMS.

ISO 9001 does not require the internal audit procedure to be fully documented. An organization has to only, to use the ISO’s own words, “maintain an audit program” and retain the documents relating to the audit and its results and information contained in them.

Multifold benefits of auditing

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Auditing, both external and internal, bring many benefits. Besides meeting the purposes as set out by ISO 9001 and others such as the FDA; auditing helps organizations:

  • Identify the areas in which they need to make improvements
  • Apply best practice relevant to the particular industry
  • Take preventive actions that could nip potential problems in the bud
  • Ensure greater customer satisfaction.

Compliance with audit requirements is considered drudgery

Despite the noble intentions behind internal and external audits; three fourths of organizations consider audits as being very cumbersome, unpleasant and baneful. Most of them carry out audits with no conviction. They carry them out only because they have no other choice. Most businesses fail to see the value behind the efforts needed for carrying out audits that meet regulatory requirements.

Carrying out audits without any sense of purpose results in more drudgery and unpleasantness. The result of carrying out audits for the sake of it, rather than with purpose is there to see: More Warning Letters, 483’s, penalties and other actions such as even Consent Decree, from the FDA.

Learn to carry out effective audits more willingly and effectively

The ways by which organizations can overcome the mental barrier to carrying out audits and put in place a well-planned, compliant audit program that reduces the risk of noncompliance will be the teaching a two-day seminar from GlobalCompliancePanel, a leading provider of professional trainings for the regulated industries, will be offering.

Susanne Manz, Quality and Compliance Expert/Auditor for Medical Devices, Manz Consulting, Inc., who is an accomplished leader in the medical device industry with emphasis on quality, compliance, and Six Sigma, will be the Director of this seminar. To enroll for this webinar and gain complete understanding of the means for planning and implementing a Quality Systems audit that meets regulatory requirements,

Please register by logging on to http://www.globalcompliancepanel.com/control/globalseminars/~product_id=900854SEMINAR?wordpress_SEO. This seminar has been pre-approved by RAPS as eligible for up to 12 credits towards a participant’s RAC recertification upon full completion.

A complete understanding of the rationale and ways of carrying out compliant audits

This seminar will be highly useful in helping audit professionals in organizations devise an effective audit program with is compliant. It will put participants on the path to a thorough quality audit program that meets regulatory requirements. Such a well devised quality audit program is a powerful tool in helping organizations to understand, reduce and communicate risks relating to quality and compliance.

Susanne will open the participants’ minds to continuous improvement, which starts with the awareness of issues and opportunities. The absence of an effective audit program deprives management of an understanding of the issues within their Quality System. As a result, management is oblivious to the lacunae in the Quality System and the risk bring for the organization. Such a situation denies the management the opportunity to assess the impact a faulty Quality Management System audit has on product quality and the risk it poses to the customer. Susanne will draw participants’ attention and focus on the red-flags and explain to them the ways by which they can reduce compliance and quality risk.

This seminar will consist primarily of lectures, interactive discussions and practical exercises. Susanne will equip the participants with the tools and techniques they need for ensuring compliance of their Quality Systems audits. They will walk away with an understanding of the key concepts and their practices, along with the ways of implementing them and use them as reference for future use

 

FDA requirements on data integrity and its implementation

The phrase “data integrity” seems to be everywhere. It is used in a number of places and situations, and the FDA has its own definition of the term. At its plainest, data integrity is defined as the assurance that data is complete, consistent and accurate. FDA requires this data to be attributable, legible, contemporaneously recorded, to be an original or a true copy, and to be accurate. This criterion is embodied in the acronym ALCOA.

Is just an understanding of this definition sufficient? In order to understand data integrity from the computerized systems point of view; one has to apply 21 CFR Part 11 and Annex 11 to data. Its implementation is considered difficult for a number of reasons. To apply data integrity to computer systems, one needs to understand the concept of data integrity.

Understanding is necessary in view of the FDA’s stepped up inspections

It is only this basic understanding that will help to determine what needs to be done to meet national and global data integrity requirements. This is all the more important in view of the fact that regulatory agencies such as the FDA have accelerated inspections related to data integrity, as a result of which there has been a big rise in the number of citations relating to data integrity.

When it comes to data integrity for computerized systems, the requirements set out in 21 CFR Part 11 and Annex 11 need to be kept in mind from the following perspectives:

o  The background to and the way in which 21 CFR Part 11 and Annex 11 have evolved and why they are being talked about all over again

o  An understanding of the full overview of Part 11 and Annex 11 and their key requirements

o  Clear understanding of how the use of Risk Based Assessment will not only achieve data integrity and compliance but also bring down work considerably

o  The FDA’s and other regulatory authorities’ method of inspecting computerized systems for data integrity.

A complete two-day exploration of data integrity from the FDA’s perspective

It is to familiarize IT professionals and professionals who work on data integrity that GlobalCompliancePanel, a leading provider of professional trainings for the areas of regulatory compliance will be organizing a two-day seminar.

The Director of this seminar is Angela Bazigos, who is CEO of Touchstone Technologies Silicon Valley. Angela brings over 40 years in the healthcare and life sciences industries. To gain the benefit of Angela’s experience in the industry and to discover ways of ensuring data integrity in the computer systems of a number of healthcare and life sciences disciplines, please register for this seminar by visiting http://www.globalcompliancepanel.com/control/globalseminars/~product_id=900946SEMINAR?wordpress_SEO . This course has been pre-approved by RAPS as eligible for up to 12 credits towards a participant’s RAC recertification upon full completion.

Practical understanding of data integrity

This seminar is very hands-on and is meant to offer guidance on how to ensure data integrity in highly regulated industries. It is of relevance and importance to both beginners and experienced professionals alike. She will offer a completely detailed experience of validation and 21 CFR Part 11 compliance that a computer system needs to have.

One of the major takeaways of this seminar is the templates Angela will give to participants, which will help them build a full package for meeting data integrity for computerized systems. She will also detail the activities associated with Computer Systems Validation, exploring areas such as:

o  What is Data Integrity and how is it implemented

o  How to use Risk Based Assessments to reduce work while still achieving Data Integrity and Compliance?

o  Data Integrity Frequently Asked Questions

o  Validation Master Plan

o  Risk Based Assessment

o  Complete Validation for a System (software development lifecycle)

o  Automated Test Tools

o  Infrastructure Requirements

o  Change Control

o  SOPs.

https://www.fda.gov/downloads/drugs/guidances/ucm495891.pdf

Article on “A Tour of the FDA”

A tour of the FDA is something like a snapshot of what the FDA does. The importance of the FDA can never be understated: It regulates products from the proverbial pin to airplane in the food, medical devices, pharma and healthcare industries, which touch almost every aspect of American lives. The products that the FDA regulates account for about a trillion dollars, which make up about a quarter of all goods traded in the US.

So, what is a tour of the FDA like?

A tour of the FDA helps to get a broad understanding of the this regulatory body and get some idea of the various departments it has, as well as the functions of these departments. To get an understanding of what the FDA does, a reference to its mission statement could give some direction:

“(The) FDA is responsible for protecting the public health by assuring the safety, efficacy and security of human and veterinary drugs, biological products, medical devices, our nation’s food supply, cosmetics, and products that emit radiation.” This is just the opening line of the FDA’s mission statement. Reference to its other statements, which have now included a reference to containing terrorism, will serve as a good guide to a tour of the FDA. In short, the FDA regulates nearly every item used and consumed by the American public.

The history of the FDA

The legal sanction for carrying out its mission is mandated by the Federal Food, Drug and Cosmetic Act (FD&C Act). An amazing fact that a tour of the FDA reveals is that it is one of the oldest regulatory bodies in the world, with its earliest jurisdiction having covered regulation of drugs in the year 1848. The Department of Agriculture, to which President James Polk appointed noted chemist Charles Wetherill, can be considered the earliest endeavor to regulate medical products of daily use in the US.

How is the FDA organized?

A tour of the FDA is incomplete without a reference to the way it is organized. Its structure consists of this hierarchy:

  • Office of the Commissioner
  • Office of Foods and Veterinary Medicine
  • Office of Global Regulatory Operations and Policy
  • Office of Medical Products and Tobacco
  • Office of Operations

Under these broad heads, a tour of the FDA shows the way into which it is divided into several offices and organizations. Important among these include:

  • Office of Regulatory Affairs (ORA)
  • Center for Food Safety and Applied Nutrition (CFSAN)
  • Center for Drug Evaluation and Research (CDER)
  • Center for Biologics Evaluation and Research (CBER)
  • Center for Devices and Radiological Health (CDRH)
  • Center for Devices and Radiological Health (CDRH)
  • National Center for Toxicological Research (NCTR)

Want to know more: Article on “A Tour of the FDA”