This document provides guidance on how to prepare for and survive a FDA inspection of a clinical trial site. It discusses the different types of inspections, including routine inspections triggered by an application submission and for-cause inspections due to complaints. When receiving notice of an inspection, key steps are to obtain inspection details, notify relevant parties, and prepare documents and staff. During the inspection, FDA inspectors will verify protocol adherence and delegation of duties. Answering questions honestly and avoiding speculation are important.
In this presentation from Validation Week Europe, Karen Ginsbury discusses the rigors, preparations, strategies, and the do's and the don't of the FDA Inspection process.
How to prepare and handle a FDA Inspection. When the FDA conducts an audit of your company, you need to be prepared. This presentation shows you what to do when your are faced with a FDA Inspection. For more information go to http://compliance-insight.com/fda-483-warning-letters/fda-483-inspection/
This presentation is aimed at providing information on automation in the GLP practices in the pharmaceutical industry.
-Standard Operating Procedures.
-Documentation in GALP.
-Logs and Related Forms.
Preparing For An FDA Inspection - Employee Reviewguest22cdb3
An employee review training session adapted from presentations by former Food and Drug Administration investigators. The presentation includes a team competition based on a popular game show.
In this presentation from Validation Week Europe, Karen Ginsbury discusses the rigors, preparations, strategies, and the do's and the don't of the FDA Inspection process.
How to prepare and handle a FDA Inspection. When the FDA conducts an audit of your company, you need to be prepared. This presentation shows you what to do when your are faced with a FDA Inspection. For more information go to http://compliance-insight.com/fda-483-warning-letters/fda-483-inspection/
This presentation is aimed at providing information on automation in the GLP practices in the pharmaceutical industry.
-Standard Operating Procedures.
-Documentation in GALP.
-Logs and Related Forms.
Preparing For An FDA Inspection - Employee Reviewguest22cdb3
An employee review training session adapted from presentations by former Food and Drug Administration investigators. The presentation includes a team competition based on a popular game show.
Product lifecycle management: process of managing the entire lifecycle of a product from its conception, through design and manufacture, to service and disposal.
How to Prepare for an FDA Inspection and Respond to FDA 483's / Warning LettersGreenlight Guru
How long has it been since your last FDA inspection?
You know FDA is technically mandated to inspect any company with class II or class III products every two years (and inspections have been on the rise particularly for foreign / outside the US firms).
If FDA called tomorrow to announce their plans to visit your facility next week would you be prepared?
Even the most prepared companies still often find themselves receiving 483 observations.
Then you must act swiftly and effectively to avoid that observation escalating to a warning letter.
But what exactly do you do?
How do you respond to FDA 483 observations and/or warning letters?
greenlight.guru founder and VP QA/RA, Jon Speer, has been through his fair share of FDA inspections over the course of his 17+ year career in the medical device industry and has helped many of companies respond to 483 observations and warning letters along the way.
In this free, 60 minutes webinar, Jon will be sharing his most effective tips on how to avoid 483’s and warning letters in the first place along with a step-by-step guide to responding the them if you do happen to receive either.
(You can view the full webinar here: http://www.greenlight.guru/webinar/fda-483-warning-letter-response)
Specifically you'll learn:
What you should be doing to always be prepared for an FDA inspection
How to help prep your team before an FDA inspection
The top 7 reasons FDA issued medical device companies 483 observations and warning letters in FY2015
Tips you can implement today to mitigate your risk of getting 483’s and warning letters
What you need to do before responding to a 483 to minimize the damage (and avoid the common pitfalls)
Best practices for responding to FDA 483 and warning letter (including a free response template)
The differences in responding to a 483 observation vs. a warning letter
What to expect from FDA after submitting your response
A guide for how to survive a FDA Warning letter. So you got at FDA 483 and now you have a FDA Warning Letter, learn how to survive the storm. For more information go to http://compliance-insight.com/fda-483-warning-letters/
FDA WARNING LETTER IS A OFFICIAL LETTER FROM USFDA TO A MANUFACTURING FIRM TO NOTICE THE SERIOUS VIOLATION FOUND AT THE FDA INSPECTION AT FIRM AND THE CORRECTIVE ACTION SHOULD TO TAKEN BY FIRM TO OVERCOME THE VIOLATION FOR FDA APPROVAL
Presentation at ACI Conference on FDA Enforcement, covered:
Warning Letters, FDA Case Referral Process/Role of DOJ and U.S. Attorney, Coordination with States, Collateral Consequences of FDA Enforcement Actions
CFTCC
2015 Learning about the IND/IDE Process and Reimbursements for New Drugs and Devices
Erika Segear Johnson, PhD, RAC
Regulatory Affairs Scientist
Duke Translational Medicine Institute
Introduces the basics of filing an Investigational Device Exeption (IDE) Application with the FDA
Product lifecycle management: process of managing the entire lifecycle of a product from its conception, through design and manufacture, to service and disposal.
How to Prepare for an FDA Inspection and Respond to FDA 483's / Warning LettersGreenlight Guru
How long has it been since your last FDA inspection?
You know FDA is technically mandated to inspect any company with class II or class III products every two years (and inspections have been on the rise particularly for foreign / outside the US firms).
If FDA called tomorrow to announce their plans to visit your facility next week would you be prepared?
Even the most prepared companies still often find themselves receiving 483 observations.
Then you must act swiftly and effectively to avoid that observation escalating to a warning letter.
But what exactly do you do?
How do you respond to FDA 483 observations and/or warning letters?
greenlight.guru founder and VP QA/RA, Jon Speer, has been through his fair share of FDA inspections over the course of his 17+ year career in the medical device industry and has helped many of companies respond to 483 observations and warning letters along the way.
In this free, 60 minutes webinar, Jon will be sharing his most effective tips on how to avoid 483’s and warning letters in the first place along with a step-by-step guide to responding the them if you do happen to receive either.
(You can view the full webinar here: http://www.greenlight.guru/webinar/fda-483-warning-letter-response)
Specifically you'll learn:
What you should be doing to always be prepared for an FDA inspection
How to help prep your team before an FDA inspection
The top 7 reasons FDA issued medical device companies 483 observations and warning letters in FY2015
Tips you can implement today to mitigate your risk of getting 483’s and warning letters
What you need to do before responding to a 483 to minimize the damage (and avoid the common pitfalls)
Best practices for responding to FDA 483 and warning letter (including a free response template)
The differences in responding to a 483 observation vs. a warning letter
What to expect from FDA after submitting your response
A guide for how to survive a FDA Warning letter. So you got at FDA 483 and now you have a FDA Warning Letter, learn how to survive the storm. For more information go to http://compliance-insight.com/fda-483-warning-letters/
FDA WARNING LETTER IS A OFFICIAL LETTER FROM USFDA TO A MANUFACTURING FIRM TO NOTICE THE SERIOUS VIOLATION FOUND AT THE FDA INSPECTION AT FIRM AND THE CORRECTIVE ACTION SHOULD TO TAKEN BY FIRM TO OVERCOME THE VIOLATION FOR FDA APPROVAL
Presentation at ACI Conference on FDA Enforcement, covered:
Warning Letters, FDA Case Referral Process/Role of DOJ and U.S. Attorney, Coordination with States, Collateral Consequences of FDA Enforcement Actions
CFTCC
2015 Learning about the IND/IDE Process and Reimbursements for New Drugs and Devices
Erika Segear Johnson, PhD, RAC
Regulatory Affairs Scientist
Duke Translational Medicine Institute
Introduces the basics of filing an Investigational Device Exeption (IDE) Application with the FDA
Regulations in clinical research: obligations and responsibilities of investi...TrialJoin
Two of the most important individuals in a clinical trial are investigators and sponsors. However, being such a crucial part of a trial also brings many obligations and responsibilities. Although the sponsor is the one who initiates and finances a trial, the investigator is the person who conducts it. For this reason, most of the obligations and responsibilities fall on the investigator as the person accountable for everything that goes wrong in a trial. Learning these obligations and knowing how to follow them is a crucial practice that will ensure compliance in a clinical trial.
For this reason, we’ve decided to compose this material that will give you a basic outline of all the rules and regulations that investigators and sponsors should follow.
Regulations in Clinical Research: Obligations and Responsibilities of Investi...Anand Butani
Two of the most important individuals in a clinical trial are investigators and sponsors. However, being such a crucial part of a trial also brings many obligations and responsibilities. Although the sponsor is the one who initiates and finances a trial, the investigator is the person who conducts it. For this reason, most of the obligations and responsibilities fall on the investigator as the person accountable for everything that goes wrong in a trial. Learning these obligations and knowing how to follow them is a crucial practice that will ensure compliance in a clinical trial.
For this reason, we’ve decided to compose this material that will give you a basic outline of all the rules and regulations that investigators and sponsors should follow.
Writing Regulatory Documents for Drug Approval: The Importance of Accuracy an...ClinosolIndia
Writing regulatory documents for drug approval is a critical process that requires utmost accuracy and clarity. These documents play a vital role in demonstrating the safety, efficacy, and quality of a drug to regulatory authorities such as the Food and Drug Administration (FDA) in the United States or the European Medicines Agency (EMA) in the European Union.
Overview of FDA requirements for clinical studies as well as privacy issues, including impact of HIPAA; plus practical considerations in developing clinical studies.
What do you need to know before and while working on a clinical trial? This slide deck tells you more about the things you need to remember when preparing to publish your clinical trial, from developing a research protocol and getting informed consent from study participants to registering your trial and preparing a clinical trial manuscript.
presentation of sampling , testing ,release and rejection of Raw materialsshaik malangsha
I hope this ppt would be help to improve & make aware about better sampling , testing ,release and rejection of Raw materials . I believe if once ill go through this ppt it ill defiantly help to improve our RM procedure. If any clarifications pls. mail me at shkrahul42@gmail.com
I am uploading this GMP presentation to make aware who are working in pharma and help to maintain high standards in products manufacturing .
GMP Vs cGMP: It is my understanding that , Ultimately GMP & cGMP both the aim is same, means to prevention of the product from bad quality entering the market to endover peoples's life.
GMP applies to pharmaceutical and healthcare products and help to maintain high standards in these products.
cGMP is to remind accepting countries that all guidelines must be followed with latest and current production processes i.e employ technologies and systems which are up-to-date in order to comply with the regulation.
FDA (Food and Drug Administration) included the word “current” to ensure that regulated firms use the most current Good Manufacturing Practices (I believe that some firms would actually use outdated versions of the GMP’s to manufacture regulated products.
(the FDA have made their standards immediately identifiable i.e cGMP; Other international bodies such as the ICH, WHO use the term GMP, as do Canada, Japan and the EMEA (European authority). In FDA view cGMP means following 21 CFR 210 and 211 and no other.)
New Directions in Targeted Therapeutic Approaches for Older Adults With Mantl...i3 Health
i3 Health is pleased to make the speaker slides from this activity available for use as a non-accredited self-study or teaching resource.
This slide deck presented by Dr. Kami Maddocks, Professor-Clinical in the Division of Hematology and
Associate Division Director for Ambulatory Operations
The Ohio State University Comprehensive Cancer Center, will provide insight into new directions in targeted therapeutic approaches for older adults with mantle cell lymphoma.
STATEMENT OF NEED
Mantle cell lymphoma (MCL) is a rare, aggressive B-cell non-Hodgkin lymphoma (NHL) accounting for 5% to 7% of all lymphomas. Its prognosis ranges from indolent disease that does not require treatment for years to very aggressive disease, which is associated with poor survival (Silkenstedt et al, 2021). Typically, MCL is diagnosed at advanced stage and in older patients who cannot tolerate intensive therapy (NCCN, 2022). Although recent advances have slightly increased remission rates, recurrence and relapse remain very common, leading to a median overall survival between 3 and 6 years (LLS, 2021). Though there are several effective options, progress is still needed towards establishing an accepted frontline approach for MCL (Castellino et al, 2022). Treatment selection and management of MCL are complicated by the heterogeneity of prognosis, advanced age and comorbidities of patients, and lack of an established standard approach for treatment, making it vital that clinicians be familiar with the latest research and advances in this area. In this activity chaired by Michael Wang, MD, Professor in the Department of Lymphoma & Myeloma at MD Anderson Cancer Center, expert faculty will discuss prognostic factors informing treatment, the promising results of recent trials in new therapeutic approaches, and the implications of treatment resistance in therapeutic selection for MCL.
Target Audience
Hematology/oncology fellows, attending faculty, and other health care professionals involved in the treatment of patients with mantle cell lymphoma (MCL).
Learning Objectives
1.) Identify clinical and biological prognostic factors that can guide treatment decision making for older adults with MCL
2.) Evaluate emerging data on targeted therapeutic approaches for treatment-naive and relapsed/refractory MCL and their applicability to older adults
3.) Assess mechanisms of resistance to targeted therapies for MCL and their implications for treatment selection
These lecture slides, by Dr Sidra Arshad, offer a quick overview of physiological basis of a normal electrocardiogram.
Learning objectives:
1. Define an electrocardiogram (ECG) and electrocardiography
2. Describe how dipoles generated by the heart produce the waveforms of the ECG
3. Describe the components of a normal electrocardiogram of a typical bipolar leads (limb II)
4. Differentiate between intervals and segments
5. Enlist some common indications for obtaining an ECG
Study Resources:
1. Chapter 11, Guyton and Hall Textbook of Medical Physiology, 14th edition
2. Chapter 9, Human Physiology - From Cells to Systems, Lauralee Sherwood, 9th edition
3. Chapter 29, Ganong’s Review of Medical Physiology, 26th edition
4. Electrocardiogram, StatPearls - https://www.ncbi.nlm.nih.gov/books/NBK549803/
5. ECG in Medical Practice by ABM Abdullah, 4th edition
6. ECG Basics, http://www.nataliescasebook.com/tag/e-c-g-basics
Title: Sense of Smell
Presenter: Dr. Faiza, Assistant Professor of Physiology
Qualifications:
MBBS (Best Graduate, AIMC Lahore)
FCPS Physiology
ICMT, CHPE, DHPE (STMU)
MPH (GC University, Faisalabad)
MBA (Virtual University of Pakistan)
Learning Objectives:
Describe the primary categories of smells and the concept of odor blindness.
Explain the structure and location of the olfactory membrane and mucosa, including the types and roles of cells involved in olfaction.
Describe the pathway and mechanisms of olfactory signal transmission from the olfactory receptors to the brain.
Illustrate the biochemical cascade triggered by odorant binding to olfactory receptors, including the role of G-proteins and second messengers in generating an action potential.
Identify different types of olfactory disorders such as anosmia, hyposmia, hyperosmia, and dysosmia, including their potential causes.
Key Topics:
Olfactory Genes:
3% of the human genome accounts for olfactory genes.
400 genes for odorant receptors.
Olfactory Membrane:
Located in the superior part of the nasal cavity.
Medially: Folds downward along the superior septum.
Laterally: Folds over the superior turbinate and upper surface of the middle turbinate.
Total surface area: 5-10 square centimeters.
Olfactory Mucosa:
Olfactory Cells: Bipolar nerve cells derived from the CNS (100 million), with 4-25 olfactory cilia per cell.
Sustentacular Cells: Produce mucus and maintain ionic and molecular environment.
Basal Cells: Replace worn-out olfactory cells with an average lifespan of 1-2 months.
Bowman’s Gland: Secretes mucus.
Stimulation of Olfactory Cells:
Odorant dissolves in mucus and attaches to receptors on olfactory cilia.
Involves a cascade effect through G-proteins and second messengers, leading to depolarization and action potential generation in the olfactory nerve.
Quality of a Good Odorant:
Small (3-20 Carbon atoms), volatile, water-soluble, and lipid-soluble.
Facilitated by odorant-binding proteins in mucus.
Membrane Potential and Action Potential:
Resting membrane potential: -55mV.
Action potential frequency in the olfactory nerve increases with odorant strength.
Adaptation Towards the Sense of Smell:
Rapid adaptation within the first second, with further slow adaptation.
Psychological adaptation greater than receptor adaptation, involving feedback inhibition from the central nervous system.
Primary Sensations of Smell:
Camphoraceous, Musky, Floral, Pepperminty, Ethereal, Pungent, Putrid.
Odor Detection Threshold:
Examples: Hydrogen sulfide (0.0005 ppm), Methyl-mercaptan (0.002 ppm).
Some toxic substances are odorless at lethal concentrations.
Characteristics of Smell:
Odor blindness for single substances due to lack of appropriate receptor protein.
Behavioral and emotional influences of smell.
Transmission of Olfactory Signals:
From olfactory cells to glomeruli in the olfactory bulb, involving lateral inhibition.
Primitive, less old, and new olfactory systems with different path
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Acute scrotum is a general term referring to an emergency condition affecting the contents or the wall of the scrotum.
There are a number of conditions that present acutely, predominantly with pain and/or swelling
A careful and detailed history and examination, and in some cases, investigations allow differentiation between these diagnoses. A prompt diagnosis is essential as the patient may require urgent surgical intervention
Testicular torsion refers to twisting of the spermatic cord, causing ischaemia of the testicle.
Testicular torsion results from inadequate fixation of the testis to the tunica vaginalis producing ischemia from reduced arterial inflow and venous outflow obstruction.
The prevalence of testicular torsion in adult patients hospitalized with acute scrotal pain is approximately 25 to 50 percent
ARTIFICIAL INTELLIGENCE IN HEALTHCARE.pdfAnujkumaranit
Artificial intelligence (AI) refers to the simulation of human intelligence processes by machines, especially computer systems. It encompasses tasks such as learning, reasoning, problem-solving, perception, and language understanding. AI technologies are revolutionizing various fields, from healthcare to finance, by enabling machines to perform tasks that typically require human intelligence.
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Ethanol (CH3CH2OH), or beverage alcohol, is a two-carbon alcohol
that is rapidly distributed in the body and brain. Ethanol alters many
neurochemical systems and has rewarding and addictive properties. It
is the oldest recreational drug and likely contributes to more morbidity,
mortality, and public health costs than all illicit drugs combined. The
5th edition of the Diagnostic and Statistical Manual of Mental Disorders
(DSM-5) integrates alcohol abuse and alcohol dependence into a single
disorder called alcohol use disorder (AUD), with mild, moderate,
and severe subclassifications (American Psychiatric Association, 2013).
In the DSM-5, all types of substance abuse and dependence have been
combined into a single substance use disorder (SUD) on a continuum
from mild to severe. A diagnosis of AUD requires that at least two of
the 11 DSM-5 behaviors be present within a 12-month period (mild
AUD: 2–3 criteria; moderate AUD: 4–5 criteria; severe AUD: 6–11 criteria).
The four main behavioral effects of AUD are impaired control over
drinking, negative social consequences, risky use, and altered physiological
effects (tolerance, withdrawal). This chapter presents an overview
of the prevalence and harmful consequences of AUD in the U.S.,
the systemic nature of the disease, neurocircuitry and stages of AUD,
comorbidities, fetal alcohol spectrum disorders, genetic risk factors, and
pharmacotherapies for AUD.
Tom Selleck Health: A Comprehensive Look at the Iconic Actor’s Wellness Journeygreendigital
Tom Selleck, an enduring figure in Hollywood. has captivated audiences for decades with his rugged charm, iconic moustache. and memorable roles in television and film. From his breakout role as Thomas Magnum in Magnum P.I. to his current portrayal of Frank Reagan in Blue Bloods. Selleck's career has spanned over 50 years. But beyond his professional achievements. fans have often been curious about Tom Selleck Health. especially as he has aged in the public eye.
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Introduction
Many have been interested in Tom Selleck health. not only because of his enduring presence on screen but also because of the challenges. and lifestyle choices he has faced and made over the years. This article delves into the various aspects of Tom Selleck health. exploring his fitness regimen, diet, mental health. and the challenges he has encountered as he ages. We'll look at how he maintains his well-being. the health issues he has faced, and his approach to ageing .
Early Life and Career
Childhood and Athletic Beginnings
Tom Selleck was born on January 29, 1945, in Detroit, Michigan, and grew up in Sherman Oaks, California. From an early age, he was involved in sports, particularly basketball. which played a significant role in his physical development. His athletic pursuits continued into college. where he attended the University of Southern California (USC) on a basketball scholarship. This early involvement in sports laid a strong foundation for his physical health and disciplined lifestyle.
Transition to Acting
Selleck's transition from an athlete to an actor came with its physical demands. His first significant role in "Magnum P.I." required him to perform various stunts and maintain a fit appearance. This role, which he played from 1980 to 1988. necessitated a rigorous fitness routine to meet the show's demands. setting the stage for his long-term commitment to health and wellness.
Fitness Regimen
Workout Routine
Tom Selleck health and fitness regimen has evolved. adapting to his changing roles and age. During his "Magnum, P.I." days. Selleck's workouts were intense and focused on building and maintaining muscle mass. His routine included weightlifting, cardiovascular exercises. and specific training for the stunts he performed on the show.
Selleck adjusted his fitness routine as he aged to suit his body's needs. Today, his workouts focus on maintaining flexibility, strength, and cardiovascular health. He incorporates low-impact exercises such as swimming, walking, and light weightlifting. This balanced approach helps him stay fit without putting undue strain on his joints and muscles.
Importance of Flexibility and Mobility
In recent years, Selleck has emphasized the importance of flexibility and mobility in his fitness regimen. Understanding the natural decline in muscle mass and joint flexibility with age. he includes stretching and yoga in his routine. These practices help prevent injuries, improve posture, and maintain mobilit
Lung Cancer: Artificial Intelligence, Synergetics, Complex System Analysis, S...Oleg Kshivets
RESULTS: Overall life span (LS) was 2252.1±1742.5 days and cumulative 5-year survival (5YS) reached 73.2%, 10 years – 64.8%, 20 years – 42.5%. 513 LCP lived more than 5 years (LS=3124.6±1525.6 days), 148 LCP – more than 10 years (LS=5054.4±1504.1 days).199 LCP died because of LC (LS=562.7±374.5 days). 5YS of LCP after bi/lobectomies was significantly superior in comparison with LCP after pneumonectomies (78.1% vs.63.7%, P=0.00001 by log-rank test). AT significantly improved 5YS (66.3% vs. 34.8%) (P=0.00000 by log-rank test) only for LCP with N1-2. Cox modeling displayed that 5YS of LCP significantly depended on: phase transition (PT) early-invasive LC in terms of synergetics, PT N0—N12, cell ratio factors (ratio between cancer cells- CC and blood cells subpopulations), G1-3, histology, glucose, AT, blood cell circuit, prothrombin index, heparin tolerance, recalcification time (P=0.000-0.038). Neural networks, genetic algorithm selection and bootstrap simulation revealed relationships between 5YS and PT early-invasive LC (rank=1), PT N0—N12 (rank=2), thrombocytes/CC (3), erythrocytes/CC (4), eosinophils/CC (5), healthy cells/CC (6), lymphocytes/CC (7), segmented neutrophils/CC (8), stick neutrophils/CC (9), monocytes/CC (10); leucocytes/CC (11). Correct prediction of 5YS was 100% by neural networks computing (area under ROC curve=1.0; error=0.0).
CONCLUSIONS: 5YS of LCP after radical procedures significantly depended on: 1) PT early-invasive cancer; 2) PT N0--N12; 3) cell ratio factors; 4) blood cell circuit; 5) biochemical factors; 6) hemostasis system; 7) AT; 8) LC characteristics; 9) LC cell dynamics; 10) surgery type: lobectomy/pneumonectomy; 11) anthropometric data. Optimal diagnosis and treatment strategies for LC are: 1) screening and early detection of LC; 2) availability of experienced thoracic surgeons because of complexity of radical procedures; 3) aggressive en block surgery and adequate lymph node dissection for completeness; 4) precise prediction; 5) adjuvant chemoimmunoradiotherapy for LCP with unfavorable prognosis.
Flu Vaccine Alert in Bangalore Karnatakaaddon Scans
As flu season approaches, health officials in Bangalore, Karnataka, are urging residents to get their flu vaccinations. The seasonal flu, while common, can lead to severe health complications, particularly for vulnerable populations such as young children, the elderly, and those with underlying health conditions.
Dr. Vidisha Kumari, a leading epidemiologist in Bangalore, emphasizes the importance of getting vaccinated. "The flu vaccine is our best defense against the influenza virus. It not only protects individuals but also helps prevent the spread of the virus in our communities," he says.
This year, the flu season is expected to coincide with a potential increase in other respiratory illnesses. The Karnataka Health Department has launched an awareness campaign highlighting the significance of flu vaccinations. They have set up multiple vaccination centers across Bangalore, making it convenient for residents to receive their shots.
To encourage widespread vaccination, the government is also collaborating with local schools, workplaces, and community centers to facilitate vaccination drives. Special attention is being given to ensuring that the vaccine is accessible to all, including marginalized communities who may have limited access to healthcare.
Residents are reminded that the flu vaccine is safe and effective. Common side effects are mild and may include soreness at the injection site, mild fever, or muscle aches. These side effects are generally short-lived and far less severe than the flu itself.
Healthcare providers are also stressing the importance of continuing COVID-19 precautions. Wearing masks, practicing good hand hygiene, and maintaining social distancing are still crucial, especially in crowded places.
Protect yourself and your loved ones by getting vaccinated. Together, we can help keep Bangalore healthy and safe this flu season. For more information on vaccination centers and schedules, residents can visit the Karnataka Health Department’s official website or follow their social media pages.
Stay informed, stay safe, and get your flu shot today!
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FDA Inspections ( How to Survive an FDA Inspection).ppt
1. How to Survive an FDA Inspection
S. Malangsha
Manager QA
shkrahul42@gmail.com
How to Survive an FDA Inspection
S. Malangsha
Manager QA
shkrahul42@gmail.com
1
2. 1. Type of Bioresearch Monitoring (BIMO)
Inspections
2. Preparing for the Inspection
3. The FDA Inspection
4. Post-Inspection
5. Most Common Findings
6. TIPS
7. Resources
1. Type of Bioresearch Monitoring (BIMO)
Inspections
2. Preparing for the Inspection
3. The FDA Inspection
4. Post-Inspection
5. Most Common Findings
6. TIPS
7. Resources
2
3. FDA conducts inspections of clinical investigators:
◦ Routinely to verify data that has been submitted to the
Agency
◦ As a result of a complaint to the Agency about the
conduct of the study at the site
◦ In response to sponsor concerns or termination of the
clinical site
◦ At the request of an FDA review division
◦ Related to certain classes of investigational products that
FDA has identified as products of special interest in its
current work plan
FDA conducts inspections of clinical investigators:
◦ Routinely to verify data that has been submitted to the
Agency
◦ As a result of a complaint to the Agency about the
conduct of the study at the site
◦ In response to sponsor concerns or termination of the
clinical site
◦ At the request of an FDA review division
◦ Related to certain classes of investigational products that
FDA has identified as products of special interest in its
current work plan
3
5. Routine inspection:
◦ Triggered by a New Drug Application (NDA) or Pre-
Market Application (PMA) submission
◦ Routine inspections account for over 80% of the
inspections performed each year
◦ Clinical Investigators who enroll the most subjects in the
NDA’s pivotal trial are the most likely to be inspected.
Routine inspection:
◦ Triggered by a New Drug Application (NDA) or Pre-
Market Application (PMA) submission
◦ Routine inspections account for over 80% of the
inspections performed each year
◦ Clinical Investigators who enroll the most subjects in the
NDA’s pivotal trial are the most likely to be inspected.
5
6. For Cause Inspection:
◦ Conducting a large volume of clinical trials
◦ Conducting clinical studies outside of one’s
field of specialization
◦ Reporting significantly better efficacy, fewer
adverse effects, or different laboratory results
than other investigators studying the same
drug
For Cause Inspection:
◦ Conducting a large volume of clinical trials
◦ Conducting clinical studies outside of one’s
field of specialization
◦ Reporting significantly better efficacy, fewer
adverse effects, or different laboratory results
than other investigators studying the same
drug
6
7. For-Cause Inspections (cont’d)
◦ Having apparent access to too many patients
with a specific disease state for the locale or
practice setting
◦ Complaints from a patient or sponsor of an
alleged violation of the regulations, protocol,
or human rights
◦ Evidence that an investigator has a significant
financial interest in the product
For-Cause Inspections (cont’d)
◦ Having apparent access to too many patients
with a specific disease state for the locale or
practice setting
◦ Complaints from a patient or sponsor of an
alleged violation of the regulations, protocol,
or human rights
◦ Evidence that an investigator has a significant
financial interest in the product
7
8. The FDA Has Called!!!
What is your next step???
The FDA Has Called!!!
What is your next step???
8
9. When FDA calls to schedule an inspection, obtain
the following information:
◦ FDA inspector name and contact information
◦ Additional inspectors information, if applicable
◦ The name of the PI being inspected
◦ What studies are being inspected
◦ The reason for the inspection
◦ Does the FDA want specific personnel available
◦ Does the FDA want specific documents available
When FDA calls to schedule an inspection, obtain
the following information:
◦ FDA inspector name and contact information
◦ Additional inspectors information, if applicable
◦ The name of the PI being inspected
◦ What studies are being inspected
◦ The reason for the inspection
◦ Does the FDA want specific personnel available
◦ Does the FDA want specific documents available
9
10. Document any telephone conversation(s) that
occurs between the FDA inspector and the study
staff
Notify study staff, Sponsor, QI Program, and
Partners Human Research Committee
The FDA inspector will usually request the
inspection take place within 10 days
Request the medical records for all subjects
enrolled in the study
Document any telephone conversation(s) that
occurs between the FDA inspector and the study
staff
Notify study staff, Sponsor, QI Program, and
Partners Human Research Committee
The FDA inspector will usually request the
inspection take place within 10 days
Request the medical records for all subjects
enrolled in the study
10
11. Reserve a room in a private area for the
inspection
◦ The room should contain no other files or records
◦ A copy machine should be located next to the room
Identify a person who will serve as an escort
Prepare a general overview of the study for the PI
and study staff
Reserve a room in a private area for the
inspection
◦ The room should contain no other files or records
◦ A copy machine should be located next to the room
Identify a person who will serve as an escort
Prepare a general overview of the study for the PI
and study staff
11
12. Update the Principal Investigator’s CV. This should
include a list of all current studies.
Ensure that all study documentation is available
for review with the inspector.
Review study documentation for:
◦ Comprehensiveness, accuracy, and compliance
◦ Weakness/gaps; correct those that can be corrected (i.e.
file violations, notes-to-file, locate missing documents,
etc.)
◦ Unresolved or outstanding issues
Update the Principal Investigator’s CV. This should
include a list of all current studies.
Ensure that all study documentation is available
for review with the inspector.
Review study documentation for:
◦ Comprehensiveness, accuracy, and compliance
◦ Weakness/gaps; correct those that can be corrected (i.e.
file violations, notes-to-file, locate missing documents,
etc.)
◦ Unresolved or outstanding issues
12
13. The PI or his/her representatives should meet the
inspector and receive and sign the FDA form 482
“Notice of Inspection.”
Request to see the inspector’s identification if
he/she does not present it to you.
Write down the inspector’s identification
information—you cannot make a copy of the
inspector’s badge!!
The PI or his/her representatives should meet the
inspector and receive and sign the FDA form 482
“Notice of Inspection.”
Request to see the inspector’s identification if
he/she does not present it to you.
Write down the inspector’s identification
information—you cannot make a copy of the
inspector’s badge!!
13
14. FDA inspector may request a tour of the
facility where research took place.
Escort should accompany the inspector at
all times.
Upon request, provide the inspector only
with files that have been requested.
FDA inspector may request a tour of the
facility where research took place.
Escort should accompany the inspector at
all times.
Upon request, provide the inspector only
with files that have been requested.
14
15. If the inspector requests copies of documents:
◦ Remove subject identifiers from the copies given to the
inspector
◦ Make a copy for yourself
◦ The inspector’s copies should be stamped ‘Confidential’
and your copies should be stamped ‘Copy.’
The PI should set aside time each day to talk with
the inspector
If the inspector requests copies of documents:
◦ Remove subject identifiers from the copies given to the
inspector
◦ Make a copy for yourself
◦ The inspector’s copies should be stamped ‘Confidential’
and your copies should be stamped ‘Copy.’
The PI should set aside time each day to talk with
the inspector
15
16. How to answer questions from the inspector:
◦ Be concise; answer only the question that is asked
◦ Always be clear with answers to questions
◦ Answer honestly and openly
◦ DO NOT volunteer information
◦ DO NOT guess or speculate
◦ DO NOT argue
◦ If you don’t know the answer, write down the question
and refer it to the appropriate person
◦ Keep a log of questions asked by the inspector
How to answer questions from the inspector:
◦ Be concise; answer only the question that is asked
◦ Always be clear with answers to questions
◦ Answer honestly and openly
◦ DO NOT volunteer information
◦ DO NOT guess or speculate
◦ DO NOT argue
◦ If you don’t know the answer, write down the question
and refer it to the appropriate person
◦ Keep a log of questions asked by the inspector
16
17. FDA Inspector will verify:
◦ Who performed various aspects of the protocol
(eligibility, consenting, etc.)
◦ The degree of delegation of authority
◦ Where specific aspects of the investigation were
performed
◦ How and where data were recorded
◦ How were study staff oriented/trained on the protocol
and investigational product
◦ That the PI followed the study protocol approved by the
IRB
FDA Inspector will verify:
◦ Who performed various aspects of the protocol
(eligibility, consenting, etc.)
◦ The degree of delegation of authority
◦ Where specific aspects of the investigation were
performed
◦ How and where data were recorded
◦ How were study staff oriented/trained on the protocol
and investigational product
◦ That the PI followed the study protocol approved by the
IRB
17
18. In addition, the inspector will record the
following information:
◦ Dates of IRB approvals (original, continuing
review, etc.)
◦ When the first subject was screened
◦ When the first subject was consented
◦ First administration of the investigational
product
◦ Last follow-up for any study subject
In addition, the inspector will record the
following information:
◦ Dates of IRB approvals (original, continuing
review, etc.)
◦ When the first subject was screened
◦ When the first subject was consented
◦ First administration of the investigational
product
◦ Last follow-up for any study subject
18
19. The following items are routinely examined:
◦ Adequacy of communication with the IRB, including the
initial submission, continuing reviews, adverse event
reporting, progress reports, etc.
◦ Completeness of accountability documentation for the
receipt, storage, administration and return of the
investigational product
◦ Compliance with the study protocol and documentation
that each deviation/amendment received IRB and
sponsor approval
The following items are routinely examined:
◦ Adequacy of communication with the IRB, including the
initial submission, continuing reviews, adverse event
reporting, progress reports, etc.
◦ Completeness of accountability documentation for the
receipt, storage, administration and return of the
investigational product
◦ Compliance with the study protocol and documentation
that each deviation/amendment received IRB and
sponsor approval
19
20. Inspected documents (cont)
◦ Appropriateness of the informed consent process
◦ Prompt and complete reporting of adverse events to the
IRB and sponsor
◦ Compliance with record retention requirements
◦ Adequate monitoring of the site and communication of
the sponsor (monitoring reports)
◦ Consent Forms (including the consent process)
Inspected documents (cont)
◦ Appropriateness of the informed consent process
◦ Prompt and complete reporting of adverse events to the
IRB and sponsor
◦ Compliance with record retention requirements
◦ Adequate monitoring of the site and communication of
the sponsor (monitoring reports)
◦ Consent Forms (including the consent process)
20
21. The inspector will review subject data to verify that:
◦ Data entered on the CRF is has been accurately and
completely recorded (matches source documents)
◦ Subjects existed
◦ Subjects meet inclusion/exclusion criteria
◦ Clinical laboratory testing was documented by laboratory
records
◦ All adverse events were documented and appropriately
reported
◦ The PI assessed the severity of the adverse event and
documented the relationship of the event to the
investigational product
◦ All concomitant therapies and/or inter-current illnesses
were documented and reported
The inspector will review subject data to verify that:
◦ Data entered on the CRF is has been accurately and
completely recorded (matches source documents)
◦ Subjects existed
◦ Subjects meet inclusion/exclusion criteria
◦ Clinical laboratory testing was documented by laboratory
records
◦ All adverse events were documented and appropriately
reported
◦ The PI assessed the severity of the adverse event and
documented the relationship of the event to the
investigational product
◦ All concomitant therapies and/or inter-current illnesses
were documented and reported
21
22. The FDA inspector will hold an exit interview at
the conclusion of the audit to discuss findings and
deficiencies
Study staff should document the interview,
specifically noting observations, comments, and
commitments
Any deficiencies will be noted on the FDA form
483 and given to the PI
◦ PI can respond to the 483 verbally during the exit
interview and/or in writing
The FDA inspector will hold an exit interview at
the conclusion of the audit to discuss findings and
deficiencies
Study staff should document the interview,
specifically noting observations, comments, and
commitments
Any deficiencies will be noted on the FDA form
483 and given to the PI
◦ PI can respond to the 483 verbally during the exit
interview and/or in writing
22
23. Contact the QI Program for assistance with
responding to the Form 483
Written response should:
◦ Determine if a finding was an oversight/single
occurrence of if it is a systemic problem requiring a
change to the procedure/process
◦ Address each specific finding, point by point
◦ Describe corrective actions—DON’T OVERCOMMIT!!
◦ The response should be sent to the FDA within 30 days
Contact the QI Program for assistance with
responding to the Form 483
Written response should:
◦ Determine if a finding was an oversight/single
occurrence of if it is a systemic problem requiring a
change to the procedure/process
◦ Address each specific finding, point by point
◦ Describe corrective actions—DON’T OVERCOMMIT!!
◦ The response should be sent to the FDA within 30 days
23
24. After the inspection, the inspector will write an
Establishment Inspection Report (EIR) and submit
it to FDA headquarters
After the report has been evaluated you will
receive one of three letters:
◦ No action indicated (NAI): No objectionable conditions or
practices were found during the inspection, or the
significance of the objectionable conditions does not
justify further FDA action
After the inspection, the inspector will write an
Establishment Inspection Report (EIR) and submit
it to FDA headquarters
After the report has been evaluated you will
receive one of three letters:
◦ No action indicated (NAI): No objectionable conditions or
practices were found during the inspection, or the
significance of the objectionable conditions does not
justify further FDA action
24
25. Post-inspection letters (cont)
◦ Voluntary Action Indicated (VAI): Objectionable
conditions were found and documented, but the FDA is
not prepared to take or recommend further regulatory
action because the objectionable conditions are few and
do not seriously impact subject safety or data integrity
◦ Official Action Indicated (OAI): Regulatory violations
uncovered during the inspection are repeated or
deliberate and/or involve submission of false information
to FDA or to the sponsor
Post-inspection letters (cont)
◦ Voluntary Action Indicated (VAI): Objectionable
conditions were found and documented, but the FDA is
not prepared to take or recommend further regulatory
action because the objectionable conditions are few and
do not seriously impact subject safety or data integrity
◦ Official Action Indicated (OAI): Regulatory violations
uncovered during the inspection are repeated or
deliberate and/or involve submission of false information
to FDA or to the sponsor
25
26. OAI may result in:
◦ Warning letter (WL)
Violations can be corrected through specific action(s) by the
investigator and adherence to the corrective action plan has
a high probability of preventing similar or other violations in
the future
◦ Notice of Initiation of Disqualification Proceedings and
Opportunity to Explain (NIDPOE)
Repeatedly or deliberately failed to comply with the
requirements for conducting clinical trials
Repeatedly or deliberately submitted false information to
FDA or to the sponsor
OAI may result in:
◦ Warning letter (WL)
Violations can be corrected through specific action(s) by the
investigator and adherence to the corrective action plan has
a high probability of preventing similar or other violations in
the future
◦ Notice of Initiation of Disqualification Proceedings and
Opportunity to Explain (NIDPOE)
Repeatedly or deliberately failed to comply with the
requirements for conducting clinical trials
Repeatedly or deliberately submitted false information to
FDA or to the sponsor
26
27. In 2013, clinical investigator
inspections were classified as:
NAI: 50%
VAI: 41%
OAI: 9 %
In 2013, clinical investigator
inspections were classified as:
NAI: 50%
VAI: 41%
OAI: 9 %
27
28. Failure to follow the investigational plan
Failure to ensure that informed consent was
obtained in accordance with 21 CFR 50
Failure to maintain accurate, complete, and
current records
Inadequate device/drug accountability
Failure to obtain IRB approval
Failure to follow the investigational plan
Failure to ensure that informed consent was
obtained in accordance with 21 CFR 50
Failure to maintain accurate, complete, and
current records
Inadequate device/drug accountability
Failure to obtain IRB approval
28
29. Develop compliance plans to ensure proper study
management:
◦ SOP’s: Standard Operating Procedures to achieve
consistency
◦ Source Documentation: Maintain all the applicable
original documents, data, and records that correspond
with the CRFs
◦ Checklists/Logs: A way to verify completion of study-
related procedures
◦ Note-to-file: A way to explain and correct unexpected
departures from the protocol
Develop compliance plans to ensure proper study
management:
◦ SOP’s: Standard Operating Procedures to achieve
consistency
◦ Source Documentation: Maintain all the applicable
original documents, data, and records that correspond
with the CRFs
◦ Checklists/Logs: A way to verify completion of study-
related procedures
◦ Note-to-file: A way to explain and correct unexpected
departures from the protocol
29
31. International Conference of Harmonisation
Good Clinical Practice Guidelines (GCP)
◦ Originally intended as guidelines to help standardize
international drug studies and speed up new drug
approval process (1996)
◦ FDA has adopted GCP guidelines from ICH
◦ ICH Guidelines contain a detailed approach to “best
practices”
International Conference of Harmonisation
Good Clinical Practice Guidelines (GCP)
◦ Originally intended as guidelines to help standardize
international drug studies and speed up new drug
approval process (1996)
◦ FDA has adopted GCP guidelines from ICH
◦ ICH Guidelines contain a detailed approach to “best
practices”
31
32. ICH GCP Guidelines
Section 8 Essential documents for the conduct of
a clinical trial
◦ These essential documents individually and collectively
permit evaluation of the conduct of the trial and the
quality of the data produced
◦ Documents are the ones typically audited by sponsors
and regulatory authorities
ICH GCP Guidelines
Section 8 Essential documents for the conduct of
a clinical trial
◦ These essential documents individually and collectively
permit evaluation of the conduct of the trial and the
quality of the data produced
◦ Documents are the ones typically audited by sponsors
and regulatory authorities
32
33. Recent findings of the FDA process has resulted in
the FDA intensifying its commitment for oversight
of clinical trials. Therefore, the number of
inspections is expected to rise.
Possible areas of focus:*
◦ Informed consent (content, timing, documentation)
◦ Protocol compliance (inclusion/exclusion deviations,
patient schedule)
Recent findings of the FDA process has resulted in
the FDA intensifying its commitment for oversight
of clinical trials. Therefore, the number of
inspections is expected to rise.
Possible areas of focus:*
◦ Informed consent (content, timing, documentation)
◦ Protocol compliance (inclusion/exclusion deviations,
patient schedule)
33
34. Areas of focus (cont)
◦ IRB reporting (notifications for protocol violations,
serious adverse events, maintenance of ongoing
approval)
◦ Disclosure and proper documentation of adverse events
◦ Drug/device accountability
◦ Delegation of investigator responsibility to study staff
◦ Foreign clinical sites
◦ Conflicts of interest
Areas of focus (cont)
◦ IRB reporting (notifications for protocol violations,
serious adverse events, maintenance of ongoing
approval)
◦ Disclosure and proper documentation of adverse events
◦ Drug/device accountability
◦ Delegation of investigator responsibility to study staff
◦ Foreign clinical sites
◦ Conflicts of interest
34
35. Document, document,
document!!
An ounce of prevention is
worth a pound of cure!!
Document, document,
document!!
An ounce of prevention is
worth a pound of cure!!
35