Regulations governing how combination products are regulated

The knowledge of combination products and their regulations is essential for regulatory professionals. This is because of the high proportion of combination products in the market, as well as the array of regulations that govern them.

21 CFR 3.2 (e) has a complete definition of a combination product. A combination product is one that is made by combining:

o  A drug and a biological product

o  A drug and a device

o  A biological product and a device

o  A drug, a biological product and a device

A combination drug is one that becomes a single product and is obtained by combining any of the above.

The FDA has a number of regulations on combination products that drug, medical device and biological companies need to show compliance with. 21 CFR Part 3 has regulations that relate to how companies need to assign their combination products to the FDA for review, and Part 3.4 explains how the FDA goes about in its work of designating the review of these products.

Recent regulation from the FDA

The FDA passed a recent regulation: the Final rule on postmarketing safety requirements for combination products, on December 20, 2016. This Rule, which came into effect from January 19, 2017, sets out the postmarketing safety reporting requirements for products

o  That are termed as constituent products, meaning the parts of the drug or devices or biological product that go into a combination product

o  Which are deemed as combination products since two or more different types of regulated products have gone into it, and whose constituent parts have received an FDA marketing authorization.

The FDA’s regulations for devices, drugs and biological products have many similarities. Yet, there are unique and different standards, reporting requirements and timeframes for each of these regulations. It is to harmonize the variations in these standards, which the FDA believes result in inconsistent and/or incomplete reporting relating to post-marketing safety, that the Final Rule came into effect. It seeks to bring about consistency and completeness in the safety reporting requirements of post-marketing activity of these products and avoid repetitive reporting for combination products that have received FDA marketing authorization.

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An understanding of the complexities and intricacies of combination product regulation

A webinar that is being organized by Compliance4All, a leading provider of professional trainings for all the areas of regulatory compliance, will give a thorough understanding of combination products and their regulations. The speaker at this webinar, Charles H. Paul, who is the President of C. H. Paul Consulting, Inc., a regulatory, manufacturing, training, and technical documentation consulting firm which is in its twentieth year of business, will be the speaker.

To gain clarity on the regulations that govern combination products, please register for this webinar by visiting How combination products are regulated

Learning session with value add-ons

Charles will offer valuable learning during this session for professionals who are currently involved in the manufacture of combination products or are about to submit products in the near future for approval. Charles will explain all the facets of combination products, beginning with their definition. He will explain the complexities associated with these kinds of products to an organization from the perspective of the constituents of the combination product and give an understanding of how to overcome them.

Charles will also present scenarios that will discuss how and which regulations apply based on the device and the kind of facility manufacturing it. He will facilitate easier understanding of the complex process of regulation application by providing a job aid that will be a value addition to this webinar.

Different regulations for different combination products

In explaining the various regulations that govern combination products; Charles will explain how the regulatory process applies to them, since the approval process for a purely medical product varies from that of a purely biological or a purely pharmaceutical product. He will also review the kind of actions that attract 483’s from the FDA to give a clearer understanding of the approaches for GMP and regulatory applications.

Charles will cover the following areas at this session:

o  Definition of Combination Products

o  Combination Products and US Regulations

o  Combination Product Approval Process

o  GMPs for Combination Products

Warning Letter Case Study Review.

How to implement technology transfer in pharmaceuticals

Technology transfer is a process that has gained widespread acceptance and prominence in many areas of knowledge all over the world today. Technology transfer can be broadly defined as the way in which technology is transferred from the source of its origin of creation to sources from where it can be developed and/or distributed to a wider area.

Technology transfer is carried out in a number of areas. In universities, which are breeding grounds for new ideas, technology transfer is carried out to help the product reach out to the market. In the field of intellectual property (IP), technology transfer is the means by which a patent or a copyright or a trade secret is licensed to be exploited for commercialization.

In pharmaceuticals

Technology transfer is a major component in the field of pharmaceuticals, as well. In the field of pharmaceuticals, the method by which technology transfer is done is important. Correctly describing the methods and processes of technology transfer is extremely important to prevent any major deviations or misunderstandings between the parties at a later date. The aim of exploitation of technology, patent-protected or otherwise, in this field is to help the product reach out to the larger market, so that the general public benefits from the invention or innovation. Defining the terms by which the commercial gains of the technology transfer will be shared is also important.

If a pharma product is to become successful; its transfer and that of its processes has to be handled extremely well for the product to enjoy a successful launch. Only this ensures that pharmaceutical products of the highest quality are delivered to the patients, and also that they meet the expected business goals.

Yet, executing the technology transfer is complex even in these days of legal protection for IP. Technological transfer of pharma products involves the interactions of many disciplines across an organization. While carefully developing, managing, and transferring of technical and business knowledge is one aspect; the development of processes and steps for defining the formal transfer of that knowledge from R&D documents and systems to commercial manufacturing documents and systems is another.

A learning session on pharmaceutical technology transfer

The ways of handling this whole process of technology transfer in the field of pharmaceuticals will be the teaching a webinar from Compliance4All, a leading provider of professional trainings in all the areas of regulatory compliance will be organizing.

The speaker at this webinar is Steven Laurenz, a senior pharma professional who brings over 25 years of technical leadership experience in product development, process development, technology transfer, and process optimization.

To enroll for this webinar and gain the benefit of hearing from this seasoned professional, please register for this webinar by logging on to http://www.compliance4all.com/control/w_product/~product_id=501257LIVE?Wordpress-SEO

The technology transfer process

The aim of this session is to introduce the concepts associated with implementing a carefully defined technical and business governance program. Along with this, Steven will also suggest a clearly defined R&D process to chart technology transfer steps for successful implementation. The concepts associated with transferring the scientific technology needed to manufacture the product, processes to ensure the receiving manufacturing facility is ready for the product and tools and templates to help capture the knowledge, will all be covered at this webinar.

These are the objectives that this webinar will help the participants achieve:

o  Define technology transfer

o  Identify elements of the business process framework for managing technology transfers

o  Identify New Product transfer process

o  Explain benefits of technology transfer

o  Determine elements of a successful technology transfer

Steven will cover the following areas at this webinar:

o  The importance of technology transfer

o  The use of a technical review system to update and review technology knowledge obtained during drug product development

o  The use of a Product Strategy Review system to review important business aspects in preparation for transfer

o  Tools and Templates used for technology transfer.

Ensuring compliance with drug advertising promotional claims requirements

Advertising is a highly challenging and creative field. However, when making claims about the efficacy and effectiveness of products, especially drug products, advertising professionals need to comply with strict compliance guidelines which set out the limits of claims. The US government lays considerable stress on the veracity aspects of the advertising claims.

An ad for a drug product must state not just the benefits of a product, but also its side effects, risk and a lot other information such as the product ingredients, generic name/s, and proper indications of use. In addition, the image of models shown for the product should be inappropriate.

It should represent the correct age group for which the product is prescribed, and should not show a model of any other age group in the ad. If a cough preparation is targeted at the teenage population, the ad image should show only a teenager as a model and not someone who is older or younger.

The FDA has many requirements on the validity of advertising claims

In addition, there is another very important requirement from the FDA: The print ad should ask the user to report a negative finding to MedWatch and should give the contact numbers of the agency to whom to report negative findings of the use of the drug. The ad promotion branding should also advice the user to seek medical opinion before using the drug, so that expert medical advice is taken and the patient does not take the drug at will.

Offering clarity on the gray areas of advertising and promotional material

These said, there is considerable confusion about the subjective, or what are called gray areas of advertising claims. The issue is how to interpret these gray areas of a product or the ad, which will make a difference to the user’s decision making.

A webinar that is being organized by Compliance4All, a leading provider of professional trainings for the areas of regulatory compliance, will seek to clarify on these and other related areas of drug ad promotion.

Peggy Berry, who is the President and CEO at Synergy Consulting, where she provides consulting services to companies in all aspects of drug development, will be the speaker at this webinar. Over the course of this 90-minute session, Peggy will explain the requirements for compliance within the US. To benefit from the enormous experience Peggy brings into field, please register for this webinar by visiting

http://www.compliance4all.com/control/w_product/~product_id=501227LIVE?Wordpress-SEO

A description of all the issues relating to advertising and promotional material

She will explain the gray areas that must be evaluated thoroughly. She will show the ways of conducting a risk assessment and suggest and describe the strategies for mitigating risks and making challenging decision. She will familiarize participants with the critical situations and the important kinds of promotional materials in which advertisers could potentially get inputs and suggestions from regulatory agencies. She will equip participants with the knowledge needed for handling these situations. An understanding will be given of the important promotional materials and the strategies for implementing review processes and procedures to facilitate high compliance standards.

An important leaning offered at this webinar is compliance issues in the creation of advertising and promotional materials. Peggy will explain what needs to be done internally to assure assessment, evaluation and documentation of the advertising material.  Attending this webinar will ensure that the participants put in place an advertisement claims compliance program that will ensure full understanding and communication of potential risks associated with materials. The webinar will also give them the ability to mitigate risk through small but important amendments, which will go a long way in ensuring a high level of compliance standards by all the staff concerned.

Peggy will cover the following areas at this webinar:

o  Compliance Requirements

o  Submission Requirements

o  Prior to Approval

o  Direct to Consumer

o  Social Media

o  Medical Affairs

o  Sales Training

o  Review Process Considerations.

https://www.fda.gov/drugs/resourcesforyou/consumers/prescriptiondrugadvertising/ucm082284.htm

https://www.fda.gov/drugs/GuidanceComplianceRegulatoryInformation/guidances/ucm064956.htm

Packaging and labeling are important components of commercial and clinical products

Packaging and labeling of commercial and clinical products are very important aspects to an organization involved in a business that relates to these products. While the packaging and labeling of commercial products is important, it is more so with clinical products, because these products play an important role in a clinical trial and also in the very life of a patient or subject.

Commercial products have their own value over time. The FDA has guidances for commercial pharmaceutical products. Subpart G of CFR 21, Vol 4 concerns itself with packaging and labeling control. In line with its guidances on many related topics, this section deals with requirements for how labeling and packaging have to be carried out. These are some of the FDA’s rules on this topic:

o  Written procedures that describe how the labeling and packaging materials are received, identified, stored, handled, sampled, examined and tested and followed

o  Rejection of labeling and packaging materials that do not meet specifications or fail to meet their purpose

o  Maintenance of records of packaging and labeling for each shipment

o  Putting proper labels for each pharmaceutical product that describes the ingredients, strength, dosage and expiry date clearly

o  Destruction of expired products

o  Cancellation of license for pharmaceutical commercial products that fail to meet these requirements

The role of packaging and labeling in clinical trial products

Given the importance of clinical trials, and considering another equally important factor –namely that they are conducted across the globe these days –the need for extreme stringency in the packing and labeling of clinical trials products can never be overstated. In the area of clinical trials, these are the most popular packages:

o  Blisters

o  Bottles

o  Pouches

o  Syringes

o  Tubes

Irrespective of which of these packaging forms one is dealing with; there are stringent regulations for how to handle the packaging and labeling of clinical trials products. These regulations require manufacturers to maintain patient-friendly packaging and maintain strict standards concerning the following activities:

o  Filling of the product

o  Assembling it

o  Sorting it

o  Ensuring stability and containment of the product

Learn about the topic of packaging and labeling

All the nuances of packaging and labeling in the commercial and clinical products arena will be taught at a meaningful and educative webinar that is being organized by Compliance4All, a leading provider of professional trainings for all the areas of regulatory compliance.

At this webinar, Peggy J. Berry, who is the President and CEO at Synergy Consulting where she provides consulting services to companies in all aspects of drug development; will be the speaker. Please register for this webinar by logging on to http://www.compliance4all.com/control/w_product/~product_id=501226LIVE?Linkedin-SEO

Teaching on all the key elements of packaging and labeling for commercial and clinical trial products

Peggy will introduce all the elements of packaging and labeling for commercial and clinical trial products at this webinar. The ways of transforming a protocol into an optimal package design will be one of the main constituents of this session. She will complete a review of the compliance requirements between commercial and clinical packaging and labeling, as well as a case study of changing commercial packaging for optimization.

Key personnel in the pharmaceutical commercial and clinical trials areas, such as    manufacturing personnel, quality and compliance personnel, regulatory personnel and clinical operations, will gain immense insights into this subject at this webinar, since Peggy will discuss all the core and auxiliary topics of commercial and clinical trials packaging and labeling, such as

o  Laws and regulations related to packaging and labeling

o  Guidelines implemented during commercial and clinical packaging and labeling

o  Implementing SOPs to ensure compliance

o  Implementing appropriate change control procedures

o  Selection of materials for packaging and labeling

o  Required submission content for the IND/NDA related to packaging and labeling materials and procedures

o  Commercial packaging compliance

o  Commercial labeling compliance

o  Clinical packaging compliance

o  Clinical labeling compliance

o  Change control for materials, design and content

At this session, the speaker will cover the following areas:

o  Commercial packaging compliance

o  Commercial labeling compliance

o  Clinical packaging compliance

o  Clinical labeling compliance

o  Change control for materials, design and content)

o  Pharmaceutical (drug/biologic).

https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfcfr/CFRSearch.cfm?CFRPart=211&showFR=1&subpartNode=21:4.0.1.1.11.7

http://pharmaceuticalcommerce.com/manufacturing-and-packaging/clinical-trial-logistics-and-packaging/

Are Your Test Methods Ready for Quality Control or any laboratory ?

The FDA considers verification and transfer of Test Methods a subject worthy of 483 observations and issuance of Warning Letters. Test method verification is also required by the GMPs, and USP has a whole chapter dedicated to test method verification. This makes comprehension of the requirements for the verification and transfer of a test method into a laboratory imperative for Laboratory Managers and other personnel.

In normal circumstances, the requirement for method transfer arises with the transfer of the method from the Method Development environment to the routine Quality Control testing laboratory. Ideally, however, the existence of method transfer any time a method is transferred from one laboratory to another should be in place, as this would also address and include the transfer of the method into more environments, such as a stability testing laboratory, or a contract laboratory or the testing laboratory of a contract manufacturer.

Support for verification of test methods

The US GMPS requires the verification of test methods under actual conditions of use to verify the suitability of all testing methods. The USP seconds this, stating that “Users of compendial analytical procedures are not required to validate these procedures when first used in their laboratories, but documented evidence of suitability should be established under actual conditions of use”.

The concept of method verification is also supported by a modified version of the accepted definition of test method validation, which requires documented evidence to ensure “that the test method performs as intended in the using laboratory”.

So, what does this mean for laboratories that have not performed the test before? Such firms must demonstrate something to prove that the test method performs as intended. This has to be done irrespective of whether the transfer is from the method development laboratory to the internal Quality Control testing laboratory or a laboratory supporting a contract manufacturer. All that is needed for the firm is to demonstrate that the receiving laboratory has the capability to perform the test, and also that the test results are an accurate reflection of the attribute being tested.

A learning session on method transfer and method verification

However, many companies do not understand what should be done for a thorough, successful test method transfer. A webinar from Compliance4All, a highly respected provider of professional trainings for all the areas of regulatory compliance, will explain all the intricacies of method transfer and method verification.

At this webinar, Jerry Lanese, an independent consultant with a focus on Quality Systems and the components of an effective Quality System, will be the speaker. In order to understand the complete nitty-gritty of method transfer and method verification, please register for this valuable webinar by visiting http://www.compliance4all.com/control/w_product/~product_id=501282LIVE?Linkedin-SEO

The term method verification acquired a new shape and meaning with the USP’s publication of its stimulus article on the test method lifecycle. This stimulus article proposes Continued Test Method Verification during stage 3 of the test method lifecycle. At this webinar, Jerry will discuss test method verification and what all need to be considered for the method verification project.

This learning, on all areas of method transfer and method verification, will be extremely useful and valuable for Laboratory Directors, Managers, Supervisors and Analysists in any laboratory performing GMP testing.

At this session, Jerry will cover the following areas:

o  The requirements for test method verification when a method is transferred from one laboratory to another

o  What might be included in the method verification that accompanies a test method transfer?

o  The regulatory and compendial expectation for test method verification as a part of the test method lifecycle

o  What might be included in continued test method verification?

How the supposed microbial control or monitoring approach SHOULD be handled.

That water systems are critical to the pharmaceutical industry is a given. This fact makes it absolutely imperative for pharmaceutical companies to get a grasp of the techniques needed for getting these systems right. Product recall, costly downtime and many other related negatives are some of the consequences of not getting these matters right.

Among the primary causes, on account of which pharmaceutical companies get their water systems wrong, is the number of water system biofilm control and microbial monitoring myths that dominate the industry. Pharmaceutical water systems experts are often in awe of the level to which myths have permeated the industry, to the extent that most water systems today have been designed and are operated and controlled using at least some traditional concepts and methods that are simply completely wrong. They are often bemused at how traditions that could be so totally wrong are so strongly rooted, misguiding practitioners in the industry.

Understand water system biofilm control and microbial monitoring myths and know how to defeat them

Busting these often dangerous water system biofilm control and microbial monitoring myths is the core of a webinar on pharmaceutical water systems that is being organized by Compliance4All, a highly popular provider of professional trainings for all the areas of regulatory compliance.

At this webinar, the world-renowned expert on pharmaceutical systems, Dr. Teri C. Soli, will be the speaker. Dr. Soli, who is Principal Consultant at Soli Pharma Solutions, will take participants through all the myths that have been prevalent in the water systems industry for so long.

In order to understand the nature of water system biofilm control and microbial monitoring myths and subsequently get your pharmaceutical water systems right, just register for this webinar by visiting

http://www.compliance4all.com/control/w_product/~product_id=501243LIVE?Wordpress-SEO

Destroying water system biofilm control and microbial monitoring myths one by one

As a first step to shattering water system biofilm control and microbial monitoring myths, Dr. Soli will zoom in on the many reasons that have resulted in the perpetuation of these myths. But whatever the cause, one needs to be aware of the myths and understand how to do away with these.

He will lay threadbare each of the common water system biofilm control and microbial monitoring myths that are doing the rounds in the pharmaceutical water systems industry. He will be discussing the water system biofilm control and microbial monitoring myths that are related to microbial control approaches as well as microbial monitoring.

He will take up each myth, trace and explain its origin, and then put how the supposed microbial control or monitoring approach should be handled into true context, rather than how it is being handled.

In this session on water system biofilm control and microbial monitoring myths, Dr. Soli will cover the following areas:

  • Why water myths develop
  • Impact of c-GMPs
  • Well-meaning but misguided precedents
  • Scientifically unchallenged traditions and benchmarking
  • Rule-hungry culture
  • Water System Microbial Control Myths
  • WFI from RO
  • Turbulent Flow and Flow Rate
  • Dead Leg Rules
  • Smooth Surfaces
  • In-Line Sterilizing Filters
  • Ozone
  • Microbial Enumeration Myths
  • Referee Methods
  • Thermophiles in Hot Systems
  • R2A, 35°C, 5 days
  • Test Filter Membrane Rating
  • Compendial Action Levels
  • TOC and Endotoxin as Microbial Count Correlates.

What to expect during GMP Inspection

Regulatory agencies such as the FDA conduct inspections for product-related Good Manufacturing Practice (GMP) in the course of assessing an application for marketing approval. The basic purpose of product-related GMP inspections is to check for compliance with the GMP guidelines set out in the International Conference on Harmonization (ICH) and national and local GMP regulations. GMP is the slightest standard that a manufacturer has to mandatorily meet in its production processes. The aim of implementing GMP is to ensure that products

o  Are of consistently high quality

o  Are appropriate to their intended use, and

o  Meet the requirements of the marketing application or product specification.

Many factors trigger a product-related GMP inspection

The reasons for which these product-related GMP inspections can be triggered are quite similar to those that trigger an OSHA inspection. It can be due to any of these:

o  A whistleblower

o  In the course of inspecting other products in the facility

o  By regulatory agencies other than the one that is meant to carry out the inspection

o  When the regulatory agency comes to know of or suspects a breach.

Thorough preparation is the key to success at a product-related GMP inspection

There are several aspects to a product-related GMP inspection that needs to be borne in mind. They could happen simultaneously, or they may happen after an announcement to this effect.

Given the complexity of the nature of a product-related GMP inspection; it is essential to understand the intricacies of this exercise. A failure at a product-related GMP inspection is sure the cost the organization a lot in terms of money and effort.

It is because of the critical importance of success at a product-related GMP inspection that an organization needs to be thorough in its preparation for such an inspection. Organizations that go through product-related GMP inspections need to be ready for a product-related GMP inspection from a number of important perspectives.

Training on how to prepare for a product-related GMP inspection

This is the training a webinar from Compliance4All, a very well-known provider of professional trainings in all the areas of regulatory compliance, will be offering.

The speaker at this webinar is Peggy J. Berry, the President and CEO at Synergy Consulting, where she provides consulting services to companies in all aspects of drug development. Understanding how to be prepared for a product-related GMP inspection from Peggy is easy. All that is needed is to visit http://www.compliance4all.com/control/w_product/~product_id=501225LIVE?Linkedin-SEO to enroll.

The aim of this webinar from Compliance4All is to offer practical tips and advice for ensuring that all inspections are conducted in the most effective and efficient way possible. The core components of ensuring these include:

o  Ongoing readiness for inspections

o  Rehearsals and preparation for successful facility inspections, and

o  Knowing how to respond to findings by regulatory agencies.

Peggy will offer in-depth insights into these aspects of product-related GMP inspection.

Handling inspections can be a tough job

Regulatory agency inspections are not the easiest of people to handle and manage during a product-related GMP inspection. They can be very fussy and tough. Organizations that have no idea about how to manage product-related GMP inspections can have a difficult time with these inspectors, no matter from various regulatory agencies they hail.

At this webinar, Peggy will show what to expect during the product-related GMP inspection. She will also show the ways of successfully and efficiently streamlining and managing the inspection. She will also highlight the importance of adequate follow-up during and after the inspection.

During the course of this 90-minute session, which will be of tremendous use to professionals related to GMP, such as Design Engineers, and those in manufacturing, supply chain, technical operations, Quality Control, Quality Assurance and Regulatory Affairs, Peggy will cover the following areas:

o  Types of Inspections (for cause, pre-approval, periodic ) > API & FDF

o  Notification Timing

o  Foreign Facilities

o  What to expect during Inspection

o  Do a company audit as the FDA would (fall dress rehearsal)

o  Make adjustments as needed/address issues/take needed actions

o  Managing the Inspection

o  Inspection on follow-up.