cGMP Data Integrity is of Critical Importance

Of late, the FDA has been turning on the heat on manufacturers in the FDA-regulated industries that violate its regulations. It has a penchant for going after manufacturing facilities that show laxity in implementing current Good Manufacturing Practices (cGMP). This ardor is understandable. cGMP violations affect the quality of the product; hence the strictness, considering that it is patients who consume these products.

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There are ways of ensuring that the product meets the acute scientific requirements set out for it at all stages, from the beginning till the end. Data integrity is the most important of these. As the term suggests, data integrity is the assurance that there is complete accuracy, security, reliability and completeness of the records relating to the product and its processes.

Data integrity comes about by tightening cGMP requirements

In the FDA’s line of thinking, the way of ensuring uncompromising quality of a product is by tightening its laws on cGMP and implementing them. The FDA believes that only extremely stringent actions on its part help manufacturers meet regulatory requirements and give patients the assurance that the products they use meet quality standards.

Among the many mechanisms that the FDA has undertaken towards ensuring this, requirements relating to data integrity rank high. Data integrity is critical to ensure the quality, safety, and efficacy of products in the FDA-regulated industries. These include biologics, pharmaceuticals, life sciences and medical devices, among others.

What happens when there is no data integrity?

Issues relating to data integrity have been high on the list of items that the FDA finds out during its inspections. When companies fail to meet the FDA’s data integrity expectations and requirements; data integrity is compromised. When this happens, many batches of finished goods that do not comply with regulatory authorization terms get manufactured. The FDA prohibits such lots and batches for release for sale.

Lack of data integrity is viewed very seriously by the FDA. It considers this as falsification or breach of data and passes heavy strictures on such companies. It initiates a series of penal actions on such companies after comprehensive investigations show lack of data integrity. These are some of the FDA actions that could accrue from data integrity breach:

Another additional enforcement action that could result from this scenario is carrying out a full risk assessment to establish the potential of the data integrity-deficient drug to cause problems for patients who consume their products. And then, the FDA could also suggest management actions that seek to correct the issues arising out of data integrity breach.

Complete understanding of data integrity

A look at the grave consequences arising out of the inability to meet the FDA’s requirements on data integrity points to the absolute need for organizations in any FDA-regulated industry to get a complete grasp of all aspects of data integrity, which will help it to avoid FDA citations. This learning will be imparted at a valuable webinar that Compliance4All, a leading provider of professional trainings for all the areas of regulatory compliance, is organizing.

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Danielle DeLucy, who owns ASA Training and Consulting, LLC which provides Pharmaceutical and Biologics based companies with training and quality systems assistance in order to meet Regulatory compliance, will be the speaker at this webinar. Want to hear from her on how to implement steps for ensuring data integrity? Then, please enroll for this webinar by visiting Management of GMP Data Integrity

Total grasp of cGMP requirements on data integrity

21 CFR Part 11 is only a part of data integrity and security breaches. Data integrity and security breaches can also involve severe cGMP violations. This webinar’s speaker will analyze these and offer information about practices that the participants can review and implement at their own site and identify gaps in their practices. The importance of data integrity in assuring the quality of raw materials, in-process materials and finished goods in the cGMP for FDA-regulated industries will be explained.

These areas will be covered at this webinar:

  • Discover the Criteria for Data Integrity
  • Recognize what needs to be addressed to ensure Data Integrity within a regulated GxP Laboratory
  • Learn about approaches to improve Data Integrity in a Laboratory Environment.

Professionals in the regulated industries, such as Site Quality Operations Managers, Quality Assurance Personnel, Plant Managers and Supervisors, Manufacturing Superintendents and Managers and Regulatory Affairs Managers will find this webinar on implementation and management of cGMP data integrity highly worthwhile.

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Techniques to Follow Which Increase the Confidence in the Audit

Auditing is a very important aspect of quality in all the areas of the medical sciences. An audit is the most reliable and foolproof method for evaluating the extent to which the various activities in an organization comply with the requirements and expectations the principal has from those to whom various processes are outsourced. Audits are the main tools for a quality unit to monitor and ensure that those activities are performed in compliance with the manufacturer commitments for quality and regulations.

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An audit is also essential to ensure that the organization meets guidelines set out by the regulatory authorities. Its uses are more pronounced in areas such as medical devices, clinical research, pharmaceuticals, and other areas of the life sciences which require adherence to very accurate and rigorous standards of processes, procedures, quality and policies.

Further, audits are also conducted to assess the quality of material supplied by vendors, who could be from fields as varied as accounting to software to claims settlements to medical products. In this era of outsourcing, it is but natural to expect players in the healthcare industry to outsource several of their activities for a number of reasons.

An audit is extremely crucial in all these activities in the life sciences industry, because it helps to control quality and save costs and many troubles that could come up if the processes are not adhered to. Outsourcing only saves the manufacturer or the provider the trouble of having to do many activities by himself; it does not absolve him of the legal responsibility. The law is very clear on this: Whenever there is noncompliance with the regulatory guidelines; it is the principal, or the provider, on whose shoulders the blame squarely lies.

An audit is effective, but only if done rightly

It is for this critical reason for which audits have to be performed, both internally and externally. But then, an audit can fail too, if it is not done properly. In the field of medical sciences, there are well-established good practices and best practices in many areas, such as Good Manufacturing Practices, Good Laboratory Practices, and so on, but there is no such convention as a Good Auditing Practice. This makes the voluntary inculcation of best practices an imperative for professionals in the areas of medical auditing.

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This is of extreme importance considering that most areas of the medical sciences deal with human lives. A high value is attached to audit practices, as an error from any of them, such as Contract Manufacturing Organizations (CMO’s), subcontractors, and suppliers of many items can have very bad consequences.

 

A learning session on auditing of CMO’s

The concept of Good Auditing Practices may not have evolved yet, but guidelines, techniques, and practices are in place to ensure that the audit meets its requirements and fulfils its objectives relating to quality.

Want to explore the matters that go into making medical audits successful and how to audit CMO’s to ensure that the products and processes required in a number of areas of the life sciences comply with the regulatory guidelines? Then, a webinar from Compliance4All, a leading provider of professional trainings for all the areas of regulatory compliance, will help you do this.

This webinar will have Eyal Learner, who is owner of ELC Consulting Services, which offers the pharmaceutical and medical devices industries support in all quality related issues, as the speaker. To gain insights into how to carry out audits and ensure an effective means of evaluating compliance with the objectives of the Quality System,  especially when it concerns suppliers and outsourcing operations like CMO’s, service providers, sub-contractors and raw materials suppliers; please register for this webinar by logging on to 3rd Party and Subcontractors

Helping auditing serve its purpose

At this webinar, Eyal will explain the vital purposes of auditing and the ways of ensuring compliance with the quality and regulatory standards set out by the regulatory agencies using the right auditing techniques. He will show practical aspects of auditing. Although auditing is based on set principles and is a well-planned activity; auditors have to contend with changes that keep coming up abruptly, unannounced.

Auditors need to be prepared for handling such situations, which is what Eyal will help understand. He will explain the audit techniques and skills needed in situations like this and show ways by which to make the audit to be successful and efficient. This course is particularly aimed at auditors, potential auditors and auditees working for the pharmaceuticals, medical devices, and API and Excipients industries.

Eyal will cover the following areas at this webinar:

  • Short regulatory overview on external audits
    • GMP Requirements
    • Types of Audits
    • Rights & Duties
  • Planning
  • Off-site Assessment
  • Prefaces to Audit Techniques
  • General Techniques
  • Specific Techniques
  • FDA’s Quality System Inspection Technique (QSIT)

CAPA and Follow-up.

The GDPR differs Significantly from EC Data Protection Directive 95/ 46

The General Data Protection Regulation (GDPR), which has been codified as Regulation (EU) 2016/679, is a very powerful law regarding the protection of data of the half billion people who live in the European Union (EU). Having come into effect as a result of the European Commission having adapted the proposal for its creation on January 25, 2012; it will replace Directive 95/46/EC, the data protection directive that has been in use in the EU since 1995.

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The GDPR becomes a full-fledged law and is enforceable from 25 May 2018. This is after it goes through a two-year transition period from its adaption date of 27 April 2016.

The GDPR doesn’t require members to endorse it

Just how powerful is this regulation? Well, an idea of its overarching potency can be understood from the fact that it becomes law and will be binding from the date of its enforcement without requiring legislative support from any of the EU members.

Rationale for the creation of the GDPR

The GDPR has been created for the purpose of harmonizing and strengthening all the legislative and secretarial bodies of the EU, namely the European Parliament, the Council of the European Union and the European Commission, and to tighten the various fragmented elements concerning data protection for all individuals within the European Union (EU). The GDPR also governs the export of personal data to regions beyond the EU.

It is being created to serve two important purposes:

  • Equipping EU citizens the power to control their personal data
  • Smoothening the regulatory environment and synchronizing and unifying all regulations concerning data protection regulations across the EU, and lubricating the process of doing global business within the EU.

What benefits does the new legislation offer?

The GDPR has been legislated to offer many advantages:

  • Within the company, Personally Identifiable Information (PII) will be processed with greater ease and clarity
  • The security controls in place till now will be unified and strengthened across all the EU members
  • Its stronger safeguards for data protection inspire greater customer confidence
  • The process of doing business in the EU is now a lot more simplified

What happens when companies fail to comply with the GDPR rules?

The EU mandates strict penalties for companies that fail to comply with the GDPR provisions on data protection provisions on data protection:

  • They have to pay penalties of between two and four percent of their worldwide revenues
  • Fines can go up € 20 million
  • The EU laws can initiate serious and expensive lawsuits
  • All these mean that companies obviously lose face

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These are the reasons for which companies that want to do business in the EU need to have thorough knowledge of this law and the ways in which it applies to them. This is the means to avert the expensive consequences that follow from noncompliance.

 

Proper understanding of the ways in which the GDPR works

Compliance4All, a leading provider of professional trainings for all the areas of regulatory compliance, will be offering a clear and thorough understanding of this new legislation at a webinar that it is organizing. Founder of GO DPO® and the Co-Director of the GDPR Transition Programme at Henley Business School and one of the leading data protection practitioners in Europe, Ardi Kolah, will be the speaker at this session.

Want to understand how Ardi will bring the varied and rich experience he has gained over the years into this very important topic? Then, please register for this webinar by visiting Features including a risk-based approach

Ardi will show how important it is for Data Controllers, Joint Data Controllers and Data Processors to address all the points relating to business continuity, risk and technology if they have to achieve the outcomes expected by the Supervisory Authorities and Industry Regulators. He will explain how to use this knowledge to build deeper trust with customers, clients, supporters and employees and a strong reputation.

The following areas will be covered at this webinar:

  • Difference in scope between Directive 95/46/EC and key data protection principles
  • Expanding the definition of personal data and special personal data
  • Enhanced individual Data Protection Rights
  • Key organisational and Personnel Changes
  • Mandatory personal data Breach Reporting
  • Global personal Data Transfers outside of the EEA and co-operation between Supervisory Authorities
  • New financial Penalties and Sanctions
  • Member State laws and the GDPR.

7 Keys to Compliance Excellence that Form the Foundation for Any Excellent Organization

In any industry, compliance is everything; be it highly specialized fields such as the life sciences, healthcare, medical devices or non-technological areas such as food and clothing. Why do companies need to be compliant? It is simply because being in compliance with the required regulatory requirements helps the organization to achieve the most positive outcomes needed for a business:

  • It earns them a good reputation
  • Increases stakeholder and customer confidence
  • Augments the value of their products or services
  • Improves performance and operations
  • Maximizes profits
  • Guarantees that they adapt the right processes.

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Meeting the appropriate compliance requirements is mandatory for the regulated industries. This fact is known, but the challenge is in implementing the measures needed for achieving compliance. A compliance program that is built into the organization’s processes and of which it is an inseparable part is the way to go about achieving compliance.

A very comprehensive term

Compliance is a very broad and huge term into which many aspects are built. Compliance has to be shown at all levels by an organization if it has to achieve its outcomes and help the organization fulfil its business and other objectives. Many organizations are somewhat lackadaisical in their approach to compliance, thinking that it is an auxiliary function and not a core business activity. They cannot be more mistaken.

It is more than just a duty that needs to be completed to satisfy regulators. An organization should strive to reach levels of excellence in compliance. Those who fail to do this are not aware of the colossal opportunity they miss to stay ahead of the competition. Excellence in compliance opens the key to several unimaginable opportunities. It leads to high levels of positive results. Achieving levels of excellence at compliance standardizes and optimizes processes and makes them safe, reliable and efficient.

Understand how to achieve excellence in compliance in all its depth

Want to understand how to achieve this in all detail? Then, you could enroll for a highly educative and informative webinar on this topic that Compliance4All, a leading provider of professional trainings for all the areas of regulatory compliance, is organizing. Please register for this webinar by visiting Achieving Compliance Excellence

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Charles H. Paul, who is the President of C. H. Paul Consulting, Inc., a regulatory, manufacturing, training, and technical documentation consulting firm that works with both domestic and international clients designing solutions for complex training and documentation issues and is celebrating its twentieth year in business in 2017; will be the speaker at this webinar. A regulatory and management consultant and an Instructional Technologist for 30 years; Charles has published numerous white papers on various regulatory and training subjects.

Seven keys to compliance excellence

At this course, Charles will explain the seven critical keys to achieving compliance:

  • Understanding the regulations that pertain to one’s industry and business throughout each level and function of one’s organization
  • Defining the critical processes relative to the regulatory path that has been chosen
  • Developing sound regulatory documentation
  • Harmonizing processes and procedures between plants
  • Committing to and executing comprehensive technical training
  • Instituting a sound and effective complaint and investigations handling process
  • Managing performance up and down the line to the performance structure created. If it is not managed it will not be performed.

At this session, which will be ideal for Directors, Managers, Scientists, Technicians and Associates; Charles will cover the following areas:

  • Understanding the Regulations that Pertain to your Industry and your Business throughout each Level and Function of your Organization
  • Defining your Critical Processes and why that is important
  • The Benefits of Developing Sound Regulatory Documentation
  • Why Harmonizing your Processes is Critical to Consistency in Operations and Regulatory Compliance
  • Why Technical Training is Essential to every Aspect of Business Operations to include Meeting and Exceeding Regulating Requirements
  • Institute a Sound and Effective Complaint and Investigations Handling Process
  • Performance Management – the glue that holds everything together and Guarantees Acceptable Performance throughout the Organization.

Understanding and applying ICH Q3A and Q3B

The ICH Q3A and Q3B are guidances on dealing with impurities in new drug products. These documents have been issued by the FDA and are updates of earlier versions on the same topic that were prepared by the ICH, which this FDA guideline complements. This is why the documents get their name. The FDA keeps revising these documents from time to time. After every revision, the latest version carries the added taxonomy of “R” to denote that the guidance is a revised one.

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The Q3A and the Q3B are two revised guidelines that relate to impurities in drugs. Impurities can happen due to a number of reasons. These are some of them:

  • Raw materials
  • Byproducts
  • Residual solvents
  • Reagents
  • Product reactions
  • Catalysts
  • Foreign impurities
  • Product degradation

The ICH guidelines Q3A and Q3B deal with the ways of addressing organic and anorganic substances, respectively.  They both follow the principles of reporting, identification and qualification of impurities at defined limits. They both exclude impurities arising out of the excipients of drug products.

Scope of Q3A

The scope of the Q3A guideline is limited to testing of impurities in new drug substances. It concerns itself with the content and qualification of chemical substances in new drugs. It is not meant for products derived from herbal, crude, animal or plant, or semi synthetic origin. It is also not for products in the clinical trial stage or for addressing extraneous contaminants, polymorphic forms or enantiomeric impurities.

Scope of Q3B

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The scope of the Q3B guideline differs in some ways from that of Q3A. It is meant for the content or qualification of degradation products. It excludes products of all the sources that Q3A does, and additionally also excludes impurities arising from excipients or extractables/leachables of the container closure system.

Thorough and full understanding of these guidelines

It is to offer a complete and thorough knowledge of how to apply the Q3A and Q3B guidelines that Compliance4All, a leading provider of professional trainings for all the areas of regulatory compliance, will be organizing a webinar. Greg Martin, who is the President of Complectors Consulting (www.complectors.com), which provides consulting and training in the area of Pharmaceutical Analytical Chemistry and served as Director of Pharmaceutical Analytical Chemistry (R&D) for a major Pharma company for a number of years during his over 25 years of experience in the pharmaceutical industry; will be the speaker at this webinar.

To gain clear insights into how these ICH/FDA guidelines apply to your laboratory or area of work, please register for this webinar by visiting Applying ICH Q3A and Q3B for Control

All about the guidelines and regulatory expectations

The objective of this webinar is to provide participants with an understanding of the regulatory expectations for controlling impurities and degradants, including DNA reactive/potential genotoxic impurities, in drug substances and drug products.

Participants who complete this course will be able to:

  • Understand regulatory expectations regarding impurities, degradants and potential genotoxic impurities in pharmaceuticals
  • Understand what specifications will conform to regulatory expectations
  • Develop a process for reporting impurities and addressing OOS situations

Greg will cover the following areas at this webinar:

  • Landscape of impurities requiring control in pharmaceutical products
    • General impurities: elemental impurities, residual solvents, microbiological
    • Drug-related impurities process impurities, degradants, potentially genotoxic impurities
  • Process Impurities
    • Understanding ICH Q3A
    • Where impurities originate
    • How impurities are characterized
    • How specifications are developed
    • How impurities should be reported
  • Degradants
    • Understanding ICH Q3B
    • Where degradants originate
    • How degradants are characterized
      • Potential genotoxic impurities
    • How specifications are developed
    • How degradants should be reported
  • Questions and discussion

How to create processes and procedures to implement them

Product Risk Management is a critical aspect of ensuring medical devices are safe and effective for intended uses. This course will help you understand the regulatory requirements, including ISO14971.

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You’ll learn techniques that can help you identify hazards and potential harms. You’ll learn how to mitigate risk and effectively monitor risk to ensure your customers receive safe and effective products. A rigorous risk management process can prevent serious problems and costs for your company.
In this webinar we’ll cover:

  • Overview and Definitions
  • FDA Expectations
  • ISO14971 Regulation
  • Linkages to Design Controls, Production Controls, Investigations, and CAPA
  • Risk Management throughout the product lifecycle
  • Common mistakes
  • Best Practices

Many companies have even experienced class action law suits because of product quality issues. An effective program of risk management can help you proactively identify and mitigate product risks. A good risk management process can help you methodically identify, mitigate, and monitor risk throughout the product life-cycle. By visiting this Management Techniques for Medical Devices

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Here the areas will be covered by the Susanne Manz

  • Overview of the ISO14971 standard as it applies to medical device companies
  • Integrating the new standard with ISO 13485 as part of your overall QMS
  • Conducting a review of the intended use of your device
  • Stages of Risk Management as well as Tools and Techniques
  • Identifying hazards in your product or production process, and estimating their severity
  • Judging the probability that harm may occur from those hazards
  • How to control those risks and monitor the effectiveness of the controls put in place

Those who will be benefited by the session as listed in the below

  • Design Engineer
  • Manufacturing Engineer
  • Quality Engineer
  • R&D Personnel
  • R&D Project Managers
  • Quality Managers
  • Auditors
  • Regulatory Affairs Specialist
  • R&D Manager

It offers professional trainings for regulatory compliance professionals and offers innovative strategic consulting and advice to a broad range of organizations. These services help them to be compliant with regulatory requirements.

Susanne Manz MBA, MBB, RAC, CQA is an accomplished leader in the medical device industry with emphasis on quality, compliance, and six sigma. She has an extensive background in quality and compliance for medical devices from new product development, to operations, to post-market activities. While at GE, J&J, and Medtronic, Susanne worked in various world-wide roles including Executive Business Consultant, WW Director of Quality Engineering and, Design Quality, and Director of Corporate Compliance. Susanne has a BS in Biomedical Engineering and an MBA from the University of NM.

Understanding GLP’s and their relationship with GMPs and SOP’s

Good Laboratory Practices (GLP’s) are a series of federal regulations passed in the US by the FDA under 21 CFR Part 58. In addition, Environmental Protection Agency (EPA) also has formed GLP’s both for Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) in 40 CFR Part 160 and for Toxic Substances Control Act (TSCA) in 40 CFR Part 792.

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GLP’s are Quality Systems that relate to the processes and conditions that organizations carrying out nonclinical studies concerning health and the environment have to comply with. The objective of creating these processes and conditions is to ensure proper planning, performance, monitoring, recording, archiving and reporting of these studies. GLP’s are not just guidelines; they have the effect of a law.

The intention of framing GLP’s is that a minimum standard has to be established for conducting nonclinical laboratory research. This acts as the basis for research or marketing of products that are regulated by the FDA or the EPA. Typically, products that come under GLP’s include:

  • Animal food additives
  • Medical devices that are meant for human use
  • Biological products
  • Pesticide products
  • Human and animal drugs
  • Electronic products

Cosmetic products do not come under GLP’s.

An understanding of GMPs

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Good Manufacturing Practices or GMPs are quality assurance standards which ensure that consistency and control go into the manufacture of products and that these products are in accordance with their quality standards that are required for their Intended Use and in conformity with the Market Authorization or the specifications that the product has to have.

What are SOP’s?

Standard Operating Procedures (SOP’s) are detailed written instructions that are aimed at bringing about maximization of safety and efficiency in the operations of select types of organizations such as:

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  • Pharmaceuticals
  • Clinical research
  • Emergency response
  • Government
  • Power

 

 

 

 

How are GLP’s related to GMPs and SOP’s?

Do GLP’s, GMPs and SOP’s have a close relationship with each other? How are they, all being vital elements of the industries to which they relate, connected with each other? GLP’s have nothing to do with GMPs, but what about SOP’s? What is the nature of the similarities between these and what are their differences?

This will be the important learning a webinar from Compliance4All, a leading provider of professional trainings for all the areas of regulatory compliance, will offer. At this webinar, the speaker is Joy McElroy. During the over 20 years of working in the pharmaceutical and biotech industries, Joy has gained extensive knowledge of Quality Assurance, Process and Cleaning Validation, and Equipment Qualification, which has enabled her to write and execute Equipment Qualification and Validation Protocols for several well-known companies.

To comprehend the nature of the relationship between GLP’s, GMPs and SOP’s, please register for which webinar by visiting Associated with GMPs and SOPs

Comparison and differences between GLP, GMP and SOP

Professionals such as Quality Assurance Personnel, Quality Control Personnel, Research and Development Personnel, Regulatory Affairs Personnel, Project Managers, Manufacturing Managers, Validation Engineers, Internal Auditing Personnel, Microbiology Personnel and Auditors will learn everything from:

  • What GLPs are
  • Why they were created
  • The objective of GLP’s
  • How they relate and are associated with GMPs.

Joy will explain what GLP’s are and help participants understand and compare the differences with GMPs.