Meeting labeling requirements of various drug products

Both the FDA and the European Medicines Agency (EMA) have regulations that cover the labeling requirements of both prescription and over-the-counter (OTC) drugs, cosmetics, generics, medical devices, nutraceuticals and other related products. These regulations have to be strictly complied with. 21 CFR under its various parts, the Federal Food, Drug, and Cosmetic Act (FD&C Act) and Fair Packaging and Labeling Act (FP&L Act) are the laws that manufacturers of these products need to comply with in order to meet labeling requirements of these products. These laws are separately made for a number of products and their subcategories, such as drugs, cosmetics, cosmetics that are also drugs, and so on. In addition, the regulations set out by the EMA also need to be complied with by manufacturers of these products, if they plan to market to the EU markets.

One of the elementary requirements of the FDA is that the ingredients of the cosmetics must be declared prominently. By this definition, the prominence should be such that users should be able to see the declaration when they purchase and see the product. The FDA prescribes that the letters in the ingredient declaration should be not less than 1/16 of an inch in height. In cases where the total package surface available for labeling is less than 12 sq. inches, the height of the letters must be at least 1/32 of an inch.

Particular about the specifications

The FDA also requires that the ingredients must be declared in descending order of importance. Color additives must be declared too, but does not require an order of prominence. The active ingredients, as well as the additives, must be clearly declared. Labels should carry warnings when they carry ingredients that are likely to cause damage to some or another part of the body. Products such as aerosols, deodorant sprays used by females, and soaps and other cosmetics used by children have their own labeling requirements.

If all this is a snapshot of the only the prominent labeling requirements for just cosmetics, imagine the kind and variety of requirements that need to be met for all other related products such as medical devices, drugs, vitamin supplements and many others. And what about understanding the EMA’s requirements?

Knowledge of the labeling requirements of the products need not be intimidating, because this is the content of a webinar from Compliance4All, a leading provider of professional trainings for all the areas of regulatory compliance.

Learning session on labeling

The speaker at this webinar is Salma Michor, who is founder and CEO of Michor Consulting Schweiz GmbH, which serves such clients as Johnson & Johnson, Novartis, Shire, Pfizer and Colgate Palmolive. The full extent of Salma’s experience will come into play at this webinar. To register for this session and to benefit from the wealth of Salma’s experience, please register by logging on to Labeling Drug Products

This webinar will focus its attention on the ways by which to remain compliant with the labeling requirements of the various regulatory bodies vis-à-vis a number of products. Salma will explain the challenges associated with remaining compliant with the labeling requirements of products such as generics, prescription drugs, OTC drugs, medical devices, vitamin supplements, traditional herbal remedies, foods, cosmetics and biocides, and will suggest ways of dealing with them. She will focus in particular on the EU requirements for labeling of these products. Regulatory Affairs and labeling specialists will understand the intricate details of the labeling requirements for these products at this webinar.

Paper records to electronic for pharmaceutical companies

Following the rapid advances being made in the field of information management in the past quarter of a century or so, computers have increasingly come to replace paper as the source in which important documents are created and stored. Till the last decade of the previous century, organizations used paper to record and document information relating to their research, development and business. From around the start of the 1990’s; the shift towards computerization of paper records has been noticeable.

Many differences between paper and electronic records

One of the defining differences between this electronic standard and traditional paper records is that while the latter used to be stored in a central, protected environment and managed by a designated managers; electronic records are spread over many locations.

Although some are managed by a central authority; most are under the control of individuals. Individuals in charge of this work have a wide range of computer based devices such as phones, laptops, tablets and USB storage devices at their disposal, which can be used for functions such as authoring, storing, and copying and transmitting relevant information.

Also, the information available on these systems can be stored and shared within several locations on the web, with the option of protecting some better than others. What has also changed substantially is the process of verifying the authenticity of a record. Earlier, the method used to authenticate paper records was via inked signatures of the author and witness. Encrypted e-signatures are replacing this practice.

Submissions to the regulatory authorities

In line with this development, the FDA and other global regulatory agencies started accepting electronic files, or at least parts of submissions, for testing and marketing drugs. This movement, which started in the early 1990’s, led to the creation of the Common Technical Document (eCTD) standard. This standard is now required in the US and most countries around the world.

If pharmaceutical and life sciences companies have to submit documents such as the NDA, ANDA, IND, BLA, DMF and the BMF to the FDA electronically, the eCTD has been the pan-industry, widely accepted standard since 2008. Submissions are, in fact, no longer done via paper records. If companies have to incorporate legacy paper records into an eCTD; they have to scan those and put them into a text readable format.

A source of important information

Despite the existence of this method; many companies continue to possess huge troves of paper based information, which are yet to enter the cyber realm. These records contain important information relating to the pre-clinical, clinical and drug safety paper records of drugs that did not make it to the marketing stage for a variety of reasons, because of which these companies have archived this information.

This archived data, if harnessed effectively, could be a rich source for offering knowledge that will go on to enhance inputs for submissions for other new or emerging indications for the drug or support efficacy or safety for related drugs. Many organizations have a large collection of paper records with retention times of 50 years or more. There is a dilemma of how to best preserve and utilize these records.

What is the way of going about for transiting?

Many companies are in a quandary about what to do in a situation in which the majority of records are electronic, but a substantial number remain as aging paper records. If the wealth of information available in paper format is to be exploited meaningfully, should they convert all the paper records to an electronic format, convert some of them, or just leave them in their current form? Given that complete conversion and subsequent integration is a very expensive and laborious exercise; a better option will be to convert on an as-needed basis.

The ways of how to do this effectively will be the topic of a highly educative webinar from Compliance4All, a provider of professional trainings for all the areas of regulatory compliance. At this webinar, Dr. Charlie Sodano, an experienced, globally recognized information management professional who launched eOrganizedWorld a consulting firm specializing in the planning and implementation of records and information management systems, will be the speaker.

To understand and have these issues resolved from the expert, please register for this webinar by logging on to Records policy and procedures

Dr. Sodano will take up and explain the issues relating to conversion of paper records into electronic, and the ways in which the submissions need to be made. This training is of importance to professionals in Research & Development, Regulatory, Clinical, Legal, Information Technology and Validation.

During the course of this session, Dr. Sodano will cover the following areas:

o  Records policy and procedures

o  Records data map

o  Incorporating paper records into a eCTD

o  Converting paper documents into a useful electronic format

o  Scanning costs and resources

o  Indexing and organizing scanned records and integrating them

o  Long term record storage and retrieval.

How does the FDA scrutinize Promotion?

The FDA has strict requirements on the way promotion and advertising practices are to be implemented by the industries that it regulates. Section 906 of the Food and Drug Administration Amendments Act (FDAAA), which came into effect in 2008 and amended the section that pertained to this topic previously, namely Section 502(n) of the Federal Food, Drug, and Cosmetic Act (FDCA); now requires that published Direct to Consumer (DTC) advertisements for prescription drugs should include the following statement printed conspicuously for all products including vaccines:

“You are encouraged to report negative side effects of prescription drugs to the FDA. Visit http://www.fda.gov/medwatch, or call 1-800-FDA-1088.”

One of many requirements

This is just one of the many requirements from the FDA about promotion and advertising practices. Any individual or company holding an approved application for a drug will be panelized for making a false or misleading claim in a Direct to Consumer (DTC) advertisement about the pharmaceutical product.

Such an entity can be fined up to a quarter of a million dollars for the first such violation in any three-year period. This fine can go up to half a million dollars for each subsequent violation in any three-year period. Further, the FDAAA fixes different levels of penalties for biological products.

New requirements that reinforce existing ones

In addition, the FDA issued two Draft Guidance documents in January 2017. These concern communications made by device manufacturers about information that is contained in the labeling of these products. The nub of these Guidance Documents is that for FDA-regulated medical device companies to escape enforcement actions from the regulatory agency; labeling has to be consistent with the standards and expectations set out by the FDA. It lists out a number of factors the FDA takes into consideration to determine if the labeling meets the standards of consistency set out by it. These are some of them:

o  Indication

o  Patient Population

o  Limitations and Directions for Handling, Preparing, and/or Using the product

o  The recommended dosage or use regimen or route of administration

o  The potential for increasing harm

o  Safe and effective use.

The FDA has, in this communication also set out the factors that it does not consider as being in line with its idea of consistency in labeling and false claims:

o  Stage, severity, or manifestation of disease

o  Use alone versus in combination with other product(s)

o  Route of administration

o  Strength, dosage, or use regimen

o  Dosage form.

This makes the grasp and proper implementation of the FDAAA requirements absolutely essential if an organization in the FDA-regulated industries has to be free of enforcement actions from the FDA and subsequent penalties.

Learning session on how to get the dynamics of FDA scrutiny of promotion and advertising practices right

This is the important learning a webinar from Compliance4All, a highly acclaimed provider of professional trainings for all the areas of regulatory compliance, will be offering.

The speaker at this webinar is Casper Uldriks, who through his firm “Encore Insight LLC,” brings over 32 years of experience from the FDA. He brings the experience of having specialized in the FDA’s medical device program as a field investigator, a senior manager in the Office of Compliance and an Associate Center Director for the Center for Devices and Radiological Health. To gain understanding and clarity on these areas of FDA scrutiny of promotion and advertising practices, enroll for this webinar by logging on to FDA Scrutinize Promotion and Advertising Practices

Anticipate the FDA’s viewpoint of consistency

Anticipating the way the FDA will view and interpret its advertising and the way it monitors this activity is critical for any company that makes a marketing launch. If it fails to do this right, it could land itself in trouble and invite expensive and reputation-damaging enforcement actions. Companies that come under FDA regulation need to have a perfect grasp of what they are doing with DTC advertising and should not leave anything to chance.

Companies have to keep up with the defined boundaries of DTC advertising and promotion if they have to avoid FDA scrutiny. If the FDA deems a DTC marketing campaign to be misbranding the product, it will not allow it to be marketed. This calls for more sophistication and novelty on the part of firms in their advertising methods and messages. Firms need to pay attention to all the components of their advertising in mass media, such as volume, images, the prominence and conspicuousness of information, the speed of the message, subliminal messaging and the core message.

Get all the factors right to avoid FDA enforcement

This calls for a proper understanding of what each component of the advertising attempts to accomplish and then evaluate the integrated message. Ironically, this range of factors arms the FDA with sufficient ammunition to determine the advertising as misbranding and term it illegal.  The speaker will suggest the ways of tackling issues like this.

Casper will talk about these issues in depth at this webinar. He will cover the following areas:

o  FDA’s approach to DTC advertising and promotion principles

o  FDA guidance and use of cognitive psychology

o  Types of violation for illegal DTC advertising practices

o  The role of sales and marketing departments

o  Executives’ legal liability.

Cash management in ERP systems and Reconciling bank statements

Cash management is a major component in ERP systems such as Oracle. It is a module that offers information about the most critical component of the business, namely cash flow. Cash management processes and analyzes all of the business’ cash and bank transactions from a number of sources such as:

o  The payments made to a supplier as reflected in the invoices

o  The value of receipts got from the business’ sales invoices

o  Single or isolated payments not from any of these above categories

Another important role performed by the cash management module is that using it, the organization’s Finance personnel can analyze financial transactions of all kinds that happened during a selected period of time. Cash management in ERP also gives Finance the inputs that help them understand where the funds are coming in from, and how they need to be allocated and spent so that the company meets its payments-related obligations.

Functionality of Cash Management module

Usually, cash management modules in ERP systems are built to accommodate the following features:

o  Tracking Supplier Payment

o  Tracking the way in which sales invoice amounts receipts are made

o  Helping to forecast the cash flow

A learning session on cash management and bank statement set up and reconciliation

Do all these aspects of cash management sound confusing? It is to address these confusions and issues related to cash management that Compliance4All, a leading provider of professional trainings for all the areas of regulatory compliance, will be organizing a webinar.

Kevin Chenoweth, who has wide-ranging expertise in designing project plans for multi-million dollar Oracle R12 financial leading to under budget and on-schedule projects and has helped organizations complete full life-cycle implementations in the Oracle financials modules through effective leadership, will be the speaker at this webinar.

To hear Kevin offer his insights into cash management, which is a result of his having implemented Cash Management processes for both technology and manufacturing SMB and Fortune 500 companies such as Comcast and having addressed their particular challenges in streamlining their bank account structures and relationships to align them with their changing business structure and accounting systems; just enroll for this webinar by logging on to   http://www.compliance4all.com/control/w_product/~product_id=501331LIVE?Wordpress-SEO

The wealth of the speaker’s experience

During this course, Kevin will offer guidance and understanding about the fundamentals of Cash Management in ERP systems such as Oracle. Another important related activity, namely bank statement formats, will also be discussed, along with how to and when to apply them.

Kevin will discuss all the challenges associated with bank statement set up and reconciliation, namely how to handle various deposits in transit, outstanding checks, service charges, and non-sufficient fees. During this explanation, he will illustrate the experiences he had earlier in his career at organizations such as ComCast, where he helped prepare its merger with Time Warner with important works like streamlining its zero-balance accounts and regional banks.

Kevin will cover the following areas at this session:

o  Bank reconciliations for various types of transactions

o  Streamlining of accounts to match company strategy

o  Consolidation of accounts to match company strategy

o  Preparation of banking relationships for a merger

o  Zero Balance accounts and how to manage them

o  Understanding of cash flows in strategic initiatives

o  How cash flows interact with financial statements

http://www.managementstudyguide.com/cash-management-module-erp.htm

Proper handling of Out of Specification (OOS) result is the hallmark of a robust investigation

The whole exercise of drug making is incomplete and unthinkable without laboratory testing. There is no better indicator of success on the part of the drug manufacturer than this activity. This is absolutely essential as a means for confirming that all the ingredients that make a laboratory product, such as the raw materials used in it, the in-process materials as well as the finished materials that go into it, and containers as well, all kowtow to the set, required specifications. This is why current Good Manufacturing Practices (cGMP) regulations are very stringent and uncompromising when it comes to laboratory testing.

Now, what does a laboratory do when its laboratory testing comes up with an Out of Specification (OOS) result? It is necessary to understand that an OOS is not something that is taken lightly. It is taken very seriously and handled very stringently by the FDA. Being the regulatory watchdog under whose watch the whole range of laboratory activity falls; the FDA is carries out laboratory operations extremely closely. It expects complete and total compliance with its requirements on the way laboratories are expected to investigate Out of Specification and Out-of-Tolerance observation investigations.

Under FDA’s Sec 211.165, cGMP regulations reject any finished Out of Specification products that do not comply with the set specifications, as well as its mandated safety and other quality standards. These cGMP regulations also mandate complete investigation of test results that demonstrate any deviation of the contents of a batch from the specifications. These cGMP rules apply irrespective of whether batches have been released into the market or not.

How do labs deal with OOS results?

The application of current Good Manufacturing Practices into the manufacture of both active pharmaceutical ingredient and finished pharmaceuticals is required under FDA’ Section 501(a) 2 (b) of cGMP guidelines on OOS. OOS testing is mandatory for any batch that is being released.

These are what cGMP regulations require laboratories to do when they observe and confirm an Out of Specification testing compulsory for the release of a test batch: Confirmation of an Out of Specification result causes the batch to get rejected. If a laboratory test result throws up an element of ambiguity, then cGMP regulations require the company’s Quality Assurance (QA) to both mention the reasons for the release and to offer justifications for it.

The FDA guidance on Out of Specification covers human drugs, biology and biotechnological products, combination products, veterinary drugs; type medicated articles, transplantation of human tissues, medicated feed, finished products & active pharmaceutical ingredients and dietary supplements.

A learning session on the vital aspects of OOS

These aspects of OOS results will be the topic of a highly interesting and valuable webinar from Compliance4All, a leading provider of professional trainings for all the areas of regulatory compliance. At this webinar, Danielle DeLucy MS, who is owner of 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.

To enroll for this webinar and to gain complete understanding of how to handle OOS test results, please visit http://www.compliance4all.com/control/w_product/~product_id=501333LIVE?Worpress-SEO

The aim of this webinar is to guide attendees through the entire process starting from detecting an OOS result to launch and completion of informal and formal laboratory and batch investigations. This will help companies understand where they are going wrong, as it has been consistently observed that most companies do have procedures in place, but these are either inadequate or are not followed.

At this webinar, Danielle will professionals in the area of lab testing, such as Quality Assurance/Quality Control Directors, Managers, and Specialists, Regulatory Affairs/Regulatory Compliance Directors, Managers, and Specialists, as well as Quality Control Laboratory Staff the responsibilities of analysts and supervisors. She will also enlighten them about how to listen to what the FDA looks for in terms of human errors, which will give them a good idea of what to do and what to avoid. She will also explain the situations in which a full investigation should be triggered, the frequency for re-testing and re-sampling, and the proper ways of implementing corrective and preventive action (CAPA) plans.

http://www.fda.gov/downloads/drugs/guidances/ucm070287.pdf

http://sphinxsai.com/2013/JulySept13/phPDF/PT=11(943-948)JS13.pdf

The art of writing effective audit observations

Audits are a means of evaluating operations and other functions of an organization. ISO 19011:2011 Guidelines for Auditing Management Systems describes audits as a process used for gathering the evidence of verifiable documents and map their suitability, alignment and fulfilment with the company’s policies and procedures.

An audit is an important tool that helps organizations to analyze opportunities, implement best practices, and assess all the important factors in a business, such as risks, ethics, controls and quality. Conveying these to the management is the primary aim of an audit.

An audit is indispensable for mitigating risks and ensuring governance. An audit can be either:

o  Internal, where an organization’s employees in charge of audits in an organization in charge of audits carry out audits, or

o  External, where an external, independent auditing professional examines and evaluates the company’s functions objectively.

Each of these two types of audits is important. Either of these may be required, or both may be required, depending on the kind of business and practices an organization has.

Broadly, these are the types of audits:

Financial audits: Financial audits, as the name suggests, are related to how an organization keeps financial controls in place and report them to the authorities. Financial audits are summed up in financial statements, which spell out the extent to and the ways by which financial aspects of organizations tally.

Operational audits: These are the audit or assessment and evaluation of how an organization actually carries out its business. Being of this nature; operational audits are concerned primarily with business processes. The aim of operational audits is to suggest ways by which organizations can improve their operations to optimize their businesses and increase ROI.

Compliance audits: These are carried out to ensure the compliance with regulatory requirements in an organization. A number of these regulations need to be complied with depending on the nature and location of business.

Information Systems: Since no organization can stay aloof from automation and since information systems are required for almost all functions in an organization; it needs to systematically and thoroughly review its information systems from time to time. An effective information systems audit takes not only existing, but also emerging technologies into consideration and suggests ways by which to improve its network and firewall its data security.

Integrated Audits: Suggestive of its name; an integrated audit is one that assesses, monitors and controls all the kinds of audits –Financial, Operational, Compliance, and information systems risks. Auditing professionals locate these integrated audits on a business process or cycle or part of it.

Understanding and carrying out operational audits

Operational audits, being among the important kinds of audits, are governed by their own set of standards. They have their own set of standards that need to be complied with. These are set out by The Institute of Internal Auditors (IIA). And, like other types of audits, operational audits require a high degree of knowledge, diligence and skill.

The ways and means of carrying out operational audits can be complex and requires adherence to a number of standards and best practices. Auditors need to be thorough in their understanding of how to do these in an optimized fashion and ensure results for the organization.

Compliance4All, a leading provider of professional trainings for all the areas of regulatory compliance, will be providing this insight at a highly educative webinar. Jonnie T. Keith, who has over 40 years of audit experience and has served as the Chief Audit Executive for the Metropolitan Atlanta Rapid Transit Authority (MARTA) for the past 10 years, will be the speaker at this webinar.

To enroll for this session and to gain from the expertise Jonnie brings into auditing, please visit http://www.compliance4all.com/control/w_product/~product_id=501309LIVE?Linkedin-SEO

A complete roundup of operational audits and the ways of writing audit observations effectively

At this webinar, Jonnie will explain the intricacies of an operational audit. Jonnie will explain the importance and ways of writing these audit observations effectively and compellingly. He will explain the concept and all the important aspects that go into operational audits, such as management responsibilities and the key IIA standards that go into audits and the areas of their purview, such as the following:

2010 – Planning

2201 – Planning Considerations

2220 – Engagement Scope

2240 – Engagement Work Program

2300 – Performing the Engagement

2400 – Communicating Results

2500 – Monitoring Progress

http://asq.org/learn-about-quality/auditing/

https://finance.columbia.edu/content/types-audits

http://www.accountingtools.com/operational-audit

https://na.theiia.org/about-us/about-ia/Pages/About-the-Profession.aspx

Writing error-free procedures while complying with GMP regulations

In the area of GMP regulations, procedures are very vital, for both execution and audits. It is always true that the greater the clarity and comprehensiveness with which these procedures are written; the easier it becomes for users to use them without missing important information for regulators.

Despite the advent of technology into almost all the areas of GMP regulations; there is still the existence of the human factor. It is still the major culprit when it comes to losses that many industries sustain in their quality and production. Technology has pervaded most industries in ways that were not imaginable a couple of decades back; yet, it is not likely that human error will ever be totally eliminated.

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Having said this, it is also true that it is possible to prevent several human performance problems. The starting point of human errors start is the design stage. Human reliability comes into play in a major way in procedures. The key to human engineering, improving and/or fixing and identifying exactly where the weaknesses in the procedures instructions lie is getting a grasp of human behavior and the psychology of error.

A learning session on all the aspects of writing for GMP regulations

An understanding of the weakness in procedures that harm productivity, quality and regulatory standing will be the major learning a webinar from Compliance4All, a leading provider of professional trainings for all the areas of regulatory compliance, will be offering.

The speaker at this webinar is Ginette Collazo, a human error and human behavior expert, who brings vast experience in the technical training, organizational development and human reliability areas. Interested in gaining insights into how to understand and reduce human errors in GMP procedures? Then, all that you need to do is to register for this webinar by logging on to http://www.compliance4all.com/control/w_product/~product_id=501285LIVE?Linkedin-SEO

Discussion of all the areas of human error in writing for GMP regulations

At this webinar, Ginette will discuss everything from content development to formats designed for human error reduction due to procedures. She will start with an outline of SOP writing and describe the role and possibility of human error in content development. She will also discuss the universal purpose of procedures in the background of regulatory compliance.

Ginette will expound the human perspective and the rational for procedure use and describe human error as a root cause. She will also explain the thinking and reading process and touch upon some common mistakes and causes.

Human error rates and measurement, the ways of creating and maintaining a procedure, as well as the goals of a procedure, will all be taken up.

Taking a glimpse at Good Procedure Writing practices

Another of the areas Ginette will traverse during the course of this very interesting session is Good Procedure Writing practices, during which she will dwell upon all its related aspects such as Terminology, Formats, layouts, mixed cases, steps content, common words, references, branching, conditional steps, the use of “Precautions”, “Warnings” and “Cautions”.

Finally, she will also explain procedure styles and the use of electronic information networks for procedure access. All in all, this promises to be a very educative and well-rounded teaching session. All the important people involved in GMP regulation and human factors, such as QA/QC Directors and Managers, Process improvement/excellence Professionals, Training Directors and Managers, those in Plant Engineering, Compliance Officers, Regulatory Professionals, people in Executive Management, Manufacturing operations Directors and Human factors Professionals, will all derive benefits in large measure from this webinar.