fda inspection prep and execution...•review audit findings, regulatory intelligence •gap...

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FDA Inspection Prep and Execution From a Site Perspective Joe Wesling

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Page 1: FDA Inspection Prep and Execution...•Review Audit Findings, Regulatory Intelligence •Gap Analysis •Facility walkabout •Employee meetings •Out put – Hot Stories •Identify

FDA Inspection Prep and Execution

From a Site Perspective

Joe Wesling

Page 2: FDA Inspection Prep and Execution...•Review Audit Findings, Regulatory Intelligence •Gap Analysis •Facility walkabout •Employee meetings •Out put – Hot Stories •Identify

Site Preparation and Inspection Performance

Regulatory Inspection

Page 3: FDA Inspection Prep and Execution...•Review Audit Findings, Regulatory Intelligence •Gap Analysis •Facility walkabout •Employee meetings •Out put – Hot Stories •Identify

• Review Audit Findings, Regulatory Intelligence

• Gap Analysis

• Facility walkabout

• Employee meetings

• Out put – Hot Stories

• Identify Team and roles

• Site Resources

• Execution

Site Prep

Page 4: FDA Inspection Prep and Execution...•Review Audit Findings, Regulatory Intelligence •Gap Analysis •Facility walkabout •Employee meetings •Out put – Hot Stories •Identify

Review 483 and warning letter trends. Know areas of focus

Inspector profiles

Prep-Risk Management

Page 5: FDA Inspection Prep and Execution...•Review Audit Findings, Regulatory Intelligence •Gap Analysis •Facility walkabout •Employee meetings •Out put – Hot Stories •Identify

• Gap Analysis – QMS review by the process owner

Prep-Risk Management

Page 6: FDA Inspection Prep and Execution...•Review Audit Findings, Regulatory Intelligence •Gap Analysis •Facility walkabout •Employee meetings •Out put – Hot Stories •Identify

Facility walk-through by management

• QMS focus

• Visual Controls

• 5-S

• Environmental controls

• Safety

Prep-Risk Management

Page 7: FDA Inspection Prep and Execution...•Review Audit Findings, Regulatory Intelligence •Gap Analysis •Facility walkabout •Employee meetings •Out put – Hot Stories •Identify

Engage all employees

• Ideas

• Problems

• Quality Policy and Objectives

• Can the identify the management rep?

• Where are work instructions?

• Auditee Training

Prep-Risk Management

Page 8: FDA Inspection Prep and Execution...•Review Audit Findings, Regulatory Intelligence •Gap Analysis •Facility walkabout •Employee meetings •Out put – Hot Stories •Identify

Know your weaknesses

Previous Audit Findings including near misses

Develop Hot Stories – Identify SMEs (and backups).

Prep-Risk Reduction

Page 9: FDA Inspection Prep and Execution...•Review Audit Findings, Regulatory Intelligence •Gap Analysis •Facility walkabout •Employee meetings •Out put – Hot Stories •Identify

Front Room Speaker, Back Room Manager, Scribes, SMEs, Runners

IT and other support, Presenters, Tour Guide/Speakers

BACKUPS!

Lunch!

Prep – Site Team

Page 10: FDA Inspection Prep and Execution...•Review Audit Findings, Regulatory Intelligence •Gap Analysis •Facility walkabout •Employee meetings •Out put – Hot Stories •Identify

No Mobile Phones

No Social Media

May need to work extended hours

May need to work late to get info for the next day

Performance The Inspection

Page 11: FDA Inspection Prep and Execution...•Review Audit Findings, Regulatory Intelligence •Gap Analysis •Facility walkabout •Employee meetings •Out put – Hot Stories •Identify

Develop Work Instruction for how to receive the Inspector.

Check list at reception desk with names and phone numbers for who to contact (Backups)

Physical Location Front Room – Close to the entrance

Crash Cart

Prep

Page 12: FDA Inspection Prep and Execution...•Review Audit Findings, Regulatory Intelligence •Gap Analysis •Facility walkabout •Employee meetings •Out put – Hot Stories •Identify

Engage top management

Presentation for opening meeting

Org Chart – Maintained

Clearly Communicate focus of the business

Clearly communicate the QMS

Prep

Page 13: FDA Inspection Prep and Execution...•Review Audit Findings, Regulatory Intelligence •Gap Analysis •Facility walkabout •Employee meetings •Out put – Hot Stories •Identify

Plant tour

Planned route, SMEs at specified spots along the route

Write a script and stick to it

Practice monthly

Prep

Page 14: FDA Inspection Prep and Execution...•Review Audit Findings, Regulatory Intelligence •Gap Analysis •Facility walkabout •Employee meetings •Out put – Hot Stories •Identify

Front Room

Back room

IT, Wi-Fi, Printers, consumables,

Hard Copies of Procedures

Project Questions on Screen

Question - Form

White boards – New Questions, Assigned, QA, Front Room Ready

Prep

Page 15: FDA Inspection Prep and Execution...•Review Audit Findings, Regulatory Intelligence •Gap Analysis •Facility walkabout •Employee meetings •Out put – Hot Stories •Identify

Mock Inspection

Prep

Page 16: FDA Inspection Prep and Execution...•Review Audit Findings, Regulatory Intelligence •Gap Analysis •Facility walkabout •Employee meetings •Out put – Hot Stories •Identify

Reception – Notify Leadership

Check credentials

Form 482, Notification to Inspect

Performance Receiving the Inspector(s)

Page 17: FDA Inspection Prep and Execution...•Review Audit Findings, Regulatory Intelligence •Gap Analysis •Facility walkabout •Employee meetings •Out put – Hot Stories •Identify

Mobilize the team

Front Room

Back Room

Scribes, escorts, runners, SMEs

Chat from front to back by scribe

Use of question boards

Chat to all interested parties

Performance The Inspection

Page 18: FDA Inspection Prep and Execution...•Review Audit Findings, Regulatory Intelligence •Gap Analysis •Facility walkabout •Employee meetings •Out put – Hot Stories •Identify

483s

List of questions

Notes

Near misses

OFI

Op Mech for readiness

Communicate to the team and extended team

Post Inspection

Page 19: FDA Inspection Prep and Execution...•Review Audit Findings, Regulatory Intelligence •Gap Analysis •Facility walkabout •Employee meetings •Out put – Hot Stories •Identify

FDA History

State of the QMS - Prep

Team Resources

Site Resources

Inspection Performance

Post Inspection

Recap

Page 20: FDA Inspection Prep and Execution...•Review Audit Findings, Regulatory Intelligence •Gap Analysis •Facility walkabout •Employee meetings •Out put – Hot Stories •Identify

Joe Wesling

[email protected]

812-339-2235 x-104389

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