fda inspectional and regulatory enforcement trends: key focus on trends in

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Anticipating FDA Warning Letters?

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Understand current Food and Drug Administration (FDA) regulatory guidance as well as current regulatory trends with regards to consent decree.\n - PowerPoint PPT Presentation

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Page 1: FDA Inspectional and Regulatory Enforcement Trends: Key Focus on Trends in

Anticipating FDA Warning Letters?

Page 2: FDA Inspectional and Regulatory Enforcement Trends: Key Focus on Trends in

WHAT IS A WARNING LETTER?

A Warning Letter is issued by the FDA to a

regulated manufacturer if it is found that any significant regulatory

violations have occurred.

Page 3: FDA Inspectional and Regulatory Enforcement Trends: Key Focus on Trends in

Nonconformance with Good Manufacturing Practices (GMP)

False Claims About a Product

Inadequate Training for Personnel

Wrong directions for Use and so on…

Violations Identified in Warning Letters Include-

Page 4: FDA Inspectional and Regulatory Enforcement Trends: Key Focus on Trends in

FDA Has Been Busy! (2000-2015)

300000+ Inspections

170000+ Facilities

130000+ 483S

4500+ Inspectors

Page 5: FDA Inspectional and Regulatory Enforcement Trends: Key Focus on Trends in
Page 6: FDA Inspectional and Regulatory Enforcement Trends: Key Focus on Trends in

What Are The Trends?

Page 7: FDA Inspectional and Regulatory Enforcement Trends: Key Focus on Trends in

Wat

ch O

ut f

or

War

nin

g L

ette

r Si

gns • Long standing internal problems that

have not yet caught the attention of the FDA but are known within the company

• Form 483 notifications (the most obvious predictor of Warning Letters)

• Red flags from the Quality Unit • Adverse events • High volume of customer complaints • Prior investigations about the same

issue or same type of issue • FDA responses to communications

from the company that do not signal satisfaction with issue resolution and so on

• Product contamination • Off-Label Promotional activities that

have caught the attention of the FDA • DDMAC letters • Repeated FDA inspections of facilities