Global collaboration between regulatory agencies and health authorities became of paramount importance during the COVID-19 pandemic. Not only allowed it regulators to continue their inspections and surveillance function, but the cooperation also enabled the rapid development and approval of treatments and vaccines against the coronavirus SARS-CoV-2.
Let's discuss in this article the potential use of statistical analysis to accomplish a computer system validation.
Regulatory bodies like the FDA enact initiatives on a routine basis. While their timing may seem random, such actions are usually driven by logic; most are taken in response to some noteworthy concern.
We know that COVID pushed the digital transformation and the cloud solutions, in combination with the broad access of the Internet, turning data consumption economically capable and available, creating an exceptional volume of data nowadays.
The Quality Systems (QS) Regulations of FDA 21 CFR 820 are general standards that apply to finished devices, that are intended for human use. Rather than impose strict requirements, the regulations offer an opportunity to the manufacturers of these devices to incorporate their quality management standards into key organizational processes.
Let’s start this piece with a question for ourselves: do we still need password expiration as a security measure? In today’s life science industry, especially the pharmaceutical sector, a number of compliance reasons, guidelines, and agency regulations are responsible for an organization’s requirement to have their employees change their passwords every so often. It is now fair to say that we arrived at a point in time where most of the reasons behind the password expiration policy seem obsolete.
According to a report from the US Food and Drug Administration (FDA), major deficiency letters were issued to 67% of premarket approval applications. Such deficiencies in applications can hold up premarket approvals - sometimes more than 180 days.
You have received one of the dreaded FDA Warning Letters. The last thing you want is to delay the launch of your company's latest innovation. However, you cannot risk shutdown for non-compliance and the possibility of never making it to market with your latest brainchild.
The ICH E6 Good Clinical Practice Guideline is a cornerstone in today’s guidance for Good Clinical Practice (GCP). The guidance addresses an international ethical and scientific quality standard for designing, conducting, recording, and reporting trials that involve the participation of human subjects. With the goal to provide a unified standard for all ICH regions to facilitate the mutual acceptance of clinical data by the regulatory authorities in these jurisdictions. As of March 2021, the newest revision R3 is in a draft state, so we took the opportunity to run down the important aspects of Data Integrity and Data Governance inside the first iteration of the ICH E6 GCP principles.
Our last Webinar about data integrity was a great success, and we thank you all for the questions and participation. We believe we can bring value to the industry when we collaborate to give insights and share solutions to our customers' challenges within compliance in Life Science.
The CAPA process from the side of regulatory compliance of both U.S. FDA requirements (21 CFR 820.100) and EU regulatory requirements (ISO 13485, 8.5.2) is one of the most important elements of a Quality Management System (QMS).
It is essential to develop a system the right way to assure QMS effectiveness and minimize irregular findings on regulatory audits.
Blockchain is the technology that created the 128 Bi cryptocurrency market, which is at the heart of Bitcoin and other virtual currencies such as Ethereum, Tether, and more. The Blockchain is an open, distributed ledger that can record transactions between two or more entities in an efficient, verifiable, and permanent way. The ledger itself can also be programmed to trigger transactions automatically (smart contracts).
Speed. It is the deciding factor between hundreds or millions of death cases. In a pandemic, speed is everything. The World Health Organization's (WHO) emergencies program executive director Michael Ryan, a doctor experienced in the Ebola outbreak, rightly said in a COVID-19 press conference that speed trumps everything else in an emergency response. Speed defines life or death. Governments, people, and especially the pharmaceutical sectors must embrace the speed to conquer a pandemic. Countries that are slower to respond are paying a huge price. Speed is everything that includes the pharmaceutical industry as well. What if we could make the vaccine available to the majority within one month instead of 18 months?
Data Integrity in 2020
The year 2020 was a game-changer in many aspects. It has forever altered the way we perceive reality down to every facet of our lives and how we implement our everyday activities. This stands true even more in the healthcare world, which has undergone a tremendous shift in a span of 10 months on a global scale. The world of regulatory affairs and compliance has also undergone some changes that has affected our views on data and our attitude towards data governance and data integrity (DI).
In these times, when everything and everyone is connected to the internet, a large volume of data is generated daily. The good news is, the more information we have, the more chances we have to achieve goals that require that large amount of data and knowledge.
This is why data collection is so important for companies.
Properly managing sensitive information to maintain privacy and security has become paramount in recent years. Today, pharmaceutical companies and medical device manufacturers are increasingly using the Internet to broaden their services making compliance with FDA regulation even more important.
Quality risk management implementation identifies and manages risks; under normal circumstances the risk-based approach to the validation of computerized systems should eliminate the risks to the system, or should at least reduce the risks to a tolerable level. (This tolerable level must naturally be defined prior to the execution of the risk analysis).
Are you sure your IT infrastructures are fully qualified, or is it possible that your methodologies missed some vital detail along the way? Perhaps you know you're good at maintaining infrastructure compliance, but your organization is about to reach its operational limits. Either way, it's time for a serious change.
Data integrity is an ever-increasing concern in life sciences, with medical device manufacturers feeling much of the conformity backlash. There continues to be heightened regulatory focus on diverse cybersecurity topics, including data integrity.
Companies that are regulated by the U.S. Food and Drug Administration (FDA) are required to perform validation to prove their software and systems are performing correctly. That’s why, with relatively few changes, we have been using Computer System Validation (CSV) for over 20 years in the regulated sector. The FDA’s first Principles of Software Validation, and later ISPE GAMP, continue to be the main go-to guidance and principles to help implement CSV.
Currently, digital transformation is a hot buzzword, and it’s something that everyone wants to be a part of, even if they don't understand what it is or what it means. So, what is digital transformation really?
To stay competitive, every organization should consider what they can do to improve the quality of their products and services. In fact, having a clear understanding of your overall quality management system to ensure that you meet or exceed your customer’s expectations is a compelling way to improve your business.
That’s where the ISO 9001 Quality Management System (QMS) comes in.
The ISO 9001 is an internationally-recognized QMS standard that can benefit every organization or company. As a powerful business improvement tool, the ISO 9001 standard sets forth a strong QMS framework that produces many benefits for businesses.
The methodologies your firm employs in the creation of pharmaceuticals, medicines and similar products designed for human consumption are most likely unique. Even if you follow relatively common chemical or physical manufacturing procedures, for instance, you still have to make modifications that fit your specific product design standards.
Pharmaceutical firms that wish to create product lines and cater to consumers as reliably as possible must ensure that their products are of a consistently high enough quality to fulfill user needs. While certain post-production checks and assurances can aid in this area, many organizations find it far more helpful to institute quality by design standards (QbD).
How do you know your life sciences firm is maintaining compliance? While FDA audits and warning letters are obvious indicators, GMP guidelines give you a number of less-stressful ways to determine how well your equipment and processes are performing their tasks and whether they'll continue to do so consistently.
Your firm will experience compliance failures from time to time. In the realm of complex GxP-regulated processes, like automated pharmaceutical manufacturing and medical device quality assurance, things can go wrong with little advance warning.
When GxP firms take actions to maintain compliance with recommendations from the FDA and the EU, it's critical that they actually analyze the results after the fact. Failing to assess your compliance implementations effectively and on a periodic basis could result in a regulatory authority taking action against your company.
Medical device manufacturers and pharmaceutical companies use advanced IT tools to maintain sensitive business information, manufacture products and establish valid Quality Systems. In the past data integrity has been an important topic and is an increasingly important focus for FDA and EU regulators. The architectures employed by life sciences firms must be designed to facilitate consistent oversight and well-maintained compliance.
The most succinct answer to the question of what determines FDA compliance with GMP regulations of pharmaceutical production is adherence to 21 CFR Part 210 and 211. Anything less than complete adherence will render products as “adulterated” in the eyes of the FDA. Failure to comply could lead to disruptive regulatory action against a company.
The European Medical Device Directive or 93/42/EEC regulates which medical devices may be sold in the European market, while 21 CFR 820 is an FDA Quality Systems Regulation is a document that helps manufacturers of medical devices establish and follow a quality system within their company / organization in order to ensure that their manufacturing processes and the resultant products consistently meet and fulfill their applicable requirements and specifications. The 21 CFR 820 (also known as the FDA’s Quality System Regulation (QSR)) determines the cGMP requirements for medical devices.