Today, many companies operate on an outsourcing model. This is very common for companies who are evolving from being mainly development-focused to a point where they are entering the latter stages of Phase 2 or Phase 3 clinical trials, and plan to have a product ready for market approval in the coming months. Most such companies are small, and may not have deep expertise in QA and GMP compliance, relying on their partners to cover those areas. Companies who outsource the majority of operations through the use of Contract Manufacturing Organizations (CMOs), Contract Research Organizations (CROs) and Contract Laboratories, however, remain responsible for the quality and compliance status of the products they send to the clinic or to the marketplace.
In this two-day workshop conference, you will learn the requirements and expectations of major healthcare regulators that are applicable to "virtual" companies. You will learn how to diagnose your company's needs based on which GMP and GCP-governed operations you retain and which you outsource; what the current expectations and best industry practices are for selecting, qualifying and monitoring your contractors to ensure they are meeting your requirements; and how to build a quality system framework that is not excessive for your current needs, but has the structure and integration to "grow with you" as the scope your operations change in the coming months and years.
You will also learn best practices for managing a regulatory inspection, with emphasis on FDA, EMA and Health Canada, but applicable to most other major agencies as well.
Learning Objectives:
Participants in this seminar will:
- Understand the GMP and GCP requirements all virtual companies must meet regardless of the extent of their outsourcing operations
- Understand how to select, qualify and monitor CMOs, CROs and Contract Laboratories
- Learn the elements to include in a quality agreement (also known as a technical agreement)
- Learn how to determine which GMP or GCP requirements apply to you, depending on the things you do internally and those you outsource
- Understand your obligations under the law for products you release to the clinic or the marketplace
- Appreciate the importance of maintaining data integrity
- Learn how to effectively manage a health regulatory inspection:
- Inspection logistics
- Responding effectively to document requests and questions from inspectors
- Managing the inspection exit discussion
- How to write an effective response to inspection observations
- How to find applicable inspection references and procedures of the FDA, EMA and Health Canada
Course Content
DAY 01 (12:00 PM - 04:00 PM EDT)
- Introductions and participant expectations for the program
- Fundamentals of Good Manufacturing Practice
- What is GMP?
- Purpose of GMP
- Basis in law: US, Europe, Canada
- Elements that apply to all virtual companies
- Elements that depend on how operations are conducted: How to tell what applies to your company
- Data Integrity: What it is and why it is important to GMP
- Fundamentals of Good Clinical Practice (GCP)
- What is GCP?
- Purpose of GCP
- Basis in law: US, Europe, Canada
- Elements that apply to all virtual companies
- Elements that depend on how operations are conducted: How to tell what applies to your company
- Regulatory and business risks: The case for compliance
- Virtual company organizational structure and responsibility for QA/GMP/GCP
- Virtual company quality system structure and management
- Policies, procedures, documentation management
- Metrics and management review considerations
- Selection, qualification and monitoring of contractors
- Initial due diligence - public information sources to gage compliance
- Qualification of vendors
- Quality agreements - determining and documenting responsibilities for GMP
- Vendor audit program
- Day One Q&A and recap of progress meeting stated course expectations
DAY 02 (12:00 PM - 04:00 PM EDT)
- Regulatory Inspections
- Purpose of an inspection
- Reasons for inspections
- Inspections at virtual company headquarters locations - purpose and scope
- Inspections at CMOs and Contract Labs
- GMP inspections versus Preapproval inspections - FDA
- GCP inspections of sponsors of clinical trials
- EMA inspections - contrast with FDA
- Health Canada inspections
- Logistics for managing inspections at your location
- Information sources about inspections on agency websites: What you need and how to find it easily
- Preparation for inspections
- Overall process - ready room support
- Receiving and hosting the inspectors
- Providing documents
- Answering questions
- Interpersonal dos and don’ts for interacting with inspectors
- Managing the exit discussion at the conclusion of the inspection
- Inspections at your contract organizations
- Making sure your CMO and contract lab are “PAI ready”
- Training employees to assure inspection readiness - pitfalls to make sure you avoid
- Conducting mock inspections effectively
- Post-inspection communications with the inspecting agency
- How to write an effective response
- Common mistakes to avoid
- Following up to ensure the response is satisfactory
- When to request a meeting, and if granted, how best to handle it
- Enforcement considerations
- FDA enforcement process - domestic and ex-US
- EMA enforcement
- Health Canada
- Final Q&A, discussion, and conclusion
- 4:00 PM: Adjourn
Course Provider
Ms Kelly Thomas,
Vice President ,
Stallergenes GreerMs. Thomas has over two decades of cGMP hands-on industry experience in both pharmaceutical and medical device manufacturing operations. Her experience covers all Quality Systems; as well as, all areas of validation; including, process/product validation, facilities validation, CSV and 21 CFR Part 11, test method validation, equipment/automated processes and cleaning validation.
Utilizing strategic thinking, risk based approaches, and Lean principles, she has demonstrated success in steering and managing complex projects within the pharmaceutical and medical device industries.
Who Should Attend
This course is designed for those charged with managing Quality Assurance and Regulatory Affairs for companies in the development or commercial phase of growth who either release investigational drugs to clinical trial sites or send commercial products to the market, but rely to a great extent on the use of Contract Manufacturers and/or Contract Laboratories. The following personnel will benefit from the course:
- Senior quality managers in manufacturing QA/GMP or clinical quality areas
- Quality professionals
- Regulatory professionals
- Clinical Operations
- Compliance professionals
- Quality auditors - GMP and GCP
- Document control specialists
