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FDA Audit next week

Elsmar Forum Sponsor
#13
Information on Pre-announcement of Inspections can be found in the FDA's Guide to Inspections of Quality Systems.

I have also reviewed some recent 483s citing complaint handling - particularly as it applies to MDR procedures. As a contract sterilizer, we don't actually market the product, so my understanding is the MDR requirements of CFR 803 would not apply to our operation.

Thanks for the good luck wishes. This is our first FDA inspection in soon to be four years.
I believe you still have to have a MDR procedure...
 

Doug Tropf

Quite Involved in Discussions
#15
Day one of our ongoing FDA audit went as follows:

Opening meeting
Tour of facility
Review of process deviations for past year plus related corrective actions
Review of customer contracts
CAPA - forms, procedures, open and closed CAPAs for past two years

Inspectors advised at the end of day one that they had not found anything that they were concerned about. :)
 

Ajit Basrur

Staff member
Admin
#16
Day one of our ongoing FDA audit went as follows: .......................... Inspectors advised at the end of day one that they had not found anything that they were concerned about. :)
Great Job Doug :applause:

Appreciate that you took your valuable time off to update us. :thanx:

How many more days is the inspection ?
 

Doug Tropf

Quite Involved in Discussions
#17
During day two the FDA inspectors audited:

Alarm testing and maintenance records on our process equipment
Calibrations of our monitoring and process equipment
Random samples of our DHRs
Job descriptions

So far - so good.
 

Doug Tropf

Quite Involved in Discussions
#18
The following items were covered during day three of our inspection:

Sterilization cycle validations - including protocols
Steam quality testing
Process software applications and validations
Training procedures and documentation
Internal audit procedures and audit schedule
Management review procedures and evidence of meetings being held
Document control procedures
Process equipment calibrations / documentation

Wrap up is tomorrow, barring something unforeseen, I think we are good.:cfingers:
 
P

Pataha

#20
Excellent job.

To add to your reference library is this link Investigations Operations Manual 2007 http://www.fda.gov/ora/inspect_ref/iom/, in the past it is updated
in March.
for medical device companies Chapter 5 is the ground rules for the Auditor.

I am not sure if one should be overly concerned about this, but it appears that for your Internal Audit program and Managment Review, you provided quite a bit of information.

Under 21 CFR 820.180(c) - (c) Exceptions. This section does not apply to the reports required by 820.20(c) Management review, 820.22 Quality audits, and supplier audit reports used to meet the requirements of 820.50(a) Evaluation of suppliers, contractors, and consultants, but does apply to procedures established under these provisions. Upon request of a designated employee of FDA, an employee in management with executive responsibility shall certify in writing that the management reviews and quality audits required under this part, and supplier audits where applicable, have been performed and documented, the dates on which they were performed, and that any required corrective action has been undertaken.

So basically when this subject matter comes out you have a upper management type to sign certifying that this activities are done.

Plus, it has been my experience that the Internal Audits being done and some outputs of Managment review show up in the CAPA system.

Still not sure if this is a point of concern . Your way of handling it should have been less adversarial, then some of the encounters I have witnessed for these sections of 21 CFR 820.
 
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