fda warning letters

Warning Letter Roundup – December 2016

By Deb Bartel,

The FDA sends Warning Letters and 483s to companies that significantly violate FDA regulations. We gather those related to computer system issues so that you can help ensure your organization doesn’t fail an inspection for similar violations. Organizations who received warning letters citing computer system issues: F.P. Rubinstein Y Cia This Warning Letter contains many observations impacting software quality, including  … Read more



WHO global framework, medical devices

Is Your Medical Device Compliant With The Second Draft Of The WHO Global Model Regulatory Framework?

By Deb Bartel,

In mid-2016, the World Health Organization (WHO) published the 2nd draft of Global Model Regulatory Framework for Medical Devices including IVDs. This document is intended to provide guidance to WHO Member States in developing and implementing regulatory controls relating to medical devices to ensure the quality and safety of medical devices. Since many modern medical devices contain software, developers of  … Read more



FDA guidance GMP active pharmaceutical ingredients

Are Active Pharmaceutical Ingredient Manufacturers Compliant With New FDA GMP Guidance?

By Deb Bartel,

In September, the FDA published Good Manufacturing Practice Guidance for Active Pharmaceutical Ingredients to provide API manufacturers with recommendations intended to ensure compliance with regulations. What is in the new FDA Guidance: This guidance document, originally published by ICH in 2000, includes recommended best practices for computer systems, such as: Validation System documentation Security Record protection and retention Audit trails  … Read more



EMA Answers 23 Data Integrity FAQs

23 Data Integrity FAQs Answered By The EMA

By Deb Bartel,

Last month, the EMA’s Good Manufacturing Practice (GMP) / Good Distribution Practice (GDP) Inspectors Working Group published their answers to 23 frequently asked questions related to Data Integrity and the Data Life Cycle. EMA’s Recommendations This Q&A document provides insight in the EU regulators’ expectations regarding data risk assessment and mitigation; data security, protection, and retention; electronic signatures; electronic data review;  … Read more



PIC/S, data integrity, draft guidance

New from PIC/S: Draft Guidance on Data Integrity

By Deb Bartel,

Earlier this year, the FDA published draft guidance on Data Integrity and Compliance for GMP. And now PIC/S has published a new, draft document Good Practices for Data Management and Integrity to guide manufacturers of medicinal products in complying with GMP and GDP requirements. As a member of PIC/S, the US FDA participated in the development of this guidance. The draft  … Read more



FDA Guidance on Low Risk Devices

Are you complying with the new FDA General Wellness Policy for Low Risk Devices?

By Deb Bartel,

In July 2016, the FDA released Guidance for Industry and FDA Staff – General Wellness: Policy for Low-Risk Devices to clarify compliance policies for low risk products that promote a healthy lifestyle. What’s in this FDA guidance document: The purpose of a general wellness product According to this FDA guidance, a general wellness product must Be intended only for general  … Read more



fda compliance data integrity cgmp validation

Are you ready for the FDA guidance on Data Integrity and Compliance?

By Deb Bartel,

The FDA just published a new, draft guidance document on good manufacturing practices (cGMP) for drugs. This document is intended to address the frequent data integrity issues found during FDA inspection of pharmaceutical and API manufacturing sites. What’s new in this draft FDA guidance document: Clarifications & Definitions of Terms This draft guidance contains clarifications and definitions for the terms  … Read more



csv sqa help with project

Are You Following the FDA Medical Device Cybersecurity Guidance?

By Deb Bartel,

In January the FDA published draft cybersecurity recommendations for marketed medical devices to protect patient safety. What’s new in this draft FDA guidance document: Manufacturer’s Responsibilities This guidance emphasizes that medical device manufacturers should monitor, identify and address cybersecurity vulnerabilities.  This draft FDA document highlights that it is essential for device manufacturers to implement comprehensive cybersecurity risk management programs. These  … Read more



FDA Guidance Interoperable Medical Devices

Are you ready for the FDA guidance on the design of Interoperable Medical Devices?

By Deb Bartel,

If your electronic medical device exchanges data with other devices, you need to read the new draft guidance just published by the FDA.  This document contains recommendations intended to promote the safe and effective exchange of information between devices.  Make sure you and your team are aware of these best practices, so you can incorporate them into your medical device.  … Read more



eudralex annex 16 software validation

Are you complying with the European Commission’s new version of Annex 16?

By Deb Bartel,

In October, a new version of Annex 16 was published due to significant changes in the globalization of pharmaceutical supply chains and the introduction of new quality control strategies. Annex 16 was last published in 2001, so this version has significant improvements. The deadline for compliance with this version of Annex 16 is 15-APR-2016. What’s in this new version: This version  … Read more



fda compliance manufacturing site changes

What do you need to know about the new FDA guidance on Manufacturing Site Changes?

By Deb Bartel,

Recently, the FDA drafted this guidance document to help the medical device industry make decisions around manufacturing site changes. This guidance is intended to help in managing the time frames for changes in manufacturing sites and the associate changes to processes, methods, procedures, qualifications and validations by helping industry predict when an FDA pre-approval inspection is likely to be required for  … Read more



WHO Guidance Data Record Management

Are you prepared for WHO draft guidance on Good Data and Record Management Practices?

By Deb Bartel,

In September 2015, the World Health Organization (WHO) published a draft guidance document focused solely on data integrity. This is due to recent increases in the number of inspection observations related to data management practices. These WHO recommendations are intended to ensure the integrity of both paper and electronic data and records. Share this with your team, so you can  … Read more



FDA Guidance Analytical Procedures Methods Validation

Are your procedures aligned with the FDA Guidance for Analytical Procedures and Methods Validation?

By Deb Bartel,

Last month, the FDA published this document for drug and biological license applicants submitting analytical procedures and methods validation data to document the identity, strength, quality, purity, and potency of drug substances and products. This guidance is intended to complement the International Conference on Harmonisation (ICH) guidance Q2(R1) Validation of Analytical Procedures: Text and Methodology for developing and validating analytical methods. Computer and software related  … Read more



ICH E6 R2 Good Clinical Practice

Are you ready for the new version of ICH E6 Good Clinical Practice for Electronic Records?

By Deb Bartel,

R2 of E6 Good Clinical Practice has been published for consultation. Once approved, it will replace the original R1 version of E6. What’s included in this revision: E6 R2 contains updates intended to increase clinical trial quality and efficiency.  The objective of this draft ICH GCP Guideline is to provide a unified standard for the European Union (EU), Japan, and the United  … Read more