fda enforcement inspections,trends q&a session with a recent fda investigator

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Slide 1 of 13 Rob Packard, President www.MedicalDeviceAcademy.com [email protected] FDA Enforcement Inspections, Trends: A Q&A Session with a former FDA Investigator

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Recent FDA Investigator Answers tough questions for Medical Device Academy on FDA Enforcement Inspection Trends and much more

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Page 1: FDA Enforcement Inspections,Trends Q&A session with a Recent FDA Investigator

Slide 1 of 13

Rob Packard, Presidentwww.MedicalDeviceAcademy.com

[email protected]

FDA Enforcement Inspections, Trends:

A Q&A Session with a formerFDA Investigator

Page 2: FDA Enforcement Inspections,Trends Q&A session with a Recent FDA Investigator

Slide 2 of 13

Rob Packard, Presidentwww.MedicalDeviceAcademy.com

[email protected]

Our Speaker

• http://bit.ly/FDA-recalls• http://bit.ly/Lead-Auditor-Course

[email protected]

+1.941.920.2645

Leo J. LagrotteFormer ORA Investigator

Page 3: FDA Enforcement Inspections,Trends Q&A session with a Recent FDA Investigator

Slide 3 of 13

Rob Packard, Presidentwww.MedicalDeviceAcademy.com

[email protected]

Question #1:You worked in the Tampa, FL office. My clients in the area mentioned that the office makes more regular visits than the target of 2 years. California seems to be another market with almost annual visits. Other regions have inspections less frequently that 2 years. Can you explain why Tampa and California are more frequent than the target of 2 years?

Page 4: FDA Enforcement Inspections,Trends Q&A session with a Recent FDA Investigator

Slide 4 of 13

Rob Packard, Presidentwww.MedicalDeviceAcademy.com

[email protected]

Question #2Yesterdays’ presentation was about FDA recalls. If a manufacturer has a recall, should an inspection automatically be expected the following year? If not, what other factors impact the likelihood of an inspection?

Page 5: FDA Enforcement Inspections,Trends Q&A session with a Recent FDA Investigator

Slide 5 of 13

Rob Packard, Presidentwww.MedicalDeviceAcademy.com

[email protected]

Question #3What’s the most common mistake you noticed in companies managing FDA inspections? How do you rectify it?

Page 6: FDA Enforcement Inspections,Trends Q&A session with a Recent FDA Investigator

Slide 6 of 13

Rob Packard, Presidentwww.MedicalDeviceAcademy.com

[email protected]

Question #4What direction do you think FDA enforcement will take over the next 5 years related to Quality System inspections?

Page 7: FDA Enforcement Inspections,Trends Q&A session with a Recent FDA Investigator

Slide 7 of 13

Rob Packard, Presidentwww.MedicalDeviceAcademy.com

[email protected]

Question #5Due to industry regulatory compliance trends, are FDA investigators receiving specific new training in QS areas that they have not received in the past?

Page 8: FDA Enforcement Inspections,Trends Q&A session with a Recent FDA Investigator

Slide 8 of 13

Rob Packard, Presidentwww.MedicalDeviceAcademy.com

[email protected]

Question #6I hear more each year about the “eFDA”--or the automation of administrative tasks at the FDA. Do you think the FDA will ever switch from green and black bound notebooks to electronic devices such as tablets? Could this include photos?

Page 9: FDA Enforcement Inspections,Trends Q&A session with a Recent FDA Investigator

Slide 9 of 13

Rob Packard, Presidentwww.MedicalDeviceAcademy.com

[email protected]

Question #7The Medical Device Single Audit Program (MDSAP) pilot has started, and the acceptance of the MDSAP reports in lieu of ANVISA audits by Brazilian regulators, Health Canada, Australia and the US FDA is exciting. Do you think MDSAP will dramatically reduce QSIT inspections?

Page 10: FDA Enforcement Inspections,Trends Q&A session with a Recent FDA Investigator

Slide 10 of 13

Rob Packard, Presidentwww.MedicalDeviceAcademy.com

[email protected]

Question #8You perform a lot of mock-FDA inspections. What is the most valuable thing your clients have learned during your simulated QSIT inspections?

Page 11: FDA Enforcement Inspections,Trends Q&A session with a Recent FDA Investigator

Slide 11 of 13

Rob Packard, Presidentwww.MedicalDeviceAcademy.com

[email protected]

Question # 9Many companies seem to use a memo to respond to FDA 483s, but what do you recommend to clients with regard to format and content of an FDA 483 response?

Page 12: FDA Enforcement Inspections,Trends Q&A session with a Recent FDA Investigator

Slide 12 of 13

Rob Packard, Presidentwww.MedicalDeviceAcademy.com

[email protected]

Question #10You and I have both been helping foreign firms with responding to Warning Letters with automatic detention. For anyone that doesn’t know what an “automatic detention” is, could you please explain it? Also, could you please explain how the reaction to FDA 483s and warning letters should be different if the manufacturer is a foreign firm?

Page 13: FDA Enforcement Inspections,Trends Q&A session with a Recent FDA Investigator

Slide 13 of 13

Rob Packard, Presidentwww.MedicalDeviceAcademy.com

[email protected]

Do You Need Training?http://bit.ly/Lead-Auditor-Course

Page 14: FDA Enforcement Inspections,Trends Q&A session with a Recent FDA Investigator

Slide 14 of 13

Rob Packard, Presidentwww.MedicalDeviceAcademy.com

[email protected]

Need help with regulatory compliance?

Rob Packard

[email protected]

+1.802.281.4381

rob13485

Page 15: FDA Enforcement Inspections,Trends Q&A session with a Recent FDA Investigator

Slide 15 of 13

Rob Packard, Presidentwww.MedicalDeviceAcademy.com

[email protected]

[email protected]

+1.561.308.3093

If you can’t reach me…