Course “FDA Penalties for Regulatory Non-Compliance in the Pharmaceuticals Industry – 2017 in Review” has been pre-approved by RAPS as eligible for up to 12 credits towards a participant’s RAC recertification upon full completion.
The FDA is increasing its enforcement actions both for domestic and foreign inspections. Enforcement statistics have not been summarized yet because 2017 has not ended yet. We are certainly seeing more Warning Letters and Import Alerts based on Data Integrity (21 CFR Part 11: Electronic Records; Electronic Signatures. In the past FDA used to issue several Warning Letters to the same firms upon consecutive inspections. Today, after receiving one Warning Letter the next regulatory action is elevated to Import Alert, Consent Decree, and Injunctions for domestic manufacturers.
Senior Management must take the initiative in setting the tone of full compliance:
• Taking “regulatory risks” may no longer be worth the price of getting caught
• Planned deviations cannot be used as an excuse for not following your written procedures
• Retesting into compliance has been unacceptable for many years and will no longer be tolerated
• Senior officials are being held responsible. Today, these “Captains” may go down with the ship – sent to prison and fined millions of dollars
FDA’s Office of Manufacturing Quality (OMQ) at the Center for Drug Evaluation and Research (CDER) evaluates compliance with current Good Manufacturing Practice (cGMP) for drugs based on inspection reports and evidence gathered by FDA investigators. The office also develops and implements compliance policy and takes advisory actions to protect the public from adulterated drugs in the U.S. market. This year we have seen:
• Increased use of Contract Manufacturing Organizations (CMO) has increased the regulatory focus on CMO and requirements for Quality Agreements are being enforced
• There has been an increase in Warning Letters in 2017
• An increase in Import Alerts enforcement actions
• Data Integrity issues are being found more frequently
This hands-on seminar provides a comprehensive approach to learning how to proactively prevent non-compliance. There will be intensive reviews on the negative consequences of receiving regulatory enforcement actions. FDA Warning Letters are posted publicly on the CDER web site. Your competitors, shareholders, the public and your patients now become aware of your shortfalls. Many Warning Letters today mandate the hiring of third party consultants, which can be quite expensive. An Injunction will require pharmaceutical companies to spend millions of dollars and require years until you “bounce back.” Multimillion disgorgement penalties are being levied along with Injunctions.
Day 1 Schedule
Introduction and Background
• Introductions / Participants’ Understanding / Participants’ Objectives for the Course (Please come prepared to discuss)
• Industry Context
• Key Concepts
Summary and Highlights of 2017 Enforcement Actions
• Warning Letters
• Import Alerts
• Consent Decrees
Penalties and Negative Financial results of Enforcement Actions
• Detailed Costs and Expenditures for Remediation
• Loss of Sales and Customers
• Decreases in Patients Access
• Loss of Good Reputation
• Loss of Jobs
ICH Guidelines on Quality Risk Management
• Science Based Quality Risk Management
• Quality Risk Management Process
• Initial Risk Assessment
• Implement & Verify Appropriate Controls
• Review Risks & Monitor Controls
Day 2 Schedule
Adequate Responses to FDA
• Comprehensive Corrective and Preventative Action (CAPA) Plans
• Sincere and Specific timelines
• Quarterly Follow-ups
• Adequate but not overwhelming documentation
Change in Attitude and Culture
• Full Support and Commitment of Senior Management
• Responsibilities to Customers
• Proactive Not Reactive
Metrics on Improvements
• Management Involvement
• Personnel Involvement
• Positive Increases in Metrics Lead to Positive Attitudes
• Incentives and Acknowledgements
Group Activities Writing FDA-483 Responses
• Instructors Evaluation and Recommendations
Brian G. Nadel
President/Sole Proprietor of Brian G. Nadel, GMP Consulting, LLC
Brian G. Nadel is the President/Sole Proprietor of Brian G. Nadel, GMP Consulting, LLC. He has over twenty-five years of diverse experience in: Pharmaceutical Quality Assurance and Quality Systems; FDA Pre-Approval and Inspection Readiness Inspections; International CGMP Auditing for finished drug products, Active Pharmaceutical Ingredients, Fermentation, Process Validation and botanical extraction.
Mr. Nadel utilizes his broad background to assess compliance issues and develop effective, efficient comprehensive systems to ensure CGMP Compliance. He assists pharmaceutical firms in maintaining and developing quality manufacturing operations. He has worked with NDA, ANDA, DMF, BLA and OTC product manufacturers. He has also conducted CGMP training for FDA, Industry and at industry conferences. He has worked to assist clients to comply with the requirements of Consent Decrees. He has used his experience in the pharmaceutical and government regulatory industries to author SOPs in quality and compliance areas.
Mr. Nadel has worked as a Senior Consultant for PAREXEL International. Prior to joining PAREXEL, Mr. Nadel was a Senior Director responsible for Supplier Quality, Risk Management and Anti-Counterfeiting, in the Corporate Quality and Compliance department at Sanofi’s US headquarters in Bridgewater, NJ. Before that, he was the Senior Manager at Forest Laboratories in NY and NJ responsible for Pre-Approval Inspection Readiness and Internal and External audits. At Forest Laboratories, he managed teams that were responsible for receiving first-pass approvals of two blockbuster NDA drug products. He started his career as a Drug Specialist Investigator in FDA’s New York District Office. He was then promoted to the FDA’s Center for Drug Evaluation and Research (CDER) in Rockville, MD, where he served as a Compliance Officer in the Office of Compliance of Compliance, Division of Manufacturing and Product Quality. At CDER, his main responsibility was reviewing recommendations from the district offices for regulatory actions such as Warning Letters, Seizures, Consent Decrees and Injunctions.
Mr. Nadel holds a BA in Microbiology and Parasitology from the State University of New York at Albany, NY and is a certified Regulatory Affairs Professional. He is a member of the Parenteral Drug Association and the Regulatory Affairs Professional Society. Mr. Nadel has spoken at many industry conferences, including three conferences in India in 2017.
Mr. Nadel has just completed his third trip to India in 2017. During these visits, he has been working with Indian Pharma to train them to proactively prevent problems and respond to “issues” with the US FDA.
Location: Chicago, IL Date: March 29th & 30th, 2018 and Time: 9:00 AM to 6:00 PM
Venue: Hilton Garden Inn O’Hare 2930 S. River Road Des Plaines, IL 60018
Register now and save $200. (Early Bird)
Price: $1,295.00 (Seminar Fee for One Delegate)
Until February 20, Early Bird Price: $1,295.00 From February 21 to March 27, Regular Price: $1,495.00
Register for 5 attendees Price: $3,885.00 $6,475.00 You Save: $2,590.00 (40%)*
Register for 10 attendees Price: $7,122.00 $12,950.00 You Save: $5,828.00 (45%)*
Sponsorship Program benefits for “Quality Assurance Auditing for FDA Regulated Industry” seminar
At this seminar, world-renowned FDA Regulated Industry subject matter experts interact with CXO’s of various designations. Executives who carry vast experience about FDA Regulated Industry and Experts get down to discussing industry-related best practices, regulatory updates, changes in technologies, and much more relating to FDA Regulated Industry.
As a sponsor of these seminars, you get the opportunity to have your product and company reach out to C-Level executives in FDA Regulatory -related industries and become known among these elite executives and subject matter experts. Apart from being seen prominently at these globally held seminars, you also get talked about frequently in our correspondences with our experts and these participants.
For More Information- https://www.globalcompliancepanel.com/control/sponsorship
Contact us today!
NetZealous LLC DBA GlobalCompliancePanel
Toll free: +1-800-447-9407
Registration Link – https://www.globalcompliancepanel.com/control/globalseminars/~product_id=901471SEMINAR?tixtore-March-2018-SEO
Follow us on LinkedIn: https://www.linkedin.com/company/globalcompliancepanel/
Like us our Facebook page: https://www.facebook.com/TrainingsAtGlobalCompliancePanel/
Follow us on Twitter: https://twitter.com/GCPanel