The Food and Drug Administration (FDA) conducts inspections and assessments of regulated facilities to determine a firm’s compliance with applicable laws and regulations, such as the Food, Drug, and Cosmetic Act. This typically involves an investigator visiting a firm’s location. Learn about the basics of FDA Audits with this starter Qstream microlearning course.
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Answer explanation:
FDA (Food and Drug Administration) inspections are an official examination of a facility to determine its compliance with laws and regulations administered by the FDA. These inspections are characterized by a focus on:
• Fact-finding
• Obtaining evidence
• Compliance with regulations
The four types of major Good Manufacturing Practices (GMP) inspections that the FDA conducts include:
• Pre-approval
• Post-approval
• Surveillance (routine)
• For-cause or directed
Answer explanation:
The Pre-Approval Inspection (PAI) assures the FDA (Food and Drug Administration) that a manufacturing establishment named in a drug application is capable of manufacturing a drug and that the submitted data are accurate and complete.
Since Corey’s team has already met this benchmark, the FDA will next conduct a Post-Approval Inspection of their product (AbleMax) and monitor for changes in the production and control practices since the PAI. In this case, there have been changes in the production because some of the equipment has been upgraded and Corey’s team should be knowledgeable in the current configuration.
Answer explanation:
The New Inspection Protocol Project (NIPP) is a new paradigm for inspections and reports designed to advance pharmaceutical quality. The main feature is the standardized approach to inspection where data is gathered to inform quality intelligence of sites and products.
When using the NIPP, Theodore needs to record both positive and negative behaviors. He uses expert questions to explore both risk-based and rule-based processes. Theodore also uses semi-quantitative scoring, which allows him to compare within and between sites.
Answer explanation:
Activities in pharmaceutical companies can be organized into systems (sets of operations and related activities). Control of all systems will help ensure production of drugs that meet intended safety, identity, strength, quality, and purity characteristics.
According to 21 CFR 211, there are six systems that are covered in an FDA (Food and Drug Administration) surveillance inspection:
• Quality
• Facilities and equipment
• Materials
• Production
• Packaging and labeling
• Laboratory controls
Answer explanation:
There are two surveillance inspection options: full and abbreviated.
A full inspection covers the quality system plus three other systems. It is required during an initial inspection or when there has been a history of noncompliance. It is also used when there are significant changes such as new technologies, equipment, or facilities.
An abbreviated inspection is meant to provide an efficient update evaluation of an organization’s Good Manufacturing Practices (GMP) compliance. This is usually conducted when:
• An organization has a record of satisfactory GMP compliance
• There are no significant recalls, product defects, or field alert incidents
• The manufacturing profile has not changed substantially within the previous two years
Answer explanation:
For-cause or directed inspections are used for anything other than pre-approval, post-approval, or routine surveillance inspections. For example, they are used when there is a need to investigate a specific problem that has come to the FDA’s (Food and Drug Administration) attention, such as TCM Global Laboratory’s product recall. For-cause or directed inspections are also used if there has been an NDA (New Drug Application) Field Alert report or an adverse event cluster.
Answer explanation:
Section 704(a) of the FD&C (Federal Food, Drug, and Cosmetic) Act provides authority for the FDA to conduct inspections “upon presenting appropriate credentials and a written notice to the owner, operator, or agent in charge.”
Louise knows she must be reasonable in her time, limits, and manner of the objective inspection. To meet this standard, she will work with a team of experts in other specialty areas such as chemistry, microbiology, process/facility, and formulation.
Answer explanation:
Miguel’s inspection plan should be based on the following information:
• Previous Establishment Inspection Reports (EIRs)
• Previous FDA Form 483 observations and their related responses, warning letters, and/or related firm commitments
• The company’s website including product literature, products manufactured, and recent press releases
• Consumer complaints and recalls since the last inspection
Answer explanation:
Clint is required by law to show his credentials upon starting an inspection to the top management official such as owner, operator, or agent in charge. Management may examine the investigators’ credentials and record the name(s) and phone number(s). However, credentials are not to be copied in any manner.
Answer explanation:
On-site FDA inspections follow a standardized process in which the lead investigator will:
1. Issue a notice of inspection
2. Display credentials, state the purpose of inspection, and provide a general agenda
3. Tour the facility
4. Get into the details of the inspection
5. Hold a daily wrap-up meeting
Answer explanation:
During an FDA inspection, inspectors are verifying that manufacturers like Ethan Pharmaceuticals are operating in a sufficient state of control by reference to the Good Manufacturing Practice (GMP) regulations and policies. If that is not found to be the case, inspectors must document accordingly to support the necessary action.
Common GMP violations include:
• Poorly trained employees
• Poorly maintained or contaminated equipment and facilities
• Lack of process control
• Failure to conduct investigations and resolve any discrepancies, failures, deviations, or complaints
Answer explanation:
Investigators look for documentation and data integrity issues during their inspections. Some of the issues Veronica’s team will look out for include:
• Activities not being recorded contemporaneously
• Fabricating data to create acceptable test results
• Discarding data without appropriate documentation
• Data that looks too good to be true
• Lack of raw data (i.e., sample weights, sample solution prep)
Her team will ask those in charge at JLP Global to review documentation of past events as well as scientific evidence to support JLP Global’s conclusions.
Answer explanation:
The three categories of inspections are:
• NAI- No Action Indicated
• VAI- Voluntary Action Indicated
• OAI- Official Action Indicated
The inspection report must be completed and provided to the organization that was inspected in a timely manner and incorporate all inspectional findings from each team member.
Answer explanation:
The FDA’s (Food and Drug Administration) Field Medical Directive 86 (FMD-86) outlines that the conclusions and decisions of an inspection report can include:
• Voluntary actions
• Advisory actions (i.e., warning letters, untitled letters)
• Legal sanctions (i.e., seizure, injunction, prosecution)
• Recognition of positive behaviors
For more information, check out the FDA Field Management Directives:
http://www.fda.gov/downloads/ICECI/Inspections/FieldManagementDirectives/UCM382035.pdf
Answer explanation:
To be prepared for an FDA (Food and Drug Administration) inspection, it is recommended to do the following:
• Know and comply with FDA regulations and policies
• Always follow SOPs (Standard Operating Procedures)
• Ask the investigator for clarification if you don’t understand or agree with an observation
• Be proactive and have a good attitude
• Display a willingness to correct problems, but do not promise to make a correction if you do not agree with it or are not sure that you will be able to follow through
Answer explanation:
FDA (Food and Drug Administration) inspections are an official examination of a facility to determine its compliance with laws and regulations administered by the FDA. These inspections are characterized by a focus on:
• Fact-finding
• Obtaining evidence
• Compliance with regulations
The four types of major Good Manufacturing Practices (GMP) inspections that the FDA conducts include:
• Pre-approval
• Post-approval
• Surveillance (routine)
• For-cause or directed
Answer explanation:
The Pre-Approval Inspection (PAI) assures the FDA (Food and Drug Administration) that a manufacturing establishment named in a drug application is capable of manufacturing a drug and that the submitted data are accurate and complete.
Since Corey’s team has already met this benchmark, the FDA will next conduct a Post-Approval Inspection of their product (AbleMax) and monitor for changes in the production and control practices since the PAI. In this case, there have been changes in the production because some of the equipment has been upgraded and Corey’s team should be knowledgeable in the current configuration.
Answer explanation:
The New Inspection Protocol Project (NIPP) is a new paradigm for inspections and reports designed to advance pharmaceutical quality. The main feature is the standardized approach to inspection where data is gathered to inform quality intelligence of sites and products.
When using the NIPP, Theodore needs to record both positive and negative behaviors. He uses expert questions to explore both risk-based and rule-based processes. Theodore also uses semi-quantitative scoring, which allows him to compare within and between sites.
Answer explanation:
Activities in pharmaceutical companies can be organized into systems (sets of operations and related activities). Control of all systems will help ensure production of drugs that meet intended safety, identity, strength, quality, and purity characteristics.
According to 21 CFR 211, there are six systems that are covered in an FDA (Food and Drug Administration) surveillance inspection:
• Quality
• Facilities and equipment
• Materials
• Production
• Packaging and labeling
• Laboratory controls
Answer explanation:
There are two surveillance inspection options: full and abbreviated.
A full inspection covers the quality system plus three other systems. It is required during an initial inspection or when there has been a history of noncompliance. It is also used when there are significant changes such as new technologies, equipment, or facilities.
An abbreviated inspection is meant to provide an efficient update evaluation of an organization’s Good Manufacturing Practices (GMP) compliance. This is usually conducted when:
• An organization has a record of satisfactory GMP compliance
• There are no significant recalls, product defects, or field alert incidents
• The manufacturing profile has not changed substantially within the previous two years
Answer explanation:
For-cause or directed inspections are used for anything other than pre-approval, post-approval, or routine surveillance inspections. For example, they are used when there is a need to investigate a specific problem that has come to the FDA’s (Food and Drug Administration) attention, such as TCM Global Laboratory’s product recall. For-cause or directed inspections are also used if there has been an NDA (New Drug Application) Field Alert report or an adverse event cluster.
Answer explanation:
Section 704(a) of the FD&C (Federal Food, Drug, and Cosmetic) Act provides authority for the FDA to conduct inspections “upon presenting appropriate credentials and a written notice to the owner, operator, or agent in charge.”
Louise knows she must be reasonable in her time, limits, and manner of the objective inspection. To meet this standard, she will work with a team of experts in other specialty areas such as chemistry, microbiology, process/facility, and formulation.
Answer explanation:
Miguel’s inspection plan should be based on the following information:
• Previous Establishment Inspection Reports (EIRs)
• Previous FDA Form 483 observations and their related responses, warning letters, and/or related firm commitments
• The company’s website including product literature, products manufactured, and recent press releases
• Consumer complaints and recalls since the last inspection
Answer explanation:
Clint is required by law to show his credentials upon starting an inspection to the top management official such as owner, operator, or agent in charge. Management may examine the investigators’ credentials and record the name(s) and phone number(s). However, credentials are not to be copied in any manner.
Answer explanation:
On-site FDA inspections follow a standardized process in which the lead investigator will:
1. Issue a notice of inspection
2. Display credentials, state the purpose of inspection, and provide a general agenda
3. Tour the facility
4. Get into the details of the inspection
5. Hold a daily wrap-up meeting
Answer explanation:
During an FDA inspection, inspectors are verifying that manufacturers like Ethan Pharmaceuticals are operating in a sufficient state of control by reference to the Good Manufacturing Practice (GMP) regulations and policies. If that is not found to be the case, inspectors must document accordingly to support the necessary action.
Common GMP violations include:
• Poorly trained employees
• Poorly maintained or contaminated equipment and facilities
• Lack of process control
• Failure to conduct investigations and resolve any discrepancies, failures, deviations, or complaints
Answer explanation:
Investigators look for documentation and data integrity issues during their inspections. Some of the issues Veronica’s team will look out for include:
• Activities not being recorded contemporaneously
• Fabricating data to create acceptable test results
• Discarding data without appropriate documentation
• Data that looks too good to be true
• Lack of raw data (i.e., sample weights, sample solution prep)
Her team will ask those in charge at JLP Global to review documentation of past events as well as scientific evidence to support JLP Global’s conclusions.
Answer explanation:
The three categories of inspections are:
• NAI- No Action Indicated
• VAI- Voluntary Action Indicated
• OAI- Official Action Indicated
The inspection report must be completed and provided to the organization that was inspected in a timely manner and incorporate all inspectional findings from each team member.
Answer explanation:
The FDA’s (Food and Drug Administration) Field Medical Directive 86 (FMD-86) outlines that the conclusions and decisions of an inspection report can include:
• Voluntary actions
• Advisory actions (i.e., warning letters, untitled letters)
• Legal sanctions (i.e., seizure, injunction, prosecution)
• Recognition of positive behaviors
For more information, check out the FDA Field Management Directives:
http://www.fda.gov/downloads/ICECI/Inspections/FieldManagementDirectives/UCM382035.pdf
Answer explanation:
To be prepared for an FDA (Food and Drug Administration) inspection, it is recommended to do the following:
• Know and comply with FDA regulations and policies
• Always follow SOPs (Standard Operating Procedures)
• Ask the investigator for clarification if you don’t understand or agree with an observation
• Be proactive and have a good attitude
• Display a willingness to correct problems, but do not promise to make a correction if you do not agree with it or are not sure that you will be able to follow through
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