|
|
|
|
 |
Compliance
Regulatory Compliance
Aveta engages the regulatory affairs function of healthcare companies from the initial drug filing to pre-approval inspections for market launch and beyond. Aveta understands the nuances of the international regulatory environment from pre-clinical development to post market surveillance for pharmaceuticals, biotech, oncology & medical devices. Aveta’s regulatory affairs services include advising on regulatory strategy & planning, scientific consultancy & data assessment, preparation, submission & maintenance of clinical trial and marketing authorization applications including eCTD.
Aveta Regulatory Offerings
Filings & Submissions
| » |
Drug Master Files (DMF) |
» |
Abbreviated New Drug Application (ANDA) |
| » |
Site Master Files (SMF) |
» |
510K’s & European Device Submissions |
Product Licensing
Pharmaceutical products for the European Union can only be commercialized after Marketing Authorization (MA) has been granted by a Competent Authority. AVETA is able to assist in preparing for the Competent Authority with our comprehensive approach that includes:
| » |
Market Application Planning & Strategy |
| » |
CTD registration dossier/submission & MAA support during the review period |
| » |
Assistance in addressing MAA Regulatory Authorities questions |
| » |
Preparation of post-approval change documentation to an existing market authorization |
Qualified Person
All medicinal products distributed within the European Union, whether manufactured inside the community or imported from third countries must receive a Qualified Person release inside the EU. AVETA is able to provide full QP support services.
Remediation & Sustained Compliance
Our Regulatory Compliance Group can assist clients in responding to Agency inquiries and developing corrective action plans from a wide range of regulatory actions to ensure sustained compliance with domestic and foreign regulatory requirements.
Aveta Compliance Offerings:
| » |
483’s & Warning Letter response preparation & remediation |
| » |
Product Seizures and Import Restriction response and remediation |
| » |
ANDA Application Withdrawal recommendations |
| » |
Injunction Recommendations, Establishing the post-injunction “Plan for Implementation” and Progress Metrics with 3rd party oversight |
| » |
Assessing the Adequacy of Application Integrity Plans (APIs) |
| » |
Team leadership of Criminal (Title 18) Actions |
| » |
Pre-approval and For-cause domestic and foreign inspection |
| » |
Import Alerts resulting from violative Foreign Inspections |
| » |
Post Market Surveillance / Complaints & Adverse Event / MDR Reporting |
Aveta Regulatory & Compliance Expertise:
| » |
Former FDA Personnel |
| » |
Quality System Gap Assessment & Auditing |
| » |
QSR Development & Implementation: Quality Policies / Manuals ; Management Review ; CAPA; Deviation; OOS ; Non-conformance ; Customer Complaints; Quality Control; Process Controls ; Investigation & Root Cause Analysis Systems; Supply Chain & Traceability; Internal Audit Programs; Inspection Preparedness |
| » |
Validation Systems: VMP; PV; Equipment; Utilities; Facilities; Analytical Methods; etc. |
| » |
Computerized / Automation Systems: Design; URS; Part 11; ERP; MES; GAMP; etc. |
| » |
Quality by Design (QbD) |
| » |
Process Analytical Technology (PAT) development |
| » |
Documentation & Records Systems |
| » |
Labeling and Packaging Design & Implementation |
| » |
Clinical Compliance Oversight & data management |
| v |
Anti-Counterfeiting / Drug Pedigree |
Gmp Gap Assessment
Aveta is adept at finding and closing compliance gaps in your Quality / GMP Operations program. Our systematic approach based on the USFDA’s QSR coupled with our extensive industry & process knowledge thoroughly examines the procedures, processes and practices in your organization or your supplier’s. Our assessments are performed by professionals who understand worldwide regulatory requirements, track inspection standards and provide highest quality review for regulatory compliance.
The USFDA’s emerging “cGMPs for the 21st Century” and the ICH guidelines have created a regulatory environment that is extremely complex. Aveta not only has the experience with the new regulations, we also have the ability to integrate those requirements into your existing processes & procedures to enable your Quality & Operations groups to achieve Best Practices which almost always translate into significant cost savings in reduced cycle times, more robust, but fewer quality checks and higher yields. Also with the new USFDA Inspectorate, inspections have become much more rigorous and what used to be noted as minor observations are now being used to point back to the Quality Systems with major observations at a systemic level. Aveta’s assists our clients in Inspection preparedness to eliminate or reduce many of the Quality System gaps that translate into Inspection observations.
Though a gap assessment may be focused on a specific area or areas, a typical cGMP Compliance Gap Assessment that covers the full regulatory compliance scope comes in two phases:
Phase 1: Inclusive of the following systems / areas of inspection:
| » |
Quality Systems: Quality Policy; Document Control; Process Change Control; Training; Investigations (including OOS) / Deviations; Corrective Actions/Preventive Actions (CAPA); Customer Complaints & Reporting; Product Disposition; Internal Audit Program; Vendor Audits (Handled by RLL); Electronic Systems; Multi-use Policy; Master Validation Plan & Associated Procedures; Calibration Program; Standard Operating Procedures (SOPs); and disaster recovery |
| » |
Regulatory Compliance: Policies and procedures related to regulatory filings (DMF, IND, NDA, ANDA, etc.), updates and annual reports. The gap assessment will include the review of one ANDA or NDA filing for one product. |
| » |
Production Systems: Warehousing and Inventory Control; Material Receiving; Production Records and Controls; In-process Controls; Water System(s); Environmental Monitoring; Housekeeping, Pest
Control, & Security; Lot Numbering & Lot Controls; Reprocessing & Rework; Final Product Storage,
Distribution and Control; Material Handling & Controls; Buildings & Facilities Equipment; waste
stream management; and Preventive Maintenance Program(s) |
| » |
Quality Control Labs: QC Lab; Instrumentation; Laboratory Analysts; Stability Program; Out of Specification Results (OOS); Retain Samples; Sample Handling |
| » |
Qualification / Validation:
| • |
Operations: Review of the Master Validation Plan for the facility & manufacturing |
| • |
Facility: GMP Utility Systems & Equipment; HVAC & Environmental Monitoring; Facility GMP Release for Production |
| • |
QC Laboratory: GLP Laboratory Equipment; Methods Process Validation |
| • |
Production: Manufacturing Equipment; Computer & Part 11; Automation Systems; Cleaning
Validation |
| • |
Product: Process Validation |
| • |
Preliminary report to auditing staff & key stakeholders: A verbal / PowerPoint initial review of gaps found during investigation, to be divided into Critical / Major & Minor with some verbal discussion around potential gap closure for the Critical & Major items. |
| • |
Final Report on Gap Analysis: Full system by system report on identified gaps in the quality system environment with suggested options for remediation of Critical & Major gaps. |
|
Phase 2: Implementation plan for gap closure based on gaps identified in the audit. The scope for this phase will be determined after gap analysis of quality systems.
Aveta Audits & Inspection Preparation
Because of the recent changes in the USFDA & EMEA regulatory environment with GMPs for the 21st Century, ICH guidelines, and Risk Based process development, the new international Inspectorates have high expectations that a company will have a robust scientific based characterization of their processes that has both measured and mitigated the risks to that process and the public. This is done within the context of a QSR Inspection that anticipates that the Quality Systems will be robust, integrated and fully embedded in the day to day running of the company’s operations. The penalties for inadequate Quality Systems and non-compliant processes are putting both products and companies at risk. Aveta’s experts help to identify compliance risks with a methodology to reduce or eliminate the risks going forward.
Aveta’s Auditing Services fall into three basic categories: Internal Audits, External Audits and Regulatory Inspections. Regardless of the type of Audit, Aveta’s team of experts can assist in the development of programs, determination of metrics, training on specifics and rapid closure of any gaps. Aveta’s systematic approach thoroughly examines the procedures and practices in your own organization or that of a supplier.
Internal Audits:
Aveta recognizes that a robust Internal Audit program is the best defense in preparing for an international inspection, maintaining sustainable compliance and having an efficient, cost effective, manufacturing environment. Aveta’s experts understand the challenges with developing robust procedures and putting in place a strong team of internal auditors. We begin by evaluating the current systems, then working directly with management, operations and your Internal Audit team to put in place a world class Internal Audit program to identify and remediate compliance and process problems before they become inspection observations.
Internal Audit program assistance in:
| » |
Quality Systems inclusive of Quality Management Review; cGMP integration of Production & Process Controls (Deviation/OOS/OOT/Non-conformance Systems, CAPA System); Training Program; Internal Audit Program & Inspection Preparedness, Supply Chain, Traceability & Reject / Reuse / Rework Control; Packaging & Labeling; Lab Controls; Change Control; Complaints and Recalls. |
| » |
Adherence to cGMP policies and procedures |
| » |
Validation Systems for equipment, utilities, analytical methods, cleaning, computer systems, etc. |
| » |
Laboratory GLP policies, procedures, equipment & method validation, reagent supply chain, reference standard traceability, sample handling & management including labeling, process, LIMS validation and stability programs. |
| » |
Training program efficiency for centralized or decentralized systems, document / record flow, hands-on training robustness and objective evidence that training has a direct and positive impact on cGMP operations. |
| » |
Post Market Controls for Complaints, Investigations and Recalls. |
| » |
Product Specific auditing. |
External Audits:
Aveta has deep experience at auditing Vendors / Suppliers and performing Due Diligence with an eye for compliance to ensure that problems are identified for potential remediation or contract negotiation. Typical services include auditing of Contract Research & Manufacturing Organizations; API, Excipient & Raw Material / Component Suppliers.
Regulatory Audits (Inspections):
Aveta has an extremely thorough approach to Inspection preparedness that includes performing Mock Regulatory Inspections and Due Diligence Audits for organizations planning for FDA, EMEA or other regulatory inspection. Preparation includes planning with and training personnel in how to prepare documents, interact with inspectors and a successful approach in fielding questions to avoid getting into trouble. Inspection preparation includes case studies in how to / not to host inspectors for best results.
|
|