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CAPA Training and Causes of Warning Letters due to Lack of Comprehension- By AtoZ Compliance
Key Take Away:
Implementing an effective corrective actions or preventive action capable of meeting QS Regulations and satisfying quality assurance and GMP/GDP documentation requirements is critical and all too often not followed in the specified sequence which has a negative effect when CAPA systems are inspected.
CAPA (Corrective and Preventative Actions) did not originate in the Pharmaceutical and Medical Device industry or the Automobile Industry as most folks post on the Internet. The program to make effective corrections and ensure that preventative applications were incorporated was in use way back in the 60s by NASA and the FAA to enhance safety but was not labeled CAPA even though the intent was the same.
A timely, well documented, Corrective / Preventive Action program validates a quality system that is not only capable of identifying potential problems but also effectively correcting problems when incidents do occur and as part of the Continuous Quality Improvement program, correcting potential problems prior to occurrence. Adequate incident tracking is the primary foundational element for an effective CAPA FDA.
Why Should You Attend:
A vast majority of the current industry deficiencies which have led to isolated 483s, Warning Letters and Consent Decrees are the result of deficient technical documentation and effective means of assessing various elements of CAPA expectations for products produced and distributed under the FDA approval process.
How do you know that your FDA CAPA training procedure(s) that address the requirements of the quality system regulation have been technically defined, documented and implemented to determine if appropriate sources of product and quality assurance are being identified and that the data from these sources are being analyzed and documented in an easy to understand technical report to identify existing product and quality problems that may require corrective action and/or preventative action?
Areas Covered In This Webinar:
Too often regulatory documents are written using subjective terminology and grammar (first person, pronouns and adverbs) instead of objective, technical descriptions of the element being addressed (stick to the facts). Lack of technical writing skills has contributed to the majority of the current submission rejections, 483s, warning letters and consent decrees - see FDA examples at end of presentation. GMP controlled documents must be written in a way that will be clear to the jury when presented in a court case, as opposed to writing like “we are having a conversation”. Who in this case is “we”, the head of quality or a janitor?
- Identification of the incident - Criticality of the Incident Tracking System separate from deviation tracking.
- Evaluation of the impact or magnitude of the incident
- Initiation and Risk Assessment to demonstrate compliance with Quality Systems Regulations
- Investigation procedure to assess various strategies in accordance with current regulatory expectations
- Root Cause Analysis training by avoiding subjective thinking to generate objective documentation
- Action Plan generation listing the tasks, metric applications and acceptance criteria for each activity
- Implementation Plan example needed to accomplish the Corrective or Preventive Action Plan
- Verification using stand-alone documentation practices of for objective evidence to meet cGMP regulations
- Effectiveness monitoring plan to demonstrate the corrective action and/or preventive action is performing as anticipated preventing reoccurrence or initial occurrence of the identified issue.
Who Will Benefit:
- Regulatory Personnel
- Quality and Documentation Personnel
- Operations and Development Personnel
Jerry Dalfors has extensive (40+ years) of business administration, consultative, technical and managerial experience in the development and manufacture of highly regulated biopharmaceutical products including injectables, biologics, medical devices and oral dosages. He has held permanent employee, temporary employee and company representative management positions with a multitude of the major pharmaceutical and biotechnology companies in the US.
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Quality and Documentation Personnel
Operations and Development Personnel
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