Checklist for Pharma Inspection Part 06

Data Integrity App


During Inspection

1 Arrival of Inspector

Ensure that ALL members of the research team know that the FDA is in the facility. Inform other staff when you will be giving the inspector a tour of the facility.

The escort will walk the inspector to an appropriate meeting room. The inspector will present his/ her credentials to verify that they are in order; do not expect the investigator to permit a copy to be made of his/her badge/credentials.

The designated escort should stay with the inspector at all times

The inspector will then present a Notice of Inspection (482) to the Principal Investigator, this notice authorizes the inspection and its presentation officially begins the inspection.

The inspector will explain the intended purpose and scope of the inspection, then ask the PI to summarize the study.

 

2 Opening Meeting

The inspector should present his/her credentials to the PI to verify that they are in order
Ask the inspector to see his/her credentials if he/she does not present them

Document all information from the inspector’s identification as no copies of the identification
badges can be made.

The inspector will present a Notice of Inspection (Form FDA 482) to the PI authorizing the
inspection.

This presentation officially begins the inspection.

The inspector will explain the intended purpose and scope of the inspection.

If the team does not ask for the inspector’s credentials and/or the Form 482, the inspector
may note this as a deficiency in his/her report.

The inspector will ask the PI to summarize and discuss the study identified for inspection and
his/her responsibilities with respect to the study.

The inspector may ask the PI for the list of his/her studies.
 
 

3 Attempt to Negotiate the Areas Being Sampled: 

During the entrance meeting, the FDA Investigators will typically disclose the types of ingredients, products and/or environmental areas they intend to sample. Attempt to negotiate with the agency to limit the amounts, types or overall focus of the sampling in such a way that, if any results are positive, you can limit to the greatest extent possible the scope of any recall.

 

4 Escort’s Role& Responsibility 

The escort’s role is to coordinate all FDA requests and see that the inspector’s questions are answered honestly and completely. Listen to the question; answer the question that was asked. Defer to others if you don't know; when possible use documents already provided for support of answers. Stop when the question is fully answered. There is nothing wrong with silence: when you have answered, wait for the next questions.

How to answer FDA Questions: 

Be concise; answer only the question that is asked.
Always be clear with the answers to questions. 
 Be positive and confident.
 Take corrective actions if possible, commit only to what you can deliver.
 DO NOT volunteer information.  DO NOT guess or speculate
DO NOT lie.  DO NOT argue.
 DO NOT panic.
 DO NOT sign affidavits.  

 

5 Carefully Document the Areas Being Sampled by FDA: 

While the FDA Investigators are conducting their sampling, be sure to carefully document the exact areas from which the FDA Investigators are collecting their samples. 

In addition, be sure to appropriately characterize the areas being sampled by the agency as Zone 1, Zone 2, Zone 3, or Zone 4. This information will be critical in the event that any samples are positive to determine the most appropriate response. 

 

“Trust but Verify “ Ronald Reagan

 

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Data Integrity App

 

Our Data integrity app will helpful for understanding what Data integrity & CSV really means & How 21 CFR Part 11, EU Annex 11 & other regulatory guidelines affects in pharmaceutical Industry.

 

Data Integrity App Include 

- Basic Data Integrity Concepts

- ERES & Its Requirement

- CSV & Its best practices 

- Mock Inspection and General Q&A

- Checklist for inspection

- Inspection Readiness

- Useful SOP’s

- Stay Regulatory Compliant.

 

“Stay One Step Ahead in Pharma IT Compliance” 


Data Integrity App Link:


https://play.google.com/store/apps/details?id=com.innovativeapps.dataintegrity

 

Try our "Data Integrity" app which helps you to better understand current regulatory agencies thinking on Data Integrity & CSV.


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