Pre-Approval Inspections A Case Study Steve Pondell 28 Nov 2007

Topics Pre-Inspection The Inspection Outcome

Pre-Inspection - Situation API manufacturer in Sweden Second site Process transferred from first site Process validation underway First inspection (of four that ultimately happened)

Supply Chain Primary API Manufacturer (US) Secondary API Manufacturer (Sweden) Formulator (US) Packager (Canada) INSPECTIONS FDA (3) FDA (1) FDA (2) EMEA (MHRA) NONE

Pre-Visit Inspection Notification received approximately 2 months prior to inspection –Four days planned, two inspectors Two day site pre-visit planned with Encysive and manufacturer All major systems reviewed Validation documentation reviewed Major issues discussed and strategized Final check

Pre-Visit Inspection Logistics of inspection discussed –Who would be with inspectors –How would information be processed –What would sponsor’s role be

Planned Logistics - People Two inspection rooms prepared Two site people in each room –One QA person as direct interface –One scribe Back room headed by QA with ample support staff Selected sponsor representatives permitted in inspection room and back room

Planned Logistics – Communications Dedicated chat room set up for site Scribe in inspection rooms set up with interface All key site departments to monitor continuously Back room set up with individual monitors as well as projection to screen

Planned Logistics - Roles Site QA – primary response to all questions Sponsor – –in inspection room, only as requested by site QA –For questions related to filing –In back room, to provide input as needed and requested

Planned Logistics - Information All process documents, SOPs and validation documents collected into back room One copier dedicated for inspection team, loaded with “confidential” watermark paper Two copies made of any requested information Dedicated person for copies Dedicated runners for information transmission

The Inspection Two sponsor representatives arrived one day early –Final check on arrangements FDA arrived with two inspectors After introduction, immediately separated

How It Worked Wonderfully! Chat room was successful beyond expectations –Back room had heads-up on incoming information requests –Information was being prepared as FDA request was being voiced –Frequently had information or person available outside of room within seconds of request

How It Worked Sponsor in back room was able to see flow of information from both rooms in real time (but in Swedish!) Site had people assigned to both FDA and sponsor for breaks and meals –Segregation was assured

Sponsor Role Discussion of filing topics Discussion of site transfer activities Excused from topics regarding other products

Major Unresolved Topic Technical Transfer Protocol –Not a specific requirement –Topic addressed by sponsor each day –Protocol did not exist as specific document

Outcomes Inspection lasted most of four days Site answered all topics Site committed to change tech transfer SOP Sponsor committed to issue final tech transfer report at end of validation

Outcomes NO FDA-483 OBSERVATIONS “Approval” letter recommended and later received

Observations Site was completely engaged with inspection –All personnel –Entire QA group Interaction with sponsor seen as positive by all End result achieved Model used successfully for other audits

Who is This Manufacturer Cambrex Karlskoga –Karlskoga, Sweden

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