If you're a
manufacturer or a processor of FDA-regulated products, you'll expect a visit
from FDA. the aim of this visit is to verify compliance with all relevant
regulations — most ordinarily stated as an “FDA inspection.” But not all inspections are created equal.
FDA performs four kinds
of inspections at many various kinds of facilities, and your company’s response
should be tailored to the precise sort of event. Facilities that represent
FDA’s watchful eye include:
ü Drug manufacturers
ü Device manufacturers
ü Blood banks
ü Food processing facilities
ü Dairy farms
ü Animal feed processors
ü Compounding pharmacies relevant to your FDA inspects
ü Facilities that conduct studies in people
ü Laboratories that conduct studies in animals (support FDA approval of
medical products)
FDA’s inspection
authority also extends to foreign manufacturing and processing sites for
FDA-regulated products sold within the US. Fall within these bounds, and you'll
expect an FDA inspection at your facility.
The four differing
kinds of inspections conducted by FDA are pre-approval inspection, routine
inspection, compliance follow-up inspection, and “for cause” inspection. Each is meant to assist protect the general
public from unsafe products, but the main target and expectations of every sort
of inspection are different.
Ø Pre-Approval Inspections are conducted
after an organization submits an application to FDA to market products for NDA
or ANDA. These inspections target verifying data included within the
application, and confirming that the firm is capable of producing said product.
At the end of inspection inspectors will recommend for or against FDA approval.
Ø Routine Inspections are expected at every
2 years for Class II and Class III device manufacturers. They follow a prescribed method referred to
as Quality System Inspection Technique (QSIT). If a heavy public health risk is
identified during a routine inspection, the inspection type may then switch to
a “for cause” inspection.
Ø Compliance Follow-Up Inspections
assures actions taken by a facility in response to a previous audit that
resulted in significant 483 observations or a Warning Letter. This inspection is
conducted to verify the adequate correction of previous discrepancies, to
document continuing violations, or to support future regulatory action.
Ø “For Cause” Inspections investigate a
particular problem that has been reported to FDA. The source of the report will
be the manufacturer (e.g., resultant of a recall, MDR), consumer/user
complaints, or perhaps a dissatisfied employee.
A “for cause” inspection will target the definite issue, but can expand
to hide unrelated elements of the firm’s operations. This inspection usually is
initiated at the request of CDRH, ORA, or regional directive. These inspections
typically are more in-depth than routine audits, and that they might not follow
a QSIT approach.
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