Welcome to Compliance Consultants...

...the more you learn...the more you will want us for FDA!

 

 

C2  considers that regardless which system: Good Manufacturing Practices, Quality Systems or ISO 9000 is integrated into your manufacturing, the ultimate goal must always remain: give the customer what is advertised and what is expected.

 

C2  brings both engineering {good science} and regulatory skills {good  communications}to support the analysis and implementation of quality systems. Our process achieves:

 

Compliance that is more likely achieved in in the first round of audits,

 

Lower overall manufacturing costs are realized; and 

 

Fewer product related customer issues occur.

 

Objective

Our process consists of an Analysis, Implementation of the System, then maintenanceto allow easy changes ensuring the system can be modified to represent actual activities on the factory floor.

 

Engineering Tasks & Analysis

Our process extends to all production issues,such as: 

Specify all components {& qualify

all vendors};

 

Define all performance requirements {substances, processes, etc.}; 

 

Optimize batch runs, 

 

Ensure repeatability  of advertised  product,

 

            Establish performance dynamics; and 

 

            Devise a manufacturing process that

            best suits all final components.

 

 

Management responsibilities

Quality Policy,

Organization,

Responsibility and Authority,

Verification Resources and Instruction,

Management Representative,

Management Review,

Quality in design,

Documentation requirements,

Purchasing,

Product traceability,

Quality in production,

Inspection and testing,

Calibration,

Audits,

Statistical techniques,

Non-conformance,

Handling and storage,

Training and servicing,

Quality costs,

Product safety,

Remedies.

 

Contract Review

Requirements

Resolving Differences

Contractual Capability

Records

 

Sales Purchase Order

This verifies the authenticity of the sale.

 

Design Control

Design Controls are the single most recent addition that caused GMP to become Quality Systems. The FDA extended their control to include design as well as manufacturing. In our analysis we cover:

 

Design and Development Planning

Specifications/Design Inputs and Outputs

Design Verification/Design Reviews

Failure Modes Effects Analysis & Reliability Assessment

Parts & Materials Quality Assurance

Software Quality Assurance

Design Transfer/Certificate/Release

Documentation/Design History Record

ISO Assessment and FDA Inspection

 

Design and Development Planning

Activity Assignment

Organizational and technical Interfaces

Design Input

Design Output

Design Verification

Design Changes

 

Purchasing

General Information

Assessment of Subcontractors

Specifications to define/ control  Subcontractors

Purchase Order

Verification of Purchased Product

Purchaser Supplied Product

 

Document Control

Analysis of requirements

Planning documentation

Developing precise communication

Writing work instructions, policy statements and procedures

 

The Need For Documentation

benefits

the Standard

Identifying the Documentation

what is documentation

the structure of documentation

physical format

documentation control

Compiling the documentation

Analyzing requirements

Getting started

Compiling Procedures

Writing Work Instructions

Standard Forms

In-House National and International Standards

Archival Document Control

Publishing /Issuing Document

 

Identification and Traceabilty

Process Control

General Information

Special Procedures

Traceability - Relate purchased parts to kitted parts - production Batch, serial #’s,

customer.

 

Inspection and Testing

Receiving Inspection and Testing

In Process Inspection and Testing

Final Inspection and Testing

Inspection and Test Records

Inspection Measuring and Test equipment

Calibrated Equipment

Test Hardware

Inspection and test Status

 

Control of Non-Conforming Product

Review and Disposition,

Material Review Board,

Dedicated Stock Room.

 

Corrective Action

Investigation

Analysis

Preventative Action

Control

Recording of Procedures Changes

Handling Storage Packing and Delivery

General Information

Handling

Storage

Packaging

Delivery

 

Records

Indexing Filing and Storage

subcontractor Records

 

Internal Quality Audits

How Internal Audits Maintain Control of System

Basic Philosophy of Assurance vs. Inspection

Interaction of Different Requirements

The Audit Cycle

The audit system

Audit program

Formatting an Audit Plan

Process Breakdown

Strategy

Checklists

Attributes and Practices

Questionnaires and Checklists

Methods of Getting Information

Recording Objective Evidence

Categorizing of Non-Compliance

Human Aspects of Auditing

Status and Importance

Follow up Actions

Training

Servicing

Statistical Techniques

Process Capability

Process breakdown

Audit environment

Strategy

Checklists

Attributes and practices

Non-conformities

Categories

Recording

Evaluation

Reporting the audit

Corrective action

Post activities

Follow up

 

Quality Systems & EN/ISO Quality Standards

Scope of GMP and EN 2900/ISO 9001

Management Responsibility

Production and Process Controls

Design Controls/Design History Record

Documentation and Quality Records

Inspection and Testing

Nonconforming Components and Devices

Corrective Action

Device Master Record and Device History Records

Packaging and Labeling Control

Product Identification and Traceability

Complaints/MDRs/Servicing

Purchasing/Handling/Storage/Distribution

Training/Personnel Requirements

Calibration

Medical Device Directive

Software Quality Assurance

The FDA Inspection

 

QA Manual

The QA manual declares and calls into existence these functions and describes their activities in the company:

Role QA

Declare Activities

Define Forms

Master Device Record

Responsibility

Organization Report

Role - Mfg., Eng., Mfg Customer

Life Cycle

Critical

Inspection

Proceed Mfg - Move

MRB

Training

Forms Definitions

Employee Affirmation

Define Remedies

content,

structure

elements of a quality system

addressing the clauses

Approval and Issues

Changes and Modifications

Procedures

identifying document requirements

planning

 

Employee Handbook for Production

Assembly Procedure

Methods Brochure, Drawings

Move Tickets

Inventory Control-Batch

Kitting

Run Control

MRB-rework/shrinkage/reject

Part Number Storage Assignment

 

Device Master File

Configuration Parts List indicate serialized/batched parts

ECNs

Drawings to Define

Build Procedure

Spec. - source control

Inspection

Certification of Compliance

510K Letter

Device Listing

User Manual

Labeling

Testing, Production

Testing, Design Performance (Weight)

 

Calibration

Certificate of Compliance/Receiving Report

Certified Test Sets

Calibration Standards

 

Incoming Inspection Plan

Define critical parts for product.

Incoming

Final

 

Test Data Records

Collect all test results for incoming inspection, performance test and final inspection.

 

Training

Skills - Defines personnel responsibility & training required.

Log - Tracks personnel & training required.


Remedies Product/Recall/Failure Field

Analyze Scenarios

Identify Quality Problems

Write Non-Compliance

Analyze Quality Problems

Analyze Non-Compliance

Non-Conformance

Categories

Recording

Evaluation

Reporting and Requirements

Corrective Action

Post Activities

 

As Build Control Sheet

 

Packing List

Specify components; 

Performance requirements {material, Dimensions, attributes, etc};

Shelf life {attributes} of stored drug;

Repeatability of advertised drug delivery; Performance dynamics;

Manufacturing processes/methods;

Drug labeling system; and

Part numbering. 

 

Quality System Certification

Inquiry,

Application,

Assessment,

Registration,

Follow-up.

 

copyright by Compliance Consultants, Stamford, CT USA, September 2001

 

 


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  Compliance Consultants
1151 Hope Street
Stamford CT 06907 USA
voice 203 329 2700
fax 203 329 2345