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5 Imperatives to Address the Remediation Plan for FDA-483 Observations

Author: Mayra I. Rosa-Pagan, Lead Consultant

After facing notification of the regulatory inspection results, it is important to address the findings with diligence and accuracy to complete the commitments satisfactorily.   Following are five (5) imperatives to manage your remediation plan.

  1. Understand the findings

Be certain of understanding the context of all observations and the evidence that was identified during the inspection.

  1. Timely response

 Act immediately to begin the investigation and demonstrate diligence to the Agency. There are specified due dates to respond with adequate action plans to correct and prevent the issues identified during the inspection. Commit to act and deliver results.

  1. Thorough investigation

 Perform a comprehensive investigation, methods and processes must be evidenced showing that root causes were determined and are being addressed.

  1. Comprehensive response content

 Work with your Counsel on the proper documented response. Primary a...

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Fundamentals for a Robust CAPA System

“Quality is not an act, it is a Habit.” - Aristotle

Author: Mayra I. Rosa-Pagán, Lead Consultant

One of the pillars for an effective Quality Management System is to have implemented a robust Corrective and Preventive Action program, which we normally call it “the CAPA system”.

The CAPA system is not only considered the heart of well-efficient management system but it also provides enormous inputs to the continuous improvement efforts towards Quality. 

What are the fundamentals for a robust CAPA System?

1. Well-defined investigation procedure

Your procedure on how to conduct effective investigations is a basic requirement for the solid results and clear action plans needed within your CAPA System.

2. Data trending for prompt detection of potential issues

Have a comprehensive mechanism to collect data and perform periodic data and trend analyses. It will show you the current issues but most important is to identify potential problems that you can prevent.

3. Effective implementa...

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