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Keywords: Medical Devices / Pharma Project Management (Europe, USA, Japan), Quality Management, GMP Guidelines and Legislation, e.g., AMWHV, EU-GMP Guidelines I, II, IV (ATMP) & Annexes, ICH Guidelines and FDA/USA 21 CFR 4, 11, 210/211, 820; MEDDEV / MDCG, MPG / MPDG, MDD, 93/42/EWG, MDR/IVDR 2017/745-746; MDSAP); Usability (Usability / Human Factors and Usability Engineering acc. to IEC 62366 / FDA CDRH); DIN EN ISO 13485:2012/2016; Audits / Inspections e.g. FDA; Regulatory Affairs, e.g., Medical Devices (510(k), former STED Format), Pharma CMC Part – Module 3, Combination Products / Companion Products, Phyto-Pharmaceuticals, e.g., Registration in Germany Europe, USA, Japan, Korea, Canada, Australia, Brazil); Work- and Organizational Psychology, Communication, Stress-Management, Audit Psychology - audit preparation of personnel, In-House Training & Lecturer for Quality Management.
For more information, please click on the following topics:
Consulting and hands-on support, e.g., issue or review of documents like quality manuals, PQRs / APRs according to EU-GMP Guideline part I - 1.10 (drugs) or part II - 2.6 (APIs) and ICH Q7 / 21 CFR 211, SOPs or forms, performance of GxP audits and gap-analyses, with the objective to establish a status of "optimum compliance" with legal requirements (e.g., EU / US GMP; GDP Guideline 2013/C 343/01), EU-directives and ISO standards (e.g., 9000 et seqq., 17025, 13485), which brings an added value to the quality and production processes --- quality management based on scientific understanding, and risk-based assessments that fits pragmatically and applicably into the existing system (e.g., people, stakeholder, corporate culture), considering the cost-benefit ratio.
In addition to the German national legislation AMG / AMWHV | MPG, requirements of, e.g., the US cGMP (e.g., 21 CFR Parts 210, 211, 820 QSR, 11, 4 [Final Guidance]), the ICH Quality Guidelines (e.g., Q7, Q9(R1) [2023], Q10), the harmonized ISO standards, the MDD / MDR or IVDR and the quality factors according to the 9 chapters of the EU GMP Guideline Part I, as well as Annexes 1 - 21 and if applicable Part IV (ATMP) are considered:
Chapter 1: Pharmaceutical Quality System
Chapter 2: Personnel
Chapter 3: Premise and Equipment
Chapter 4: Documentation
Chapter 5: Production
Chapter 6: Quality Control
Chapter 7: On Outsourced activities
Chapter 8: Complaints and Product Recall
Chapter 9: Self-Inspection
Sciene-based writing of clear technical documentation, e.g., former STED format ("nlVDMAToC" or "IVDMAToC", March 2019) and regulatory documents, i.e., modules 3 and 2.3 of the "Common Technical Documents (CTD)", which are accepted by authorities, e.g., "Drug Master Files, DMFs", "Active Substance Master Files, ASMFs", "Certificates of Suitability, CEP," "Investigational Medicinal Product Dossiers, IMPDs", "Investigational New Drugs, INDs" for national and international registrations (e.g., EU, USA, Canada, Japan), as well as preparation and editing of eCTD according to ICH guidelines M2, M8 with commercially available software.
Under the Mutual Recognition Agreement (MRA), the number of routine FDA inspections in Europe is likely to decrease in the future. However, FDA will continue to perform some "product manufacturing assessment inspections" in recognized countries (currently 27 countries recognized between November 2017 to July 2019), to support marketing approval decisions.
A lot is heared and read about the horrors of FDA inspections and also as many tips about strategies to deal with them are circulating. But, there is no such a thing like the FDA inspection!
FDA inspections depend on the hard facts, as documentary evidence of quality (written evidence), but are influenced as well to a large extent by individual personality characteristics of inspectors and auditees, the so called audit psychology. For this reason it is necessary to develop for each inspected company an individual approach to ensure that the inspection will be a success, i.e., no FDA form 483 observation is filed. In order to apply optimal measures, I have researched in recent years in many actually inspected companies on the complex psychology of the entire inspection phase, from the announcement to the completion of possible reworkings. Typical steps for the preparation and moderration of FDA audits in the field of pharmaceutical and medical technology are:
Further information:
Employees or "Human Resources" are the capital of a company. Therefore, employee satisfaction and the environmetal fit of new employees --- regarding internal placement or employment --- are very important for the optimization or development of a company, especially for small and medium-sized enterprises. In this context, I offer the following services:
Training for individuals or groups in the regulated industry. A typical course covers the following topics, which can be customized, e.g., supplemented or shortened:
The necessary qualifications are available that allow a co-payment / reimbursement by German health insurances according to § 20 SGB V (German Social Security Code).
In order to be able to optimize and to develop systems and processes, you need "evaluable" information from experts of these systems and processes. Laboratory talks, informal networking or individual opinions of individual, particularly communicative employees or customers are not to be regarded as "evaluable" information.
With the help of anonymous employee or customer surveys that are standardized and statistically evaluable (online and / or paper based), questions that are specifically developed for the company about the typical processes, as well as exploratory free-text boxes that can provide representative indications of previously unknown trends in the employee or customer opinion. A survey comprises the following steps:
Figure: In my projects, I am working according to a comprehensive, "transactional" quality management approach
that comprises the socio-cultural perspective as well as the technical perspective.