FDA査察対応セミナー 4章

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FDA査察対応セミナー
1章 FDA査察について
2章 FDAによる法的措置の統計
3章 査察からW/Lまでのフロー
4章 査察スケジュールについて
5章 査察対応組織
6章 FDA査察の準備
7章 査察対応の考え方
8章 FDA査察と内部監査
9章 GMPにおけるシステム査察
10章 医療機器における査察
11章 品質システムとは
12章 FDA査察とCAPA

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[blogcard url=”https://ecompliance.co.jp/SHOP/L_FDA.html” title=”【VOD】FDA査察対応セミナー・入門編” content=”演者は年間10件程度のFDA査察対応を実施しています。本セミナーでは、FDA査察を全般的にまた具体的にわかりやすく解説します。

米国に医薬品・医療機器を輸出している企業は輸出実績に関わりなく、FDA査察を受ける可能性があります。
日本におけるFDA査察はどのように実施されるのでしょうか。本セミナーでは、演者のこれまで多くのFDA査察対応コンサルテーションや、実際のFDA査察に立会った経験からFDA査察対応のノウハウを惜しみなく説明いたします。

FDA査察の目的は、『粗悪な医薬品・医療機器・体外診断用医薬品の米国輸出を阻止し、米国における患者・ユーザを保護する。』ということです。したがって、企業は、自社の製品が安全で安心できるということをFDA査察官に客観的な証拠(文書)を提示して証明する必要があります。
指摘事項が何もない場合は良いのですが、指摘事項がある場合は、連邦食品医薬品化粧品法704(b)項「査察官は指摘事項を文書で製造所に提示すること」に基づいて、査察の最後の講評時(クローズアウトミーティング)に、FDA Form 483が発行されます。

クローズアウトミーティングにおいて、査察官との対話は誤解や説明の間違いを正す機会でもあります。 企業からの意見を査察官が考慮し、FDA Form 483の最終版を作成してくれますので、すでに改善した事項があれば説明すると良いでしょう。FDA Form 483には「最終的な評価はFDAコンプライアンス部門で実施されるので、FDA Form 483は査察時の指摘事項としての報告である。」と記載されています。
FDA Form 483により指摘された内容に対し、15営業日以内(必着)に改善策、スケ ジュールを盛り込んだレスポンスをFDAに送付しなければなりません。
FDAは、2009年8月発表のFederal Registerで 「FDA査察の指摘事項(FDA Form 483)への回答期限を15日以内とする。Warning Letterを速やかに出せるようにするためである。」 と通知しました。

FDAに対するレスポンスは、査察を実施した査察官宛に送付するのではなく、FDA本部に送付することに注意が必要です。指摘へのレスポンスは極めて詳細である必要はありません。また次回査察時に改善実施について確認されるので、確実に改善ができることを書くことが重要です。つまり、机上の空論のようなことは書いてはいけません。

FDA Form 483の回答が不十分であれば、Warning Letterをもらうことになってしまいます。;;
FDAは、2014年10月に「医薬品査察の遅延、拒否、制限、拒絶に相当する状況についてのガイダンス」を発行しました。つまり【査察妨害】に関するガイダンスです。

では、いったいどんな行為が【査察妨害】に相当するのでしょうか。

FDA査察においてはFDAの要求事項(21 CFR)への深い理解が求められることはもちろん、査察本番における適切な資料のスピーディーな提出も必要となります。

本セミナーでは、まずFDAの要求事項や指摘事項等などの理論面を解説し、さらに当社が経験してきた実際のFDA査察事例をもとに、FDA査察本番でとるべき対応をわかりやすく説明します。
また、来るべき査察時に使える「FDA査察対応計画書」、Form483への「回答書のサンプル」を電子ファイルにて配布いたします。”]

[blogcard url=”https://ecompliance.co.jp/SHOP/EL-005.html” title=”【セミナービデオ】FDA査察対応セミナー【入門編】
” content=”演者は年間10件程度のFDA査察対応を実施しています。本セミナーでは、FDA査察を全般的にまた具体的にわかりやすく解説します。

米国に医薬品・医療機器を輸出している企業は輸出実績に関わりなく、FDA査察を受ける可能性があります。
日本におけるFDA査察はどのように実施されるのでしょうか。本セミナーでは、演者のこれまで多くのFDA査察対応コンサルテーションや、実際のFDA査察に立会った経験からFDA査察対応のノウハウを惜しみなく説明いたします。

FDA査察の目的は、『粗悪な医薬品・医療機器・体外診断用医薬品の米国輸出を阻止し、米国における患者・ユーザを保護する。』ということです。したがって、企業は、自社の製品が安全で安心できるということをFDA査察官に客観的な証拠(文書)を提示して証明する必要があります。
指摘事項が何もない場合は良いのですが、指摘事項がある場合は、連邦食品医薬品化粧品法704(b)項「査察官は指摘事項を文書で製造所に提示すること」に基づいて、査察の最後の講評時(クローズアウトミーティング)に、FDA Form 483が発行されます。

クローズアウトミーティングにおいて、査察官との対話は誤解や説明の間違いを正す機会でもあります。 企業からの意見を査察官が考慮し、FDA Form 483の最終版を作成してくれますので、すでに改善した事項があれば説明すると良いでしょう。FDA Form 483には「最終的な評価はFDAコンプライアンス部門で実施されるので、FDA Form 483は査察時の指摘事項としての報告である。」と記載されています。
FDA Form 483により指摘された内容に対し、15営業日以内(必着)に改善策、スケ ジュールを盛り込んだレスポンスをFDAに送付しなければなりません。
FDAは、2009年8月発表のFederal Registerで 「FDA査察の指摘事項(FDA Form 483)への回答期限を15日以内とする。Warning Letterを速やかに出せるようにするためである。」 と通知しました。

FDAに対するレスポンスは、査察を実施した査察官宛に送付するのではなく、FDA本部に送付することに注意が必要です。指摘へのレスポンスは極めて詳細である必要はありません。また次回査察時に改善実施について確認されるので、確実に改善ができることを書くことが重要です。つまり、机上の空論のようなことは書いてはいけません。

FDA Form 483の回答が不十分であれば、Warning Letterをもらうことになってしまいます。;;
FDAは、2014年10月に「医薬品査察の遅延、拒否、制限、拒絶に相当する状況についてのガイダンス」を発行しました。つまり【査察妨害】に関するガイダンスです。

では、いったいどんな行為が【査察妨害】に相当するのでしょうか。

FDA査察においてはFDAの要求事項(21 CFR)への深い理解が求められることはもちろん、査察本番における適切な資料のスピーディーな提出も必要となります。

本セミナーでは、まずFDAの要求事項や指摘事項等などの理論面を解説し、さらに当社が経験してきた実際のFDA査察事例をもとに、FDA査察本番でとるべき対応をわかりやすく説明します。
また、来るべき査察時に使える「FDA査察対応計画書」、Form483への「回答書のサンプル」を電子ファイルにて配布いたします。”]

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