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Conducting Internal Audits

Best Practices for GxP Compliance Auditing

  • 03/16/2009 - 03/17/2009

    Princeton, NJ

Agenda: Day Two

V. Conduct Internal Audits to Ensure GxP Compliance and Improve Performance

  • Compare auditing for effectiveness vs. compliance
  • Establish the phases of an internal audit
  • Examine the special considerations for auditing different functional areas
  • Define audit standards and execute a comprehensive, logical audit
  • Define major vs. minor observations
  • Evaluate audit findings and deliver an effective audit report

Exercise: Critique a Sample Audit Report

VI. Determine Appropriate Actions Where Non-Compliance is Identified

  • Examine common compliance challenges
  • Address objectionable observations
  • Provide recommendations for corrective and preventive actions (CAPA)
  • Identify methods to ensure corrective action follow-up
  • Write process deviations and failure reports
  • Manage remediations work after an audit

Exercise: Identify Common Causes of OOS Investigations and Brainstorm Possible Solutions

VII. Ensure Effective Management of Change

  • Examine the fundamentals of change control
  • Define areas to review in a change control program
  • Use complaint systems and annual product review to monitor for change

VIII. Use Internal Audits to Prepare for Regulatory Inspections

  • Anticipate and prevent potential problems and prepare audit plans
  • Develop skills to effectively manage the inspection
  • Define which records are required for various inspections
  • Analyze the inspection approach
  • Establish timelines for inspection preparation
  • Examine previous audit reports and all OOS notices since the last audit
  • Complete a pre-audit assessment
  • Learn how the site prepares throughout the inspection process

Exercise: Review Current FDA 483s and Warning Letters to Recognize Common Trigger Points

IX. Examine FDA Inspection Techniques

  • Determine how FDA inspectors conduct inspections
  • Identify key points, common observations and comply with FDA expectations
  • Examine proven solutions to challenging issues
  • Meet the challenges of the FDA's Systems-Based Inspection and quality systems inspection technique
  • Assess legal implications of FDA inspections
  • Compare U.S. vs. foreign inspections

Interactive Discussion: Do's and Don'ts During an FDA Inspection

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