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FDA Inspection – Procedures, Compliance, and Regulatory Guidelines-11.docx
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FDA Inspections: - ANS✔✔ Under the Food, Drug, and Cosmetic Act, the Food and Drug Administration (FDA) has the power to inspect clinical investigators, sponsors, contract research organization (CRO), institutional review board (IRB), and other parties involved in clinical trial conduct. This is done through the Bioresearch Monitoring (BIMO) program. The goal of the BIMO program are: - ANS✔✔ 1. To protect the rights, safety, and welfare of subjects involved in FDA-regulated clinical trials
-The inspection is typically study-specific and is usually pre-announced to sponsor / CRO in advance. List of events that may occur during an FDA inspection: - ANS✔✔ 1. Notice of inspection and credentials
Area of focus during an FDA inspection of sponsor / CRO may include: Adverse Event Monitoring / Reporting - ANS✔✔ 1. Review of systems / process for adverse events tracking 2 Reporting of adverse events to regulatory authorities, review boards, and other investigational sites. Area of focus during an FDA inspection of sponsor / CRO may include: Data Handling / Data Verification - ANS✔✔ 1. Procedure and process for data handling (e.g. standard operating procedures)
FDA Warning Letter (WL): - ANS✔✔ A Warning Letter is a formal notification that allows prompt voluntary corrective action to be taken. The sponsor / CRO must provide formal respond to the Warning Letter within a specified time allowed. Warning Letter is also public information that will be posted on FDA website. FDA Inspection of Clinical Trial Site: - ANS✔✔ FDA conducts clinical trial site inspections to determine if the conducting of the clinical studies is in compliance regulatory requirements. Investigators who conduct FDA-regulated clinical trials are required to permit FDA investigators to access, copy, and verify any trial related records or reports Possible reasons behind an FDA inspection of a clinical trial site: - ANS✔✔ 1. To verify the accuracy and reliability of data that has been submitted to the agency
documents were signed by the subject or the subjects' legally authorized representative prior to entry in the study Areas of focus during an FDA inspection of clinical trial site may include: Data Collection - ANS✔✔ 1. How the study data were obtained and where the study data were recorded
Areas of focus during an FDA inspection of clinical trial site may include: Electronic Data - ANS✔✔ Whether or not 21 CFR 11 requirements have been met Areas of focus during an FDA inspection of clinical trial site may include: Adverse Events - ANS✔✔ Whether prompt and complete reporting of adverse events to the IRB and sponsor Areas of focus during an FDA inspection of clinical trial site may include: Record Retention - ANS✔✔ Whether record retention was done following the protocol and regulatory requirements Areas of focus during an FDA inspection of clinical trial site may include: After the Inspection - ANS✔✔ 1. A FDA form 483 may be given to the investigator.