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GxP Lifeline
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    Final FDA Rule on Dietary Supplements (21 CFR Part 111) Guidance

    In June 2007, the U.S. Federal Drug Administration issued the Dietary Supplement Current Good Manufacturing Practice (CGMP) Final Rule (21 CFR Part 111). In essence, the final rule requires that the proper controls be in place for dietary supplements during manufacturing, packaging, labeling, and holding operations.

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    Optimizing Your eCTD Submission: How to Achieve an Efficient and Timely Review - GxP Lifeline

    Ginny Ventura of the FDA?s Review Technology Staff shares the top 12 mistakes in eCTD submissions she sees nearly every day

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    Do's and Don'ts in Process Mapping for Life Science Companies

    The medical device and pharmaceutical industries are built upon process orientation to complete tasks in a uniform and documented fashion. Both industries also depend upon a systematic series of linked and reproducible activities completed by trained people to enable inputs to become outputs and outputs to realize a return on investment.So, how does process mapping help these industries in turning inputs into predictable outputs that would help them comply with regulations, as well as realize co

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    Death by CAPA: Essential Elements of Effective CAPA Systems

    The end result objective of a corrective and preventative action (CAPA) is, quite simply, a solution to the issue from which the CAPA was generated. If it is not driving toward a solution, a CAPA is a waste of time and resources. For organizations in regulatory environments, CAPA is an overarching umbrella—all control points flow through to the CAPA system.

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    Sizing Up Staff Competency Article

    Training employees to perform tasks in a laboratory or technical environment is critical to the success of any regulated business. Assessing employee skill levels is one way to see if employees are comprehending what they are learning.

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    Tissue Banking - Good Tissue Practices GTP - Regulations, Operations and Medical Oversight

    An Interview with Ted Eastlund, M.D., by Robyn Barnes

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    Designing a Learning and Performance Program in Tissue and Organ Banking

    Keeping up with the changes and the training in tissue and organ banking is an ongoing process. We know what works well and what doesn't. We know with a field-based staff that classroom training is difficult to pull off when trying to coordinate everyone's schedules and of course working around the case load. What we have found is that online learning or on-demand learning does work. This allows all of the staff to access training when and where they need it. We currently offer the following typ

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  • How to Practice Quality Management in Your Personal Life

    “Quality management” is one of those terms that sounds so simple and esoteric at the same time, like DNA or free cash flow. I’m pretty sure I know what those terms mean until I start explaining them to someone. 

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  • When You Find Yourself Between a Rock and a Hard Place

    We all have those days where everything that can go wrong, does. Where it seems the entire universe is working against you, testing your patience, your determination and your will to carry on. But in the scheme of things, are these so-called bad days really

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  • The Most Important Four-Letter Words in ISO 9001:2015

    Most organizations are well under way with the transition to the new ISO 9001:2015.  As such you should be very familiar with the emphasis on two four-letter words found throughout the document ….

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  • Brave New World: The Mutual Recognition of CGMP Inspections

    Last week, the United States and the European Union agreed to recognize each other’s drug cGMP inspections. The agreement reached (see

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  • Supplier Approval Challenges Under FSMA

    As a food safety and regulatory consultant, I work with diverse clients who face many different challenges with Food Safety Modernization Act (FSMA) implementation. The ones that are the hardest to address fall into the intersection between company policy and regulatory requirements. Supply-chain approval is a major challenge for many larger corporate clients, as well as smaller clients who must remain flexible to maintain profitability. The requirements of the Foreign Supplier Verification Prog

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    FDA Crisis: An Attrition of Brain Power

    If people are an organization's greatest asset, the FDA's current ""people status"" is one of serious attrition.

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  • How to Lead with Respect

    “Over time I’ve come to realize that engaging in this problem-solving process is actually the highest form of respect….The manager truly respects the employee’s knowledge and his or her dedication to finding the best answer….Only by showing mutual respect-- each for the other and for each other’s role-- is it possible to solve problems, make work more satisfying, and move organizational performance to an ever-higher level.”

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  • Supplier Qualification: An Important - and Often Neglected - Validation Component

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  • Surviving Live Data Inspections by the FDA---3 Critical Success Factors

    I have long been a supporter of being well prepared for FDA inspections, including how data is presented during the inspection. Historically, you’d print the files for FDA review rather than do a live demonstration of the database information. While I haven’t experienced it yet, it is my understanding that the FDA is now requesting a “live” data review. Essentially the expectation is for you to walk the inspector through your files and explain the information rather than have you print and organize paper files before they see it.

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    GCP Compliance: Eliminating Silos between Clinical Quality and Clinical Operations

    In a classic episode of Seinfeld, George Costanza is terrified of the potential ramifications of his “worlds colliding” when his fiancée, Susan, becomes friendlier with his dubious pals Elaine, Kramer and Jerry. “Everybody knows you’ve got to keep your worlds apart,” George rants (but when does George not rant?) “If Susan is allowed to infiltrate this world then George Costanza as you know him ceases to exist. If Relationship George walks through this door, he will kill Independent George! A George divided against itself cannot stand!”

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    Factoring Regulatory Strategy into New Product Development

    It is unfortunate that so many new medical devices and new generation product launches are delayed due to the absence of regulatory input at the beginning stages of design control and the new product development process.

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    Retraining and Refresher Training: Aren’t They One in the Same?

    Ask an operations manager and he’ll acknowledge that what it’s called is less important than getting the “assignment” done and entered into the LMS. He’s usually more concerned about the loss of productivity during the training than the effectiveness of the training at that time. It isn’t until later when the training may have to be delivered again (repeated), that the comment “training doesn’t really work” is heard.

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    Pros and Cons of Proposed PDUFA IV User Fee Increase From FDA - For Pharmaceuticals

    FDA Proposes PDUFA User Fee Increase to Boost Drug Safety

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