FDA Inspection Wizard: What’s Scary Can Turn Out to Be a Piece of Cake

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FDA Inspection Wizard: What’s Scary Can Turn Out to Be a Piece of Cake

 Although FDA inspections of clinical sites are not an indictment of something being wrong with a clinical site, it can nevertheless still be a scary experience, especially if you are not properly prepared.
An FDA inspection is basically a quality assurance process that is used to confirm clinical data management/integrity and regulatory compliance.  Here we show you how to make it a piece of cake for your site and your nerves.
Kinds of inspections

Verdana;mso-bidi-font-family:Verdana">-       The most common FDA inspection is the ‘routine inspection’, prompted by a New Drug Application (NDA) submission.  The typical candidates for a routine inspection are clinical sites that enroll the majority of patients in the NDA’s critical clinical  trials.

Verdana;mso-bidi-font-family:Verdana">-       ‘For Cause inspections’ are not common, and are prompted when the FDA receives a report of, or becomes aware of, suspicious behavior.  Here are some reasons that may bring about such an audit:

font-family:"Arial","sans-serif"">_ The carrying out of many clinical trials


font-family:"Arial","sans-serif"">_ The carrying out of clinical studies outside of your specialization field


font-family:"Arial","sans-serif"">_ The reporting of much better effectiveness, less unfavorable effects, or different laboratory results from other sites studying the same drug


font-family:"Arial","sans-serif"">_ Having noticeable access to a large number of patients with a specific disease state for the setting


font-family:"Arial","sans-serif"">_ Complaints from a patient or sponsor in regards to regulations, protocol, or human rights violations


font-family:"Arial","sans-serif"">-Customer complaints that may trigger a product recall

How it all starts
It all starts with a phone call.  The FDA will call to program an inspection at a time that is agreed between both parties and that does not interrupt the site’s activity.  Nevertheless, they will only give you between 5 to 14 days notice, and will spend around 2 to 3 days on site.
You are entitled to ask what study they are going to inspect and who should be available during the visit, and contact the study sponsor immediately, because this sponsor can give you good suggestions and they are not directly notified by the FDA about clinical site inspections.
Before the inspection, gather these documents for the study in question:

Verdana;mso-bidi-font-family:Verdana">-       Protocol

Verdana;mso-bidi-font-family:Verdana">-       Investigator’s brochure and IND Safety Reports 

Verdana;mso-bidi-font-family:Verdana">-       Form FDA 1572 with accompanying CVs

Verdana;mso-bidi-font-family:Verdana">-       IRB correspondence, including approval documentation and final report to IRB and Sponsor

Verdana;mso-bidi-font-family:Verdana">-       IRB-approved Informed Consent form

Verdana;mso-bidi-font-family:Verdana">-       IRB-approved advertising

Verdana;mso-bidi-font-family:Verdana">-       Correspondence related to the study, excluding investigator agreement and financial information

Verdana;mso-bidi-font-family:Verdana">-       Monitor sign-in log

Verdana;mso-bidi-font-family:Verdana">-       Laboratory certification documents

Verdana;mso-bidi-font-family:Verdana">-       Drug accountability records

Verdana;mso-bidi-font-family:Verdana">-       Each subject’s signed informed consent

Verdana;mso-bidi-font-family:Verdana">-       Assess support areas, like pharmacy or lab, to make sure they are properly prepared.  The FDA may tour the facility
Be ready to answer these questions:

Verdana;mso-bidi-font-family:Verdana">-       Where was the study done?

Verdana;mso-bidi-font-family:Verdana">-       What special equipment was used?

Verdana;mso-bidi-font-family:Verdana">-       Who assisted in doing the study?

Verdana;mso-bidi-font-family:Verdana">-       What were each person’s specific responsibilities?

Verdana;mso-bidi-font-family:Verdana">-       Describe the sponsor’s monitoring procedures and your interaction with the monitor.

Verdana;mso-bidi-font-family:Verdana">-       How did you account for the drug received, distributed to, or returned from subjects?  Were all drugs returned to the sponsor?
Train your personnel to relate to the FDA.  You must show you are a professional and should answer questions in a direct way, without giving information they haven’t requested. 
When the inspector arrives
First, check his ID, because you don’t want an unauthorized person checking your files.  The inspector will fill a Notice of Inspection (FDA Form 482) and will hand it to you.

Arial">1.        The inspector will begin by determining the nature of the investigator’s conduct of the study.  He may want to tour the facilities and talk to everyone who took part in the study. 


font-family:"Arial","sans-serif"">His intention is to establish the level of delegation of the investigator’s authority, where specific procedures were performed, where and how the data was gathered, and where the drug was accounted for and stored.


font-family:"Arial","sans-serif"">These things are normally checked:

Verdana;mso-bidi-font-family:Verdana">-       Communication capability with the IRB, including the initial submission document, adverse event reporting, and progress reports

Verdana;mso-bidi-font-family:Verdana">-       Totality of accountability documentation for the receipt, storage, administration, and return of test article (drug, device, etc.)

Verdana;mso-bidi-font-family:Verdana">-       Compliance with the study protocol and documentation that each deviation/amendment received the approval of the IRB and the sponsor

Verdana;mso-bidi-font-family:Verdana">-       Aptness of the informed consent process

Verdana;mso-bidi-font-family:Verdana">-       Timely and full reporting of adverse events to the IRB and sponsor

Verdana;mso-bidi-font-family:Verdana">-       Compliance with the record retention requirements and that the investigator had instant access to the study records during the trial

Verdana;mso-bidi-font-family:Verdana">-       Ample monitoring of the site and communication with the sponsor

Arial">2.        The inspector will move on to audit the data.  He will compare the data submitted to the FDA with the medical charts and source documents that support it. 


font-family:"Arial","sans-serif"">He will review data from before and after the subject’s participation to make sure the subject had the medical condition under treatment and that excluded medications were not given to him or her during the study period. 

Arial">3.        After finishing the audit, the inspector will meet with the investigator to talk about the results.  Any inconsistencies will be registered on FDA Form 483, of which you will receive a copy.     

Arial">4.        The inspector will write an Establishment Inspection Report (EIR) that will be sent to the FDA for evaluation.  You will receive a letter after this evaluation is finished.

font-family:"Arial","sans-serif"">This letter may show one of three scenarios:


Verdana;mso-bidi-font-family:Verdana">-       It may simply recognize that the inspection was done and that nothing significant was found.

Verdana;mso-bidi-font-family:Verdana">-       It may list deficiencies found during the inspection, but may point out that no response is necessary.  Nevertheless, it is important that the site acts on these deficiencies in view of future inspections.

Verdana;mso-bidi-font-family:Verdana">-       It may point out serious negative discoveries.  The site and the data are at risk here, and you must answer immediately to clarify what steps you will take to solve the situation. 

font-family:"Arial","sans-serif"">Get the help of your sponsor, because the pharmaceutical company has lots to lose too, and contact your pharmaceutical consultant for guidance and support.

font-family:"Arial","sans-serif"">If you do not respond correctly, you may be banned from performing other studies; your study data, or even the whole marketing application, can be rejected; and you may even face criminal charges.
The EIR is available, upon request, to the site, sponsor, and general public, after 4 to 6 months through the Freedom of Information Act.    

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Nigel Smart
Nigel Smart is a pharmaceutical consultant and founder of the pharmaceutical consulting blog.