FDA GMP Training for Drugs, Pharmaceuticals, Medical Devices and Dietary Supplements


GMP, QSR and FDA Resources

Articles by David Markovitz
Personal Productivity
FDA Resources
Timely Resource Articles
cGMP for Dietary Supplements
cGMP for PET Drugs
INDs - CGMPs During Phase I Clinical Trials
Medical Gases
Medical Devices

Breaking News
cGMP for Dietary Supplements


Articles authored by David Markovitz

Practical Preparation for Effective GMP Training
Six Steps to Success!
   First published in the Journal of GXP Compliance, this article is the first of three parts aimed at developing an effective GMP training process.

Conducting Effective GMP Training:
Do’s and Don’ts for Success!
  First published in the Journal of GXP Compliance, this is the second of three parts.

Effective Follow-up Strategies
to GMP Training
   First published in the Journal of GXP Compliance, this is the final of three parts.

A Risk-based Approach to GXP Training:
One Size Does Not Fit All
  First published in the Journal of GXP Compliance, this article explores developing an effective GMP training process in sync with FDA's new risk-based approach.

A System of Leadership for the 21st Century 
Lessons from Theodore Roosevelt
  An unique perspective building on David's innovative approach of bringing Teddy Roosevelt Back to Life. 

Problem Solving is Not Good Enough!  Problem Prevention is the Key to Success  Effective use of After Action Reviews.


Personal Productivity
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100 Ways to Kill a Concept: Why Most Ideas Get Shot Down - This short e-book will help you become better at "selling" your ideas and creating a culture of innovation in your workgroup.

Innovation: More Than a New Year's Resolution - This short e-book will help you defy complacency in your work and career.

The Six Core Values of Innovation - This short e-book describes the six core values, or contexts, of innovation.

A Major Mistake That Managers Make - Article by Russ Ackoff, Ph.D.

A Little Book of f-Laws: 13 common sins of management - Article by Russ Ackoff, Ph.D.

Transforming the Systems Movement - Article by Russ Ackoff, Ph.D.

From Mechanistic to Social Systems Thinking - Article by Russ Ackoff, Ph.D.

Questionating - This short e-book will help you develop your skill in asking questions. It was W. Edwards Deming who said, "The questions are more important than the answers."

Nelson Mandela's Lessons of Leadership - Excellent article from Time

 


FDA Resources
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Innovation or Stagnation - Important report issued by FDA in March 2004, and revised and updated in 2005.

FDA Recall Data for FY 2005 - CDER recalls in FY 2005, Top Ten reasons

Centennial of the 1906 Pure Food and Drugs Act - First in a series of articles in 2006 that will highlight some of the popular perceptions of the 1906 Pure Food and Drugs Act

Dispute Resolution Guidance - Formal Dispute Resolution: Scientific and Technical Issues Related to Pharmaceutical cGMP Guidance Document issued January 11, 2006

FDA Enforcement Report February 1, 2006 - A sample of FDA's weekly Enforcement Report

The Regulation of Dietary Supplements - Congressional testimony by the FDA Director of the Center for Food Safety and Applied Nutrition on March 9, 2006

FDA's Deputy Commissioner Speech, March 14, 2006 - Scott Gottlieb, MD, FDA's Deputy Commissioner for Medical and Scientific Affairs address at  the 30th International Good Manufacturing Practices Conference at the University of Georgia College of Pharmacy

Human Drug CGMP Notes March 1999 - FDA's reference to Process Validation and "three consecutive batches"

Small Business Guide to FDA - FDA's handbook for small business.  Contains information about FDA's organization, procedures, policies, and regulations.

FDA Enforcement Report Aug 9,2006 - Selected excerpts from FDA's Enforcement Report highlighting GMP issues.

Current Good Tissues Practice Guidance Document - FDA Guidance for Industry issued September 2006.

Current Good Tissue Practice Regulation - FDA's regulation implemented in 2005.

Implementing Quality Systems - PowerPoint presentation by Chris Joneckis, PhD  FDA CBER  August 2006

Quality Systems Approach to Pharmaceutical cGMP Regulations - Guidance document issued September 29, 2006.

OOS Guidance Document - FDA Guidance for Industry issued October 12, 2006.

FDA presentation on ICH Q10 - Presentation by FDA on ICH Q10 - Quality Systems

FDA Consumer Safety Office job description - Read the job description for an FDA Investigator (Consumer Safety Officer).

ICH Q10 Pharmaceutical Quality System guidance document, July 13, 2007 - Read this new guidance document available for public comment.

A Parent's Guide to Kids' Vaccines July 31, 2007 - FDA Consumer Health Information article

FDA Report - FDA Science and Mission at Risk November 2007 - Read this disturbing report commissioned by the FDA.

Food Safety Tips for Healthy Holidays - FDA's Tips for Healthy Holidays

Speech by FDA Commissioner Feb 29, 2008 - Read this speech entitled "FDA at a Turning Point: Meeting the Challenge of a Rapidly Changing World" by Andrew C. von Eschenbach, M.D.

Laws Enforced by the FDA and Related Statutes - A listing of all the laws and statutes that the FDA enforces

FDA Manuals, Regulatory Publications, and Reports - A listing of all the FDA Manuals, Regulatory Publications, and Reports

 


Timely Resource Articles
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Continuous Improvement under Modern Quality Systems and cGMPs - FDA's Richard Friedman's presentation at the 2005 Drug Information Association meeting, June 26 - 30  Washington DC

Able Labs in USA Today July 12, 2005 - Read this interesting story published in USA Today.

Able Laboratories FDA 483 July 2005 - Read this fifteen page FDA 483 with twelve major observations.

Pharmakon Labs Shut Down July 27, 2005 - Read FDA's Press Release

Jury Award in Vioxx Trial - August 18, 2005 - First jury award against Merck

US Marshals seize infusion pumps, Oct 12, 2005 - FDA and US District Court work together to seize products manufactured by Baxter Healthcare Corp.

FDA Issues Consent Decree to MBI Nov 29, 2005 - Read FDA's Press Release

Google's Ten Golden Rules Dec 2, 2005 - Newsweek article describing how Google manages "knowledge workers"

Guidant Corp. FDA 483 Sept 2005 - Read this seven page FDA 483 with fifteen major observations

Guidant Corp. Warning Letter Dec 2005 - Read FDA's Warning Letter as a follow-up to the Sept 2005 FDA 483

Schering-Plough's Consent Decree - Read this 46 page Consent Decree issued in May 2002 to Schering-Plough Corporation

FDA Cease Manufacturing Letter Jan 31, 2006 - FDA's letter to Biomedical Tissue Services Ltd

Executives convicted May 3, 2006 - FDA's Press Release with details

Centennial of The Jungle - Read this fascinating story published on May 31, 2006 about the intricacies of how the landmark book, The Jungle by Upton Sinclair, led to the Pure Food and Drugs Act of 1906.

Protecting America's Health - Read this review of Philip J. Hilts' book, Protecting America's Health: The FDA, Business, and One Hundred Years of Regulation.

How Theodore Roosevelt Made Your Dinner Safe to Eat - Read this fascinating article published in American Heritage Magazine on June 29, 2006

Prescription for Harm: The Decline in FDA's Enforcement Activity - Congressional report issued June 27, 2006 by Rep. Henry Waxman

Rep. Waxman's statement June 27, 2006 - Statement upon release of Prescription for Harm report

Sanofi Pasteur FDA 483 April 2006 - Read this eight page FDA 483.

Sanofi Pasteur Warning Letter June 30, 2006 - Read this seven page Warning Letter.

FDA Q&A regarding Sanofi Pasteur Warning Letter - Gain valuable insights into FDA's thinking by reading this Question and Answer document released by FDA on July 3, 2006

FDA Commissioner Nomination Embroiled in Politics - Read this article published the day after the Senate held confirmation hearings on Andrew von Eschenbach's nomination as FDA's Commissioner.

Command Medical Products Warning Letter August 17, 2006 - Read this short Warning Letter and gain insights into FDA's thinking.

American Red Cross fined by FDA September 8, 2006 - Read this Press Release from FDA explaining why the American Red Cross was fined $4.2 million for violating GMP regulations.

USA Today Sept 12, 2006 - Dr. Graham Speaks Out - Read this article where FDA official Dr. David J. Graham speaks out about new arthritis drugs.

Graham's editorial published by JAMA - Dr. David J. Graham's editorial published by the Journal of the American Medical Association.

GSK recalls Paxil - Missing Active Ingredient - October 5, 2006 news article

FDA Newsletter from November 1962 - Historic photos of President Kennedy upon the advent of GMP

Bausch and Lomb FDA  483 May 2006 - Read this eleven page FDA 483.  Bausch and Lomb issued a recall of one of their products the day after receiving this 483.

Bausch and Lomb Warning Letter Oct 31, 2006 - Read this eleven page Warning Letter outlining systemic violations

Perrigo recalls acetominophen Nov 9, 2006 - News story detailing recall of 11 million containers of acetominophen for metal fragments

FDA Press Release - Medical Device Post Market Monitoring - Nov 9, 2006 - FDA's action plan for strengthening the way it monitors the safety of medical devices after they reach the marketplace.

Boston Globe news article  - Read this analysis of the impact of the November election and FDA as well as an analysis of FDA's action plan for Medical Device Post Market Monitoring

Why Drug Prices are High - An informative article by syndicated columnist Jay Ambrose published December 11, 2006.

New Congress to Split FDA? - Published January 7, 2007.  An article speculating that the new Democrat controlled Congress will split FDA into two agencies, one for the Foods industry, and one for the Medical industries.

GE OEC Medical Systems Consent Decree announcement - Read FDA's Press Release January 12, 2007 announcing this Consent Decree.

GE OEC Medical Systems Warning Letter - Read this Warning Letter issued in March 2005.

News account of GE OEC Medical Systems problems - Read this newspaper account about the problems facing this company.

The Birth of CGMPs - Read this article by FDA Historian Dr. Suzanne White Junod about the beginnings of the CGMP regulation.

Whistleblowers Help Congress Strengthen FDA - Read this February 2007 article.

FDA's announcement of Cardinal Health Consent Decree - Read FDA's reasons for obtaining this consent decree for condemnation and permanent injunction against Cardinal Health.

Cardinal Health Consent Decree - Read this 27-page Consent Decree for condemnation and permanent injunction.

Edwards Life Sciences Warning Letter - Read this eight page Warning Letter issued in February 2007

Actavis Totowa, LLC Warning Letter - Issued February 2007

GE Healthcare Technologies Warning Letter - Issued February 2007

First Check Diagnostics, LLC Warning Letter - Issued February 2007

Fisher and Paykel Healthcare Inc. Warning Letter - Issued February 2007

Medical Concepts Development Warning Letter - Issued February 2007

Niagara Pharmaceuticals Inc. Warning Letter - Issued February 2007

Rymed Technologies Inc. Warning Letter - Issued February 2007

Abbott Consent Decree - Read this landmark twenty-four page Consent Decree issued in 1999

Abbott Laboratories, Inc. Warning Letter - Issued to Abbott Diagnostics Division in March 2007

FDA Comes Under Fire - AGAIN! - Read this story from the Washington Post April 2007

Senate debates bill to increase power and money for FDA - Read this story from The New York Times May 2007

FDA Plans to Close Labs - Read this story from McClatchy Newspapers on this controversial plan by FDA to close and consolidate their laboratories May 2007

Advanced Medical Optics recall notice November 21, 2006 - Read this recall notice of a contact lens solution - contaminated batches

Advanced Medical Optics Recall of Contact Lens Solution May 25, 2007 - Read FDA's announcement of Advanced Medical Optics' recall of one of their contact lens solutions.

Chinese toothpaste advisory June 1, 2007 - Read FDA's advisory to avoid toothpaste containing diethylene glycol made in China.

Taste of Raspberries, Taste of Death - Read this chilling account of the 1937 Elixir of Sulfanilamide tragedy

Crystal Reflections International Warning Letter June 14, 2007 - Read this Warning Letter issued to a manufacturer of contact lenses. The change control system consisted of "post-it" notes!

Imported Generic Drugs on the Rise June 17, 2007 - Read this Washington Post story about the increase in generic drugs from India and China and FDA's challenge in inspecting plants in these two countries.

Shelhigh Consent Decree June 22, 2007 - Read FDA's Press Release announcing this consent decree for a manufacturer of heart valves.

Chinese FDA Chief executed July 10, 2007 - Read this startling article on China's former head of their FDA executed for taking bribes.

AIDS drug recalled July 23, 2007 - Read this article from the New York Times detailing the impact on poor people in developing nations of this contaminated AIDS drug.

Sunburst Biorganics Warning Letter August 7, 2007 - Read this Warning Letter to a New York company detailing the fine line between a Dietary Supplement and a Drug.

Swanson Health Products Inc. Warning Letter August 8, 2007 - Read this Warning Letter to a North Dakota company detailing the fine line between a Dietary Supplement and a Drug.

Proctor & Gamble Warning Letter September 14, 2007 - Read this Warning Letter detailing the difference between a sanitizer and a drug.

Contaminated beef leads to company shutdown October 5, 2007 - Beef processor forced to recall one year's production and calls it quits

Tylenol is Different ad campaign - Look at Tylenol's new advertising campaign "Tylenol is different because of the people who make it."

Med-South Pharmacy Inc. Warning Letter - An interesting look at drugs compounded by local pharmacies. Read FDA's comments on how these drugs are regulated. This is a good case study demonstrating the "c" in cGMP - keeping current with the ever evolving GMP regulation.

FDA Damned If It Does, Damned If It Doesn't - An interesting article published in Fortune about FDA's current strategies.

China Gets Serious on GMP  - China's State FDA is ramping up its enforcement of GMP, working with US FDA on safety pact. 

Dirty Tank Leads to Contaminated Products - Read this news account of an API manufacturer who hadn't cleaned a holding tank with a key starting raw material in years, and how it led to several batches of product getting contaminated.

G. Dundas and Company, Inc. Warning Letter December 13, 2007 - Read this Warning Letter issued because of an inadequate response to a Form FDA 483, List of Inspectional Observations.

Noven Pharmaceuticals, Inc. Warning Letter January 4, 2008 - Read this Warning Letter issued because of an inadequate response to a Form FDA 483, List of Inspectional Observations.

Recall Notice of Contaminated Syringes January 18, 2008 - Heparin and Saline pre-filled flushes recalled due to bacterial contamination.

Vintage Pharmaceuticals, LLC Warning Letter February 1, 2008 - Read this Warning Letter issued because of an inadequate response to a Form FDA 483, List of Inspectional Observations.

FDA Fines Red Cross $4.6M February 7, 2008 - FDA assesses another fine on the American Red Cross for distribution of unsuitable blood products. Fines in recent years now total more than $19 million.

Red Cross announcement of fine - February 7, 2008 - Read The Red Cross' announcement regarding the new fine.

Congressman Calls for FDA Commissioner to Resign Feb 15, 2008 - Read this news account about FDA getting blamed by a Congressman for recent problems.

FDA Mixed-up Drug Plant Names in China Feb 19, 2008 - Read this news article about FDA's mix-up and Baxter's troubles with heparin, a blood thinner.

Baxter's explanation of the heparin incident Feb 19, 2008 - Read Baxter's explanation about the heparin incident.

Testimony of Sidney Wolfe, M.D. before Congress February 27, 2008 - Read Dr. Wolfe's testimony citing a crisis in leadership in the FDA.

Philips Lifeline, Inc. Warning Letter February 29, 2008 - Read this Warning Letter issued to a Medical Device manufacturer

The Heparin Fiasco April 10, 2008 - Read this New York Times story with details

Trying Times at the FDA: The Challenge of Ensuring Safety of Imported Pharmaceuticals April 24, 2008 - New England Journal of Medicine article

National Biological Corp. Warning Letter April 23, 2008 - Read this Warning Letter dealing with customer complaint handling and caPA (Corrective and Preventive Action)

Merck Warning Letter April 28, 2008 - Read this nine page Warning Letter issued to Merck and Company, Inc.

Scientific Laboratories Inc. Consent Decree May 16, 2008 - Read this Press Release from FDA announcing the Consent Decree signed by Scientific Laboratories Inc.

Warning Letters Drop in Number June 6, 2008 - Read this news report about the Enforcement Shift at FDA

FDA Staff in Crisis - June 8, 2008 - Read this news account of FDA staffers leaving the FDA, where the average age is 54

Keep your GMP Training ALIVE!  Table Topper example - June 15, 2008 - Here's an example of a Table Topper you can use in Keeping Your GMP Training Alive

Written Procedures and the Incoming Workforce - A list of interesting facts regarding those entering the workforce in 2008. An example: They grew up with digital clocks. Half past three or quarter to four may have no meaning to them.

 


cGMP for Dietary Supplements

cGMP for Dietary Supplements Final Rule June 22, 2007 - FDA's Preamble and Final Rule to the Current Good Manufacturing Practice in Manufacturing, Packaging, Labeling, or Holding Operations for Dietary Supplements

cGMP for Dietary Supplements 21CFR Part 111 - Current Good Manufacturing Practice in Manufacturing, Packaging, Labeling, or Holding Operations for Dietary Supplements

FDA Press Release announcing cGMP for Dietary Supplements June 22, 2007 - FDA's Press Release

FDA's Background info on cGMP for Dietary Supplements June 22, 2007 - FDA's Backgrounder document

FDA Consumer article on new Safe Use of Dietary Supplements June 22, 2007 - FDA Consumer Health Information article

Definition of Adulteration - Section 402 of the Federal Food, Drug, and Cosmetics Act

NEW!
GMP Training Systems Inc. announces:
Public workshop set for Nov 12 - 13, 2008 - Click here for info
 


cGMP for PET Drugs

On September 19, 2005, FDA proposed cGMPs for Positron Emission Tomography (PET) Drug Products. 

FDA's Press Release - Read FDA's announcement here.

cGMP for PET Drug Products Guidance Document - Read the Guidance Document here.

FDA's Questions and Answers - Read FDA's Questions and Answers regarding the proposed cGMPs.


INDs - CGMPs During Phase I Clinical Trials

In January 2006, FDA proposed a controversial change to CGMP
 compliance during Phase I clinical trials.  FDA withdrew the rule on May 1.

INDs - Approaches to Complying with CGMP During Phase I Guidance Document - Read the Guidance Document here.

Proposed Rule - Read the announcement published in the Federal Register.

Direct Final Rule - Read the announcement published in the Federal Register.

Rule Withdrawal - Read FDA's announcement of May 1, 2006 withdrawing this controversial change.


Medical Gases

FDA Press Release April 10, 2006 - Read this Press Release detailing FDA's new proposed rule for Medical Gases

FDA's Questions and Answers - Read FDA's Questions and Answers regarding the new proposed rule

Medical Gas cGMP - 21 CFR Parts 201 and 211, Medical Gas Containers and Closures; Current Good Manufacturing Requirements (draft guidance)


Medical Devices

FDA Press Release May 22, 2006 - Initiative to Facilitate the Development and Availability of Medical Devices

Medical Device Initiative May 2006 - Medical Device Innovation Initiative

Draft Guidance May 2006 - Guidance for the Use of Bayesian Statistics in Medical Device Clinical Trials: Draft Guidance for Industry and FDA Staff

Inspection of Medical Device Manufacturers June 2006 - Guidance document issued by FDA on June 15, 2006