This document provides guidance on what to do while an FDA audit is occurring. It advises being prepared to address any issues or observations from the inspectors as they arise, and if possible, to remediate problems before the audit ends. It also recommends moving meetings, having someone handle daily tasks, keeping senior management informed, and discussing major issues with the inspectors. The document stresses being prepared to provide options for resolving issues, controlling all documentation in a "war room," and addressing inspector concerns and needs at the end of each day.
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steps involved
This series is designed in parts
Part 1 Preparing for the FDA
Part 2 What to do when the FDA arrives
Part 3 What to do while the FDA is there
Part 4 What to do during closeout
Part 5 What to do with the 483
This is Part 3
What to do while the FDA is there
3. Try to understand any issues (observations) as they
happen.
If possible, remediate prior to the end of the audit
but
Use caution when implementing quick changes without
the opportunity to fully evaluate
Be prepared to work late or over the weekend
Move your routine meetings around dont leave the
audit for something else
Have someone handle day-to-day activities for you while
you are at the audit
Keep management and corporate in the loop.
4. If the audit goes badly and you are seeing a major issue being
evaluated, dont just accept it:
Pass the information along to senior management
Discuss the issues with the inspector
Be concerned show that you are willing to resolve the issue
At some point, you may want to bring in some options for resolving
the issues:
Corporate help not directly with the audit but to fix the issues
Third Party
Be prepared the inspectors may dig deeper into the issue or expand
into other areas
5. If youve ever been in an audit especially a long or complex
audit you know that there will be a ton of documentation
pulled for review
Have your war room practices well defined.
Keep control of all your documents
People may start to get burned out tired after a few days of
intense audit. Watch for this issue dont let them snap or
loose control. Tired people make mistakes you cant afford
mistakes.
6. At the end of each day:
Review the concerns of the inspector
What will they need for the morning
Schedule still as previously discussed
Management should be aware of the situation
Inform folks in the facility as to what is happening
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