Training Course
Syllabus:
Effective Quality Oversight of Pharmaceutical Contract Manufacturing Organizations (CMOs)
The globalization of the pharmaceutical supply chain has led increased us of Contract Manufacturing Organizations (CMOs). The use of CMOs provides many benefits; however, it can present unique compliance risks, particularly since the operations are not in your facility and therefore not under your direct control. The compliance risks are highlighted by FDA Warning Letter trends, the majority of which are related to serious compliance and data integrity issues at foreign CMO sites.
If you use CMOs, your company has the ultimate responsibility for product quality, safety, efficacy, and cGMP compliance. Furthermore, FDA has clearly stated that organizations using CMOs will be held accountable for CMO compliance to cGMPs, as well as adherence to regulatory commitments. Therefore, issues identified at your CMO may result in FDA 483s and/or Warning Letters issued to your company. Since FDA is holding firms using CMOs responsible, it is imperative that your organization have a robust CMO management system. At the end of the day, your organization’s ability to provide proper quality oversight of CMOs is the key to assuring product safety and your company’s compliance profile.
This seminar will help all personnel responsible for CMO oversight understand how to manage CMOs- from start to finish. In-depth focus will be placed on Selection and Qualification, Quality Agreements, Understanding of CMO Operations, and Review of Key CMO Records. Considerations for different types of manufacturing will be highlighted, and techniques for managing difficult CMO situations will be discussed. This is a practical how-to course, designed to provide participants with skills they can immediately apply to CMO oversight within their own organizations. Group exercises will allow participants to practice skill sets with feedback from the instructor. Learning Objectives: Upon completing this course, participants should be able to:
Understand the CMO business model Learn the regulatory requirements for CMO quality oversight Learn how to structure your organization for effective CMO oversight Learn key points for selecting and qualifying CMOs Learn how to prepare for and conduct CMO Qualification Audits Learn how to develop a Quality Agreement and how to execute it Learn how to fully understand CMO operations Learn key points for reviewing CMO records Learn how to resolve issues identified in CMO records Learn how to prepare for and conduct routine CMO audits Learn how to manage CMOs on an ongoing basis Course Outline: DAY ONE (8:30 AM – 4:30 PM) Registration Process: 8:30 AM – 9:00 AM Session Start Time: 9:00 AM The CMO Business Model Regulatory Requirements & FDA Expectations for CMO Oversight Structuring Your Organization for CMO Oversight Manufacturing Chemistry / Laboratory Quality Assurance Regulatory Affairs Project Management CMO Selection and Qualification Key Selection / Qualification Criteria API Manufacturers Drug Product Manufacturers Testing Laboratories Aseptic Manufacturers Evaluating CMOs vs. Selection / Qualification Criteria Group Exercise- Selection and Qualification CMO Qualification Audits CMO Questionnaires Risk Assessment for Use of Questionnaires Good vs. Bad Questionnaires Evaluation of Questionnaire Responses Audit Planning CMO Background/Research Auditor Selection Audit Agenda Audit Execution Introductory Meeting / Orientation Area Tours Document Review / Interviews Time Management Group Exercise- Qualification Audits The Quality Agreement Regulatory Guidance Documents Elements of the Quality Agreement General Elements Manufacturing / Testing Elements Quality Assurance Elements Negotiating the Quality Agreement Executing the Quality Agreement Group Exercise- Quality Agreement DAY TWO (9:00 AM – 1:00 PM) Getting to Know Your CMO Understanding CMO Operations Operational/Communication Style The Seven CMO Personality Types Review of Key CMO Records Batch Records Change Controls Group Exercise- Change Control Critique Deviation Investigations / CAPA Group Exercise- Deviation Investigation Critique OOS Investigations Group Exercise- OOS Investigation Critique Routine CMO Audits Audit Planning Audit Execution Group Discussion- Routine CMO Audits Ongoing CMO Oversight Depth and Breadth of Oversight Managing Routine / Critical Issues Building Relationships Project Management |