DIGR-ACT® Critical Thinking Focuses on Addressing the Right Issue or Risk at the Right Level – Part 7

11/23/2021

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What does ‘T’ stand for?

Everyone talks about learning from when things go wrong. People say it's the best way to learn, but it's not always easy. The DIGR-ACT® solution gives you a way. By taking you through the issue to the root cause, actions and then making sure the actions work, you have learned from the issue. Maybe your learning can be transferred to others? Perhaps the same problem happens to other people too?

Live Webinar: Risk Assessment & CAPA without Tears: The DIGR-ACT® Critical Thinking Solution

11/16/2021

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Date: 27 January 2022

Time: 10:30 AM - 12:00 PM EST

Location: Interactive Webinar

Registration: HERE

Training on RCA does not usually happen, so many do not know how to carry out a proper RCA. Yet, it is an important step in understanding what happened so the issue(s) can be prevented from recurring. In this webinar, you will learn about a practical approach to RCA that shows results while encouraging critical thinking for GXP professionals.

These sessions introduce to the GXP audience to DIGR-ACT® as a solution to mature teams and processes in the era of big change. Attendance at this or another session (live or recorded) is required before attending the Train-the-Trainer workshop scheduled for February 15 & 22.

Concerning Violations: Sponsor-Investigator Warning Letters

11/09/2021

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There are two recent warning letters relating to sponsor-investigators. (warning letter 1 HERE and warning letter 2 HERE). A sponsor-investigator both initiates and conducts a clinical trial, which is also known as an investigator initiated clinical trial (IIT). In both examples, the investigator used protocols internal to the institution but did not submit an Investigational New Drug (IND) application to the FDA. The drugs chosen for the protocols were approved and being used for on label use in the protocols. However, the protocols restricted what drug was being used and so could not be considered standard of care.

IRB Review Still Needed for Deidentified Specimens

11/02/2021

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The US Food and Drug Administration (FDA) wrote a letter to industry, “Studies Using Leftover, Deidentified Human Specimens Require IRB Review.” It is a reminder to in vitro diagnostic medical device sponsors that Institutional Review Board (IRB) review is needed for clinical trials on leftover, de-identified human specimens. The 2006 FDA guidance “Guidance on Informed Consent for In Vitro Diagnostic Device Studies Using Leftover Human Specimens that are Not Individually Identifiable” clarifies that informed consent to use leftover human specimens that are not individually identifiable is not required, if it meets exemption criteria from the Investigational Device Exemptions (IDE) regulation (21 CFR 812.2(c)(3)).

Comment Now! RWE Using Electronic Health Record and Medical Claims Data Draft Guidance

10/26/2021

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The US Food and Drug Administration (FDA) released a draft guidance on “Real-World Data: Assessing Electronic Health Records and Medical Claims Data to Support Regulatory Decision Making for Drug and Biological Products.” This draft guidance is published in line with the 21st Century Cures Act (Cures Act). Part of the Cures Act is related to the use of real-world evidence (RWE) to help support the approval of a new indication for an approved drug or to support post approval study requirements.