When QMS Validation Goes Wrong: FDA Consequences

Before U.S. manufacturers can begin selling their products, they must ensure, by law, that their wares meet an acceptable level of quality.  A key part of that process is the act of providing objective, documented evidence to the U.S. Food and Drug Administration (FDA) that their processes, equipment and computerized systems are checked and validated.

Failure to meet these requirements can result in consequences of varying degrees of severity, depending on the nature of the offense and an outfit’s history with the FDA. These include:

  • Recommendation – Important feedback provided to companies with a good FDA relationship. An issue is noted in an audit file with the expectation that it be addressed by the next audit.
  • 483 form – A formal notice sent to the head of a company’s Quality department, with a response due within 30 days. This a low-key public record similar to a misdemeanor.
  • Warning letter
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3 Ways MDSAP Improves Audit Effectiveness


What is the MDSAP program?
In Singapore in 2012, the International Medical Device Regulators Forum (IMDRF) began development of a Medical Device Single Audit Program (MDSAP). MDSAP allows approved auditing organizations to conduct a single regulatory audit of a medical device manufacturer. This single audit expands the scope of the audit to previously unaudited areas of large organizations, standardizes a consistent auditing model, and replaces as many as five separate . It also satisfies the regulatory requirements of the authorities participating in the program – even ISO 13485:2016. MDSAP focuses on defined and linked processes and is based on requirements for risk management. The goals of MDSAP are:

  1. to improve audit effectiveness and the influence the audit can have on outcomes that improve patient safety, and
  2. to reduce the resource demands on both regulatory bodies and auditees in organizations having to comply with a variety of global standards and .
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FDA’s New FSMA Rules Mean Hard Times for Old Compliance Tracking

Food and beverage companies would be well-served by moving away from paper-based compliance systems and replacing them with modern, automated solutions.

Regulations contained in the U.S. Food and Drug Administration’s Food and Safety Modernization Act (FSMA) have made the food industry safer, improved product quality, and reduced food recalls. They have helped businesses focus on quality and manage suppliers in a more efficient and proactive way. This has minimized their costs of incidents associated with noncompliance, such as reinspections, food recalls, and even brand and reputation damages.

For most companies, FSMA has meant:

  • An increase in the frequency of inspections. Implementation of a prevention-based food management solution and a food safety plan is now a requirement for compliance.
  • Supplier verification. Companies that import foods internationally must ensure their suppliers are verified and their food products are safe.
  • More intensive sampling and testing of food. This requirement has placed an enormous
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Mitigating Risk in Global Food Sourcing Begins with Integrated Supplier Management

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Increasing public concern for food quality and global sourcing of food products is moving the entire food and beverage industry towards creating better ways and means of ensuring the safety of what we eat.

It’s also driving the creation of an interconnected global system for the production and distribution of food. During the last decade, many public and private standards for food safety and quality have been developed around the world and today there are more worldwide standards than ever before. The trend is clear – food safety is top of mind concern on a global scale.

With the finalization of Food Safety Modernization Act (FSMA) and compliance Preventive Controls rules for large companies already announced, the increased need for integrated supply chain management has become paramount.

What are the most important trends impacting food and beverage companies today?

Source: LNS Research Food and Beverage industry survey data

Still, it’s … Read more...

FDA Finalizes FSMA and New Bill Introduced for Immigrant Worker Safety

On this week’s edition of EHS This Week we’ve got the week’s top stories in environment, health and safety news:

  • FDA Finalizes Food Safety Modernization Act (FSMA)
  • U.S Government Introduces Bill on Immigrant Worker Safety

Remember to write us with your suggestions, questions and comments. Also, if you are an industry expert and ever want to take part in the program, we’d love to have you. Until next week, enjoy the program!

EHS This Week Resources

For more information on the stories and resources mentioned in this week’s podcast, check out the links below.

  • FDA Food Safety Modernization Act (FSMA). Click here
  • U.S Government Introduce Bill on Immigrant Worker Safety. Click here
[audio: 2015/11/EHSTW-112015.mp3]… Read more...

FDA Looks to Eliminate Trans-Fat and Charges Laid in Lac-Megantic Derailment

On this week’s edition of EHS This Week we’ve got the week’s top stories in environment, health and safety news:

  • Federal Government Lays New Charges in 2013 Lac-Mégantic Train Derailment
  • FDA Looking to Eliminate Trans-Fat from Processed Foods

Remember to write us with your suggestions, questions and comments. Also, if you are an industry expert and ever want to take part in the program, we’d love to have you. Until next week, enjoy the program!

EHS This Week Resources

For more information on the stories and resources mentioned in this week’s podcast, check out the links below.

  • Charges Laid Against Railway in Lac-Megantic Crash. Click here
  • FDA Cuts Trans Fat in Processed Foods. Click here.
[audio: 2015/06/EHSTW-062615.mp3]… Read more...

Minority Health Month, ICAO’s Safety Ratings, FDA Food Facility Regulations and More!

On this week’s edition of EHS This Week we’ve got the week’s top stories in environment, health and safety news:

  • April Minority Health Month
  • North Dakota Approves Project to Recycle Oil Drill Waste
  • International Civil Aviation Association’s Safety Ratings Impact Aviation Industries
  • FDA Regulations on Registration of Food Facilities

Remember to write us with your suggestions, questions and comments. Also, if you are an industry expert and ever want to take part in the program, we’d love to have you. Until next week, enjoy the program!

EHS This Week Resources

For more information on the stories and resources mentioned in this week’s podcast, check out the links below.

  • National Minority Health Month. Click here
  • North Dakota’s Oil Drill Waste Project . Click here.
  • FDA Wants to Amend Regulations on Registration of Food Facilities. Click here
[audio: 2015/04/EHSTW-041715.mp3]… Read more...

FDA Releases Mobile App, Bangladesh Factory Collapse, NTSB Forum, and More!

On this week’s edition of EHS This Week we’ve got the week’s top stories in environment, health and safety news:

  • Bangladesh Factory Collapse
  • FDA Releases Mobile App to Identify Drug Shortage
  • OSHA Announces Final Rule on Retaliation Complaints
  • NTSB Forum Addresses Dangers of Railroad Trespassing

Remember to write us with your suggestions, questions and comments. Also, if you are an industry expert and ever want to take part in the program, we’d love to have you. Until next week, enjoy the program!

EHS This Week Resources

For more information on the stories and resources mentioned in this week’s podcast, check out the links below.

  • Bangladesh Factory Collapse. Click here
  • Mobile App Released to Identify Drug Shortages. Click here.
  • OSHA Whistleblower Protection Programs. Click here
  • NTSB Announces Forum to Address Railroad Trespassing Dangers. Click here
[audio: 2015/03/EHSTW-031315.mp3]… Read more...

OSHA Requests Public Input on Chemical Hazards, FSMA Proposals to Become More Flexible, Canada Invests in Food Traceability and more on EHS This Week!

On this week’s edition of EHS This Week we’ve got the week’s top stories in environment, health and safety news:

  • OSHA releases RFI, launches “national dialogue” on workplace chemical hazards
  • FDA looking to increase the flexibility of FSMA proposals
  • Canadian government invests in livestock traceability database
  • Unique mobile unit initiative promoting awareness of workplace safety

Remember to write us with your suggestions, questions and comments. Also, if you are an industry expert and ever want to take part in the program, w e’d love to have you.

Until next week, enjoy the program!

EHS This Week Resources

For more information on the stories and resources mentioned in this week’s podcast, check out the links below.

  • OSHA seeks public opinion on chemical hazards and permissible exposure limits. View instructions for submitting comments are here.
  • Canada’s proposed national livestock traceability database. Learn more about it here.
[audio: 2014/10/EHSTW101014.mp3]… Read more...

FDA Announces 2014 Food Safety Challenge, Severe Black Lung Cases on the Rise, Protecting Healthcare Workers from Splashes, and more on EHS This Week!

On this week’s edition of EHS This Week we’ve got the week’s top stories in environment, health and safety news:

  • FDA challenges food safety professionals to innovate
  • NIOSH says severe black lung at highest level in decades
  • Study shows workers underestimate workplace disability stats
  • CEO Council on Health and Innovation promotes workplace wellness
  • Healthcare worker safety threatened by splashes

Remember to write us with your suggestions, questions and comments. Also, if you are an industry expert and ever want to take part in the program, we’d love to have you.

Until next week, enjoy the program!

EHS This Week Resources

For more information on the stories and resources mentioned in this week’s podcast, check out the links below.

  • FDA 2014 Food Safety Challenge. Learn more here.
  • Data Letter from NIOSH researchers to the American Journal of Respiratory and Critical Care Medicine. Find it here.
  • RBC Insurance Survey on
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