
Checklist that will helpful in before Inspection
11 Prioritize Areas of Scrutiny
With the list of potential questions and possible documentation to provide, it is time to prioritize likely inspection points.
Identify between 5-10 likely areas that will be reviewed. For instance, if the review indicates the agency is concerned about management involvement and support for the company’s quality system, then what is it about management involvement and support that is likely to draw inspector scrutiny?
For a more virtual pharmaceutical firm, one specific area might be the effectiveness of supplier oversight in the context of management involvement.
Document Corrective Actions Properly:
Ensure that, in the event there is a deviation, you are documenting all corrective actions correctly.
All corrective actions should identify the root cause of the deviation, actions taken to prevent recurrence and, if product safety is not affected, a written conclusion (supported by factual and scientific data) that the deviation “does not create an immediate food safety issue.”
12 Conduct Environmental Monitoring:
If your company processes ready-to-eat food products that are exposed to the environment prior to packaging,
FDA will require you to have an environmental monitoring program. Ensure that an appropriate program is developed and implemented before FDA arrives.
13 Develop a Companion Sample Policy:
When FDA collects food product or environmental samples, some companies elect to collect companion samples at the same time.
Although we typically counsel against this practice, if you choose to collect companion samples, make sure to have a policy in place governing exactly how those samples will be handled, tested and/or discarded following collection.
14 Develop a “Photographs” Policy:
In many cases, FDA Investigators will insist on taking photographs while inspecting the processing environment.
If you have a corporate policy which helps visitors from taking photographs, you may be able to use the policy to FDA from taking pictures.
If the FDA inspector insists on taking photographs or other video or audio recordings, take and retain duplicates at the same time.
15 Develop a “Do Not Sign” Policy:
At the conclusion of the inspection, the FDA investigators may ask you or your employees to author or sign a statement or affidavit describing the inspection, the observations and/ or the conclusions.
Sometimes, during an FDA inspection, the FDA Investigators will insist that a company representative sign a statement or affidavit.
You have no legal obligation to do so. Develop a policy that states you will neither sign nor acknowledge any written statements presented by FDA Investigators.
Do not sign, correct or acknowledge any documents, as you have no legal obligation to do so. If the inspector presents an affidavit for signature, politely decline to sign and tell the inspector that you must first consult with the FDA lawyer/ consultant
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