Serving the medical devices / pharmaceuticals /
dietary supplements (neutraceuticals) industries for over 37 years
... "Business Success From Regulatory Compliance(TM)"
and "Completed Staff Work
How would a typical compliance project start with J. E. Lincoln and Associates LLC?
Our typical approach:
1. Initial step is a "walk-thru" (can be over the phone or by e-mail, in many cases)
of your project / operations / systems / existing
documentation
-- about an hour or 1.5 hrs; N/C; a full blown 1-day on-site
audit costs additional,
including travel expenses, and is usually not recommended at this stage; or at all;
2. Based on the above, we develop a proposal, N/C, no obligation, including
outlining key milestones / tasks, and a total project cost, with incremental
billing periods / amounts; this includes an amount up front, prior to start;
3. If that's agreeable, the project starts. We then develop a very detailed
Gantt chart with all anticipated milestones / tasks, timelines, and team
members, broken into modules, each costed and billed separately;
4. Then we (with your team's inputs) tackle each module, modifing the initial
Gantt periodically as the project evolves;
5. Each module is completed by several give and take meetings between me
and those persons on your team that will have the responsibility of implementing
and maintaining that system / procedure; it includes a training element by me;
usually talking through the rationale and activity required; SOP(s) and forms
are generated, with the goal of mimicking your existing / de facto systems as
closely as possible, modified by U.S. FDA / QS Reg / cGMP requirements
(of 21 CFR 4 (combo), 210/211 (drugs), 600-680 (biologics), 820 (devices), 1271 (tissue)...);
6. The next module is completed, and so on.
7. Often, companies also require, in addition to the specific sections of
the QS Reg, may need a risk document on their device(s), Design History Files
(DHF)for them, including s/w validation docs, and validations of any electronic
systems, and of any production or test equipment. The risk document can provide
justification for the level of documentation necessary. Resources would also
be a consideration.
8. If a company decides to pursue this further, the next step would be the
execution of an NDA (mine or theirs) and scheduling / performing the "walk thru".
J. E. Lincoln and Associates
LLC
Medical Devices / Pharmaceuticals / Quality Systems / Regulatory Affairs Consultants
Phone 435-840-0252 / E-mail jel@jelincoln.com / www.jelincoln.com
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