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Pharmaceutical Industry:

Compliance Performance

  Client:

An international pharmaceutical company with a major presence in the U.S. and products that include pharmaceuticals (e.g. solid dose, liquid, sterile) and biopharmaceuticals (e.g. peptides, recombinant therapeutic proteins, monoclonal antibodies).

  Problem: Regulatory authorities (FDA) inspected a U.S. facility and made multiple observations about current practices as well as historical patterns. Significant actions (i.e. injunction) were threatened, and a limited period of time was granted for the company to demonstrate improvements in quality system requirements.

  Approach: An independent evaluation of the company’s compliance history was performed by Tunnell consultants. The results were quantified to identify the most critical and frequent citations. A communication plan was developed to share this information with senior management and departmental staff. Teams were created to address the most critical areas requiring remediation. Consulting support included subject matter experts, management consultants, project managers, and a technical/functional support staff. Teams of consultants and company employees were well integrated, focused, had planned daily interactions, and regularly scheduled updates were made to management.

  Results: A general FDA inspection took place less than 6 months after project initiation. The results of these efforts, as well as many of the project plans, and the rationale and approach we took, were highlighted to the FDA during inspection. The FDA immediately took the client out of an “export hold” status.
   
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