FDA Recalls - Before You Start, and After You Finish

Understanding FDA's Recall Authority and Policy

This course will teach how to establish a roadmap for conducting recalls. The knowledge you gain will sharpen your recall management decisions and strategy. You will learn how to use the FDA's health risk criteria so you can develop effective recall procedures. One critical aspect of recalls involves the identification of the root cause of the recall and how you could or should prevent that problem from happening again. Your corrective and preventive action program (CAPA) and quality assurance functions require a rigorous approach to prevent a chronic history of recalls. Reiterative recalls lead the FDA to the conclusion that, "You don't get it." FDA's recall authority and program launches you into a project of crisis management.

Your compliance competency becomes a regulatory issue for the FDA if your recall is deemed ineffective. The seminar will cover critical performance targets for conducting an effective recall. You will learn how missteps in the recall process become an expensive problem in terms of money and a sloppy corporate image.

You will take away practical knowledge on how to work with FDA staff during a recall, and how you can prepare for inspectional follow up or a regulatory action, and in some cases a legal action. You will learn that your approach to recalls plays a major role in mitigating direct and indirect damage to your firm's business. A firm with a history of chronic recalls needs to learn how to get out of that downward spiral. Likewise, for established and new firms you will learn how you can reduce the negative impact of a recall with the use of proper planning.

FDA Recall Training Agenda

FDA’s Regulatory Authority

• Recall Regulations
• Voluntary recall: 21 Code of Federal Regulations (C.F.R.) Part 7
• Mandatory recall actions
• 21 C.F.R. Part 810
• 21 C.F.R. Part 806

Recall Classification

• Violation of the law
• Risk to Health
• Precedents
• Exemptions
• Stock Recovery
• Product Withdrawal
• Product Improvement

Recalls and risk to health

• Risk to health categories
• Death
• Serious injury / serious illness
• Non-reversible / reversible
• May cause, if it were to recur
• Remote possibility
• Health Hazard Evaluation for Recall Classification
• FDA’s internal evaluation
• Vulnerable subpopulations
• Scoring
• Participants
• Industry HHE equivalent
• FDA’s recall database

FDA’s Recall Procedures

• Understanding FDA’s program and implementation
• FDA’s agency-wide recall procedures
• The FDA’s investigator’s job
• Preparing a recall strategy
• Preparing for FDA oversight
• Recall notification to FDA’s District Office
• Recall notification to the public
• Root cause identification
• Correction and Prevent Action (CAPA)

FDA inspectional follow up

Enforcement: FDA administrative and legal remedies

End

Learning Objectives:

• Understand FDA's recall authority and policy
• Learn how to manage recalls under FDA oversight
• Learn how to interact with FDA
• See how to develop health risk determinations
• Learn critical recall strategy components
• Manage possible FDA enforcement actions
• Many more....

Who will Benefit:

• Recall managers
• Quality assurance managers
• Regulatory affairs directors
• Risk and product liability managers
• Manufacturers’ sales and marketing managers
• Own label distributors

Companies and departments:

• Manufacturers
• Own Label Distributors
• Importers
• Healthcare institutions
• Nursing homes
• Medical practice groups

.This live training Seminar includes the following for each registered attendee:

• A copy of the presentation slides by download
• A certificate of participation for attendee training records
• Q/A Session
• Free Handouts on FDA Inspection

How to Attend:

All WCS Seminar live training programs audio and visuals are delivered via Go to Seminar with a basic system requirement of a computer with internet access. You do not require a Go to Seminar account to join WCS Seminar live training courses, participants receive an email invitation that provides the access you need to join the meeting.