The author presents an 8 item action plan and discussion for getting your FDA inspection off to a good start, beginning when FDA enters your facility. When an FDA inspector arrives at the reception desk of your facility, the last thing that you want is a Keystone Kops scenario with people running around in a panic and keeping the inspector waiting. This is your first opportunity to make a professional impression, and you never want to give an inspector the impression that you have something to hide. What happens during the first 30 minutes of arrival is critical. While medical device inspections are often announced several days in advance, there is no obligation for the Agency to do so. Therefore, your team needs training and a plan. This training should involve more than just reading the Quality System Inspection Technique (QSIT) manual (http://bit.ly/QSITManual), and conducting a mock FDA inspection. Last year, Rob Packard wrote a blog about “10 FDA Inspection Strategies that Don’t Work” (http://bit.ly/QSITmistakes), but the following activities need to be executed in the first 30 minutes to ensure your next inspection starts smoothly.
The FDA Inspection: 8 Immediate Actions to Take
1. Receptionist-Personnel Contacts (Time Zero)
I once witnessed a receptionist sarcastically comment to an inspector that people must be thrilled when they walk in the door. That was not a great start to the inspection. Ensure that your receptionist and additional personnel who may sit at the desk are trained, understand what to do and know how to behave when an FDA inspector(s) arrives. This exercise should not cause panic. You need a simple work instruction located at the reception desk and a list of key staff members to contact immediately. The head of the Quality department, or Management Representative, is usually the first call.
2. Have Chain of Command in Place (Time = 1 minute)
DO NOT keep the inspector waiting in the lobby. Have a communication chain in place to ensure that other appropriate personnel are available in the event that the first point of contact cannot be reached. It is reasonable to ask the inspector to return at a later date ONLY if all individuals with the technical expertise to participate in the inspection are not on site, or are out of the country. The agent will make the decision whether to honor this request, but the expectation is that there is always someone with whom they can work with. Never make this request to put off the inevitable.
3. Ask To See Inspector Credentials (Time = 2 minutes)
Ask to see the inspector’s credentials, and ensure that you give them more than a cursory glance. This is important to avoid allowing an imposter posing as an Agency employee from gaining access to your business. While a rare occurrence, it has been known to happen. Some investigators are officers of the Public Health Service and may be in uniform. However, even these officers are not required to wear a uniform to all visits. Note: Section 18.104.22.168 of the FDA Investigations Operations Manual (http://bit.ly/FDAIOM) instructs inspectors to provide their credential to top management, but copying of official credentials is not allowed.
4. Escort Inspector to Inspection Room (Time = 5 minutes)
Make sure that you can have the inspector escorted to a suitable room with the respective hosts within five minutes of arrival. This will involve ensuring that it is clearly understood by all administrative staff and key management that any other meeting may need to be curtailed, or moved immediately to another location in order to provide an appropriate space for the inspection. Providing substandard accommodations, such as a very cold or warm room is not a good strategy for shortening the inspection time, and is a ploy easily recognized by the Agency, though not appreciated. Note: Rob Packard taught an audio seminar earlier this year where the use of inspection war rooms was covered in more detail—including a diagram with a proposed layout for the room (http://bit.ly/FDAInspectionSeminar).
5. Ready the FDA Inspection War Room (Time = 10 minutes)
Immediately after your inspection room is identified, you need to prepare your back room or “war room.” This room should be located near the inspection room, and set up at a moment’s notice with staff who can expertly execute their respective roles. You will need a mode of communication between the inspection and war rooms, runners to retrieve documents and records in the shortest time possible, as well as a technical individual to review these documents to ensure that they are appropriate and accurate before being provided to the inspector. This room should be ready within ten minutes of arrival.
6. Ensure You Have Emergency Supplies & Copies (Time = 15 minutes)
Your war room will need supplies. You should have a mobile cart equipped with inspection supplies ready and waiting at all times. Suggestions for the contents of your war room cart include: laptop, projector, staplers, staples, pens, blank folders, a label maker,and a stamp for “uncontrolled copies.” Your supplies need to make it to the war room within 15 minutes of arrival.
7. Ready the Frequently Requested Documents (Time = 25 minutes)
Don’t wait for the inspector to tell you which documents are invariably requested at the outset of any inspection. This includes, but is not limited to, the organizational chart, an index of all procedures, CAPA log, and your nonconformance logs for medical devices—all dating back to the last inspection. This doesn’t mean that you should offer these documents to the inspector. You want to prepare these before they are requested, so that they can be provided quickly, but you should keep the copies in the war room until the inspector requests each document and record. Copies of these records and documents should be stamped and ready within 25 minutes of arrival.
8. Relax (Time = 30 minutes)
It sounds as though this process is a race against time. It is not. No one engaging with the inspector should be running in and out of the room gasping for breath, or perspiring profusely from the effort. Keeping the inspector waiting can be perceived as a stall tactic, perhaps arousing suspicion that you are creating records “on the fly” in the war room (definitely not a strategy that I recommend), or that you are having difficulty locating the requested documents, and are not in control of your Quality Management System (QMS). The most important aspect is to manage your QMS, so that you are always ready for an inspection at a moment’s notice. If you prepare in advance, you shouldn’t need to do anything more than ask if the inspector would like coffee before the inspection begins.