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More About This Title A History of a cGMP Medical Event Investigation
English
Case study details the right way and the wrong way to successfully develop and market a new drug
Beginning with the untimely death of a young mother, A History of a cGMP Medical Event Investigation unfolds a fictitious case study that captures how unchecked human flaws during the development and launch of a new drug can lead to disastrous consequences. Moreover, it illustrates how and why Six Sigma principles and methods should be applied to fully comply with FDA regulations at every stage of drug development and commercialization.
From initial transgenic mouse studies to the FDA fatality investigation, this case study introduces all the key regulations and practices that govern the development, manufacture, and marketing of a new drug, including:
- FDA Investigational and New Drug Application Processes
- FDA Code of Federal Regulations' current Good Manufacturing Practice (cGMP)
- ISPE Good Automated Manufacturing Practice (GAMP)
Readers will also be introduced to a variety of managers and researchers whose personal agendas conflict with best practices and therefore compromise the safety and effectiveness of a new drug product. Throughout the case study, the author offers tested and proven practices and tips so that these human flaws are not translated into drug product flaws. These practices and tips are critical and typically can only be learned through years of experience working in competitive drug development environments.
A History of a cGMP Medical Event Investigation is ideal for students in biotechnology, pharmacology, engineering, and business management as well as professionals in biomedical and drug development. All readers will discover what can go wrong in developing and bringing a new drug to market. Most importantly, they will also learn how to apply Six Sigma principles and methods to ensure safe and effective product design, development, and manufacturing.
English
MICHAEL A. BROWN, PhD, PE, is a Visiting Professor at the University of Illinois at Chicago. Dr. Brown has twenty-five years' experience in the biomedical industry in a product and process design capacity with responsibilities for worldwide engineering and management. He has served as a lead engineer on numerous products, process, and equipment projects including design, implementation, and qualifications. He is a registered Professional Engineer and a certified Six Sigma Black Belt with considerable experience in team leadership. The material presented in this case, including the FDA regulations and Six Sigma concepts, was tested in an engineering senior design course taught by Dr. Brown over a three-year period. Student feedback noted that the difficult design principles were explained in an easy-to-read story that introduced them to the Six Sigma methodologies in an engaging manner.
English
Preface xi
Part One The Event 1
1 Francesca 3
Part Two Drug Discovery: Five Years Earlier 9
2 Katlin Bioscience: Transgenic Mouse Study 11
3 Oxy-Fox Inhaler 21
3.1 Kinnen Laboratories 21
3.2 Kinnen Laboratories: Oxy-Fox Transfer 22
3.3 Due-Diligence Team and Katlin Data Acceptance 23
Part Three Kinnen Oxy-Fox Inhaler Market Launch Program 25
4 Agency IND and NDA Requirements, Six Sigma Charter, and Device Master Record 27
4.1 Launch Team Meeting Number 1 27
4.2 Meeting with Medical Affairs: Toxicity Studies 46
5 Meeting Minutes Guidelines 49
5.1 Launch Team Meeting Number 2 49
6 Project Timing, Marketing Plan, and Offshore Molding 55
6.1 Launch Team Meeting Number 3 55
6.2 Project Financial Review 61
6.3 Progress Meeting: Who Takes Credit for What? 64
6.4 Morning Meeting: Just-in-Time Manufacturing 65
7 cGMP Process Validation Requirements 69
7.1 Launch Team Meeting Number 4 69
8 Failure Mode Effects Analysis 81
8.1 Launch Team Meeting Number 5 81
9 Design for Manufacturability, Design for Six Sigma, Concurrent Design 93
9.1 Product Development Meeting Number 1 93
9.2 Update Meeting with Ed Chase and Gordon Taylor 102
10 Design Fishbone Diagram 105
10.1 Launch Team Meeting Number 6 105
11 Product Specifications 111
11.1 Product Development Meeting Number 2 111
12 Design Control 115
12.1 Design Team Meeting Number 7 115
12.2 Product Development Staff Meeting 118
12.3 Engineering One-on-One 119
12.4 Program Update 120
13 Design of Experiments (DOE) 123
13.1 Molding Team Meeting 123
14 Start-Up Issues 129
14.1 Oxy-Fox Inhaler Wrap-Up and Equipment Start-Up 129
14.2 The Final Management Review 135
Part Four Present Day: Funeral 139
15 Grief 141
16 The Autopsy Results 145
17 The Agency 151
Part Five Agency Medical Event Letter 155
18 Kinnen Notification 157
18.1 Another Agency Letter 157
18.2 Medical Event Review Meeting 158
19 Investigation Team Management 161
19.1. Morning Meeting with Gail Strom, Marcia Hines, and Dan Garvey 161
20 DMAIC Investigation Process 163
21 Internal Quality Review 171
21.1 Meeting with Gail Strom and Marcia Hines 171
21.2 Executive Management Review 174
22 The Agency Audit Letter 179
23 Agency Arrival 183
24 The Audit 187
24.1 Agency Meeting to Review Qualification Documents and the Quality Acceptance Records of First Lot to Stock 187
24.2 Agency Meeting to Review the Oxy-Fox Inhaler Lot Used in the NDA Clinical Studies 189
24.3 Agency Meeting to Review the Design and Program Team Meeting Minutes 190
24.4 Agency Meeting to Review the Due-Diligence Report Katlin Studies, and Oxy-Fox Design History File, 192
25 End-of-Day Agency Wrap-Up Meeting 197
26 Kinnen Management Review 201
Part Six Reckoning 207
27 Blame and Responsibility 209
27.1 The Investigation Is a Public Record 209
27.2 Kinnen Wrap-Up 210
28 Closure 213
Bibliography 215
Index 217
