I have read through the pain points discussed on June 11 and am in complete agreement with the ideas expressed by Beth, Liz, Hiral, Richard, Ginger, and anonymous. Permit me to share some of my own experiences.
I have been a regulatory and compliance consultant with additional full-time staff for almost 40 years. Occasionally we even did clinical studies and monitor and currently audit for GCP, GMP, and GLP. Actually we've done about 360. Prior to this time I taught as an assistant professor in a medical school followed by 10 years in industry ending as a group vice president at Warner-Lambert. Most of the time I interfaced with regulatory affairs reporting directly to me or as a separate function where we worked cooperatively.
From inside the company I very much appreciate the interplay of RA and marketing. Even as a consultant where we review all promotional material there really is an educational process to inform marketing people about such things as fair balance and what can and cannot be said or written in a branded piece. There can also be frictional areas between legal and regulatory. Regulatory and legal are both called upon to discuss issues dealing with the Code of Federal Regulations, guidance documents and the US code. In my experience of about 37 years in RAPS I really never saw a discussion about legal versus regulatory responsibilities. So let me hedge my bets and say that it may have been there, but I just didn't see it.
An issue which many experience in a company is when a consultant is brought in. I write now from the perspective of both working in a corporation and as a consultant who was brought in. When the company has an existing regulatory staff or individual and a consultant is hired there may be several reasons. First, the consultant may need to confirm the RA staff judgment, the company does not appreciate in-house staff or the consultant has a level of competency that existing staff may not have. It is imperative in our judgment and experience that an outside consultant meet as soon as possible with existing staff and that management encourages it.
I find it very surprising that multibillion-dollar companies who use our services have to go outside and not use their existing staff. Obviously if the company is small or does not have the capability then one needs temporary help such as a consultant.
There are certain commonalities between regulatory affairs in the corporation and those of us who are consultants. I can list a few:
- Constant changing of regulations.
- The need for consistency in FDA review
- Clarity between legal and regulatory functions
- Respect and support for regulatory affairs personnel in corporations
- Whether it is necessary to distinguish between regulatory and quality activities and if so make the differentiation clear.
- Because the regulations differ in many respects from country to country harmonization will probably be necessary.
- Conflict between marketing and RA.
These are just a few. Those working in a corporate environment hopefully it is comfortable and meaningful for you. Those of us in the consulting space we have the option of whether or not to take a client on or if there is a problem or concern during the project execution we will no longer work with this client in the future.
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Robert Schiff PhD, RAC, CQA, FRAPS
CEO
Schiff & Company, Inc.
583 Mountain Avenue
North Caldwell, NJ 07006
rschiff13@aol.com973-568-3361
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Original Message:
Sent: 09-Apr-2021 08:28
From: Beth Lentz
Subject: Pain Points of an RA professional?
Hello - I have been in and out of the medical device RA world for 25+ years. (Well, do you ever really 'leave' it? haha!)
I'm curious to learn what others in this group feel are their biggest pain points. Some of mine include:
1. Constant changes to global regulations
2. Too much admin work
3. Searching for market entry requirements
What are YOUR frustrations?
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Beth Lentz
Pittsburgh PA
United States
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