Regulatory Open Forum

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  • 1.  Getting company colleagues to attend internal training

    Posted 03-Apr-2023 10:57

    In convincing top management to comply with the requirements under the Federal Food, Drug, and Cosmetic Act or those under the fraud and abuse statutes, the most persuasive argument is: 

    1. It’s the right thing to do.  
    2. It’s the law. 
    3. It will help us sell better products. 
    4. If we don’t comply, we can be subject to regulatory sanctions. 


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    Nancy Singer JD, FRAPS, RAC
    President, Compliance-Alliance
    Newport Coast CA
    United States
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  • 2.  RE: Getting company colleagues to attend internal training

    Posted 04-Apr-2023 05:06

    You are still going strong, Nancy! Congrats!
    I like your list, with 'it's the right thing to do' at the top. Couldn't agree more.

    Best wishes



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    Rod Ruston FRAPS
    Director
    Milton Keynes
    United Kingdom
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  • 3.  RE: Getting company colleagues to attend internal training

    Posted 04-Apr-2023 07:58

    Rod,
    Thanks for replying  I would really like your opinion. Out of the list  mentioned above, which is your number 1 choice. My number 1 choice as a lawyer would be it is the law.
    Thanks in advance for engaging on this topic.
    Nancy 



    ------------------------------
    Nancy Singer JD, FRAPS, RAC
    President, Compliance-Alliance
    Newport Coast CA
    United States
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  • 4.  RE: Getting company colleagues to attend internal training

    This message was posted by a user wishing to remain anonymous
    Posted 04-Apr-2023 15:29
    This message was posted by a user wishing to remain anonymous

    "Top management" isn't a unitary entity... If you're trying to persuade a human being, know what motivates that particular person.




  • 5.  RE: Getting company colleagues to attend internal training

    Posted 04-Apr-2023 16:04

    Hi Nancy

     

    My first thought was 'it is the right thing to do', and it still is my Number 1 choice. However, to grab the ear of 'top management' I would use 'because it is the law', but then move on to say, 'the right thing to do must be the motivation, since if we do not do it because it is the right thing to do, we shall never remember we have to do it'.

     

    Oops, a bit long winded! But I am writing to a lawyer...!

     

    Best

     

    Rod

     






  • 6.  RE: Getting company colleagues to attend internal training

    This message was posted by a user wishing to remain anonymous
    Posted 05-Apr-2023 13:35
    This message was posted by a user wishing to remain anonymous

    I've experienced numerous challenges with various Chief Medical Officers and their direct reports in Senior Leadership regarding regulatory training assignments mostly in GCP and GVP compliance areas.  Their argument is always about how their time is important, and they don't execute the daily tasks for clinical trials (although they are the final signatory approval of clinical trial protocols & amendments and Investigator's Brochure).

    I've finally had enough recently and I told them that it is important that they are trained and knowledgeable because if there is a 483, warning letter, or any regulatory citation, those will be addressed either to them or the CEO depending on the org chart review by the regulatory inspectors.  




  • 7.  RE: Getting company colleagues to attend internal training

    Posted 06-Apr-2023 06:24

    Nancy,

    I would add to you list: 

    5. If you do not know the laws regarding the industry you work in, you won't know you have broken the law until you are indicted.

    My personal favorite spin on #5:

    5.  If you do not know the laws regarding the industry you work in you could end up in an orange jumpsuit, slow dancing with some big guy named Bubba.

    That usually gets their attention.



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    Arvilla Trag RAC
    Principal Consultant
    CMC Compliance Services
    Iron River MI
    United States
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  • 8.  RE: Getting company colleagues to attend internal training

    Posted 06-Apr-2023 12:53

    Arvilla,
    Thanks for your creative suggestions. They are always very helpful!



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    Nancy Singer JD, FRAPS, RAC
    President, Compliance-Alliance
    Newport Coast CA
    United States
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