Regulatory Open Forum

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  • 1.  Compliance to updated standards

    Posted 23-Apr-2018 22:39

    Hi,

     

    Is there a requirement to have a Letter to File on records for FDA , whenever there is an update to the standards.

     

    Thanks & Regards,

     

    Rashmi Pillay
    Regulatory Affairs Associate


    Ellex 

    3-4 Second Avenue

    Mawson Lakes SA, 5095

     

    T + 61 8 7074 8105
    rpillay@ellex.com

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  • 2.  RE: Compliance to updated standards

    Posted 24-Apr-2018 05:37
    Rashmi,

    When there is an new or updated standard, guidance document, or regulation, the expectation is that the organisation has reviewed the new or updated regulatory requirement against what currently exists in your quality system.  This is also a requirement in ISO 13485 that regulatory requirements are reviewed as part of management review.  FDA knows this as well.  So as an example, if a sterilisation standard like ISO 11135 was revised, and the company sold sterile product, the expectation would be to review the new requirements against what currently exists to either have a Letter to File that there is no impact or up to a re-validation or new validation.

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    Richard Vincins RAC
    Vice President Regulatory Affairs
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