Regulatory Open Forum

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  • 1.  Is "Read and Understand" an adequate training plan?

    Posted 27-Sep-2019 10:27
    After the FDA webpage redesign, Warning letters older than 2018 have been removed from the site (!). I am looking for any FDA WLs or statements about the adequacy of "training plans" that require staff to "read and understand" without any tests for competency. Is anyone familiar with Best Practices, GDPs, or other issues related to the adequacy of training plans and SOP updates that merely request or "require" "read and understand"?  Thank you.

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    Andrea Chamblee Esq., RAC, FRAPS

    This information and views expressed are provided in my capacity as an FDA and compliance professor at Johns Hopkins and George Washington universities, and do not necessarily represent the official views of the agency or the United States. Consult the Agency for an official position.

    Silver Spring MD
    United States
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  • 2.  RE: Is "Read and Understand" an adequate training plan?

    Posted 27-Sep-2019 10:52
    Side note:  The WL database still has WL back to 2014.  See https://www.fda.gov/inspections-compliance-enforcement-and-criminal-investigations/compliance-actions-and-activities/warning-letters

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    Kevin Randall, ASQ CQA, RAC (U.S., Canada, Europe)
    Principal Consultant
    ComplianceAcuity, Inc.
    Golden CO
    United States
    www.complianceacuity.com
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  • 3.  RE: Is "Read and Understand" an adequate training plan?

    Posted 27-Sep-2019 11:02
    Since the web teesign, I don't think they go back that far now. Older letters were in the archive link, which is no longer available. Regardless when I search for "procedure," I get zero hits. That's impossible. The redesign destroyed the public accessibility to warning letters.

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    Andrea Chamblee Esq., RAC, FRAPS

    This information and views expressed are provided in my capacity as an FDA and compliance professor at Johns Hopkins and George Washington universities, and do not necessarily represent the official views of the agency or the United States. Consult the Agency for an official position.

    Silver Spring MD
    United States
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  • 4.  RE: Is "Read and Understand" an adequate training plan?

    Posted 27-Sep-2019 12:48
    The drop-down menu at https://www.fda.gov/inspections-compliance-enforcement-and-criminal-investigations/compliance-actions-and-activities/warning-letters allows you to select WL back to 2014 and then the search locates those WLs and lists them at the bottom of the page.

    But indeed (and quite sadly) the new database search engine no longer appears to detect words from within the WLs themselves.  The old database allowed such searches and therefore was (in my opinion) superior to the new and improved database.  I recently queried FDA about this and unfortunately they weren't sympathetic to the issue.

    Luckily, private databases like Dan's or mine can help fill the void.


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    Kevin Randall, ASQ CQA, RAC (U.S., Canada, Europe)
    Principal Consultant
    ComplianceAcuity, Inc.
    Golden CO
    United States
    www.complianceacuity.com
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  • 5.  RE: Is "Read and Understand" an adequate training plan?

    Posted 27-Sep-2019 12:00

    I have excerpts from all device Warning Letters since 2008. I use them in my courses. I believe this would come under 820.25. I did a word search for words such as "read", "understand", "individual", and "method". I didn't find anything relevant. There were references to individual training records and to group training records, but nothing about the method of providing individual training.

    For training, I've used I often used ISO 10015:1999 Quality Management – Guidelines for Training. In section 4.3.3 it says, (after adjusting it a little) "Potential training methods to meet the training needs should be listed. The appropriate form of training will depend on the listed resources, constraints, and objectives. Training methods might include: courses and workshops on or off site; apprenticeships; on-the-job coaching and counselling; self-training; and distance learning".

    Section 4.5.1 includes, "The purpose of the evaluation is to confirm that both organizational and training objectives have been met, i.e., training has been effective. … The results of training often cannot be fully analyzed and validated until the trainee can be observed and tested on the job".

    Also, the standard is under revision and, as of 9/9/2019, is at stage 50.60 "Proof sent to Secretariat or FDIS ballot initiated".

    It falls under Technical Committee: ISO/TC 176/SC 3 Supporting technologies. Perhaps there is a committee member who could provide more information.

    My conclusion is that "Read and Understand" is a valid self-training method. The effectiveness check would include observation on the job.

     



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    Dan O'Leary CQA, CQE
    Swanzey NH
    United States
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  • 6.  RE: Is "Read and Understand" an adequate training plan?

    Posted 28-Sep-2019 20:46
    There are some divergent views on this depending on what part of the regulations you are looking at. 

    For Medical Device: The requirement is NOT for training, but competence. See ISO 13485:2016, section 6.2. Training is recognized as one way to obtain competence (along with education, skills & experience). Note, you must also have effectiveness of actions (training being an action) that is proportionate to the risk. This is where I have advised that instead of "read and understand" or "read and acknowledge" you might be able to change the thinking by calling this "self-certification of competence". For low risk procedures or changes, you can have people self-certify competence. For higher risk changes or procedures you could have an instructor certify or have them perform the activity (certify competence by others). I would also have a manager or supervisor periodically have a discussion with them and certify they have maintained their competence (because a competence of a manager or supervisor is to judge the competence of people they manage or supervise). As to 820.25(b), I would point you toward the preamble comments 48 & 59 that use the same phrases in combination with training that ISO 13485 uses.

    For Pharm or Lab/Biologics, the regulations require training (and periodic refresher training) and it is not clear they have shifted toward a competence model.

    Hope this helps!

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    Regards,
    Mark Swanson, ASQ CBA, CMQ/OE, CQE ASQ, MBA
    Becker MN
    United States
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  • 7.  RE: Is "Read and Understand" an adequate training plan?

    Posted 29-Sep-2019 14:00
    Edited by Kevin Randall 29-Sep-2019 14:04

    Remember that, with respect to FDA medical device regulation, 21 CFR 820.25(b), entitled 'Training', requires that we establish procedures for identifying training needs to ensure personnel are adequately trained.  Remember also that a fundamental premise of FDA's Quality System Regulation (QS Reg) is its flexibility.  Indeed, when promulgating the QS Reg, FDA in the preamble stated that, "…the new regulation is less prescriptive and gives the manufacturer the flexibility to determine the controls that are necessary commensurate with risk.  The burden is on the manufacturer, however, to describe the types and degree of controls and how those controls were decided upon. Such determinations are made in accordance with standard operating procedures (SOP's) established by the manufacturer..."

     

    Accordingly, there is no direct statutory or regulatory premise prohibiting a firm from utilizing "read and understand" / "self-certify" training methods.  For example, we see evidence of this in FDA's old Small Entity Compliance Guide, which permitted employee training to be achieved by many methods, including reading GMP/QA manuals.

     

    But make no mistake, FDA investigators will most certainly scrutinize a firm's training processes and the adequacy of personnel training (as measured by things like completion of planned/promised training and by observing evidence of competence).  There has repeatedly been Warning Letter citations for failure to complete training and for FDA-perceived incompetence.  Indeed, FDA's QSIT guide notes how FDA investigators may consider various facts and then form ideas about whether the training being provided is "sufficient".  And in the QS Reg preamble, FDA states, "…During inspections, FDA will assess whether a manufacturer has established procedures and followed requirements that are appropriate to a given device under the current state-of-the-art manufacturing for that specific device…"

     

    A 2008 Warning Letter citation noted in a 2009 issue of "The Silver Sheet" recites how a firm was in fact cited for utilizing "read and understand" training instead of relying on demonstrated competency.  The citation stated, "…Your firm's retraining (re-qualification) of employees includes only a review of the written procedure and does not require actual demonstration of adequate manual bonding by the employees…"  So there is definitely Warning Letter precedent for FDA objections to "read and understand" training.  But as mentioned above, there is no direct statutory/regulatory premise for that.  Instead, FDA likely weighed the associated risk of the particular scenario and then concluded that "read and understand" training was insufficient to assure public health in that case.

     

    To help avoid similar FDA citations involving FDA's specific 820.25(b) "training" regulations, firms should establish (define, document, and implement) procedures for development of risk-based training plans structured by job title and/or where appropriate, by job task.  In each plan, prescribe and justify the type and degree of training and competence evaluation needed (be it "read and understand", on-the-job, external course, written exams, and so on and so forth.).  If the firm has a reasonable risk-based rationale for its training methods and can thus reasonably assert that such methods will guard the public health, then corresponding FDA 483s and/or Warning Letters are unlikely.



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    Kevin Randall, ASQ CQA, RAC (U.S., Canada, Europe)
    Principal Consultant
    ComplianceAcuity, Inc.
    Golden CO
    United States
    www.complianceacuity.com
    © Copyright 2019 by ComplianceAcuity, Inc. All rights reserved.
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  • 8.  RE: Is "Read and Understand" an adequate training plan?

    Posted 29-Sep-2019 16:19
    Hi Andrea,

    I re-read your initial question. The first item you outlined was that "read and understand" was being used without a 'test for competency'. All actions (training being one possible action) requires a determination of effectiveness. If the action to 'read and understand' is intended to result in competence, then there must be a measure of its effectiveness to attain the competence that is proportionate to the risk associated (what is the harm/likelihood of occurrence of that harm) with the training method being ineffective? Perhaps just completing the read an understand is a sufficient verification of effectiveness or maybe something more needs to be done (depends on the risk). Hope this helps.

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    Regards,
    Mark Swanson, ASQ CBA, CMQ/OE, CQE ASQ, MBA
    Becker MN
    United States
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