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Ask Me Anything Session: The Strategic Role of the Regulatory Professional

  • 1.  Ask Me Anything Session: The Strategic Role of the Regulatory Professional

    Posted 08-Apr-2020 13:27
    Hi Members,

    Recently, RAPS released it's quarterly article series focusing on the strategic role of the regulatory profession. Today, we have two experts, Amaris Ajamil and Adriana Becker, who will be discussing the article series and available to answer your questions in real time.

    Please use this thread to ask the experts your questions.

    Can't wait to read the discussions!

    Best,
    Annie

    ------------------------------
    Annie O'Brien
    Community Manager
    Regulatory Affairs Professional Society
    regex@raps.org
    ------------------------------


  • 2.  RE: Ask Me Anything Session: The Strategic Role of the Regulatory Professional

    Posted 08-Apr-2020 13:29
    Thanks, Annie! Amaris Ajamil here. I'm looking forward discussing more on this topic with all of you!

    ------------------------------
    Amaris Ajamil
    Senior Quality Assurance / Regulatory Affairs Engineer
    Lebanon NH
    United States
    ------------------------------



  • 3.  RE: Ask Me Anything Session: The Strategic Role of the Regulatory Professional

    Posted 08-Apr-2020 13:29
    Hello RAPS and Annie, thank you for having me. I'm looking forward to answering the questions from the community.

    ------------------------------
    Adriana Becker
    Los Angeles CA
    United States
    ------------------------------



  • 4.  RE: Ask Me Anything Session: The Strategic Role of the Regulatory Professional

    Posted 08-Apr-2020 13:31
    What substantive trends and issues do we need to prepare for to keep ourselves marketable as a Regulatory professional?

    ------------------------------
    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
    ------------------------------



  • 5.  RE: Ask Me Anything Session: The Strategic Role of the Regulatory Professional

    Posted 08-Apr-2020 13:35
    Great question, @Andrea Chamblee. Coming from the medical device industry, cybersecurity and data protection have shown to be more and more critical as our devices become more and more interconnected. Often times, cybersecurity measures are implemented as an after-thought into a design, leaving products and infrastructures at risk for attack. Similarly, the emergence of more Digital Therapeutics will continue to push the boundaries of how Software as a Medical Device is regulated.

    ------------------------------
    Amaris Ajamil
    Senior Quality Assurance / Regulatory Affairs Engineer
    Lebanon NH
    United States
    ------------------------------



  • 6.  RE: Ask Me Anything Session: The Strategic Role of the Regulatory Professional

    Posted 08-Apr-2020 13:37
    Edited by Adriana Gavrilciuc 08-Apr-2020 14:07
    Hello - thank you for your question. The top ones I can think of right now from a medical devices perspective:
    1. The list of harmonised standards for MDD, AIMDD and IVDD has been updated. One highlighted change that is very important is that EN ISO 10993-11:2018 ( systemic toxicity) replaces EN ISO 10993-11:2009. Although these are not harmonised to the MDR, keeping track of newly harmonized standards for all directives is very important for regulatory professionals.
    2. Updated MDCG guidances, especially as we work towards MDR.
    3. Understanding PMCF requirements under MDR, as this has changed substantially.
    4. How to define ''sufficient clinical evidence'' as a manufacturer of a medical device.

    ------------------------------
    Adriana Becker
    Los Angeles CA
    United States
    ------------------------------



  • 7.  RE: Ask Me Anything Session: The Strategic Role of the Regulatory Professional

    Posted 08-Apr-2020 13:40
    In light of COVID-19, many applicants had to pause ongoing clinical trials, and likely expect protocol compliance issues (incl. data missingness) given limitations pertaining to travel to and treatment at participating trial sites. Several regulatory experts explore real-world evidence as a potential stop-gap solution to bridge the issue of data missingness, which would require protocol amendments and regulatory approval thereof (assuming technical feasibility). What is your perspective on this matter, and the strategic role of a regulatory professional in navigating these options?

    ------------------------------
    Ilker Oztop
    Real World Data Analytics Manager
    Brooklyn NY
    United States
    ------------------------------



  • 8.  RE: Ask Me Anything Session: The Strategic Role of the Regulatory Professional

    Posted 08-Apr-2020 13:51
    Thanks for your question, @Ilker Oztop. I agree that, in these trying times, regulatory professionals across the globe need to adapt in order to move projects ​forward. If Real World Evidence and the method for determining the validity of that evidence for your particular situation is established, then use of RWE may be used. Of course, it is the responsibility of the Regulatory Professional to verify the proposed technique with the Regulatory Authority's latest thinking on this topic.

    ------------------------------
    Amaris Ajamil
    Senior Quality Assurance / Regulatory Affairs Engineer
    Lebanon NH
    United States
    ------------------------------



  • 9.  RE: Ask Me Anything Session: The Strategic Role of the Regulatory Professional

    Posted 08-Apr-2020 14:05
    Thanks for your question! In these unprecedented times, the role of a regulatory professional in quickly interfacing with the respective authorities directly becomes crucial. Establishing direct (and highly responsive) lines of communication with authorities and proposing RWE as a bridge, while in the meantime preparing for all the additional regulatory work that implies (such as protocol amendments), should be done by the Reg professional in a timely manner. Authorities are swamped and the focus is off of clinical trials currently (unless specifically related to COVID19), so the Reg professional should attempt to make their job as easy as possible by providing these interim solutions up front in a proactive manner, and be ready to back up any ''moving forward'' decisions with sound regulatory justifications and the required paperwork.

    ------------------------------
    Adriana Becker
    Los Angeles CA
    United States
    ------------------------------



  • 10.  RE: Ask Me Anything Session: The Strategic Role of the Regulatory Professional

    Posted 08-Apr-2020 13:40
    I really enjoyed reading your article, Adriana, on the "Changing Role of the Regulatory Professional" and wholeheartedly agree that the various "soft" skills required for a regulatory professional can make or break success in this career. In my experience, one skill that has surprised me for its importance is teaching. I find myself often in a "teaching" role when it comes to regulations - whether it be with engineers, marketing, or upper management. Are there any other roles you've had to assume that have surprised you?

    ------------------------------
    Amaris Ajamil
    Senior Quality Assurance / Regulatory Affairs Engineer
    Lebanon NH
    United States
    ------------------------------



  • 11.  RE: Ask Me Anything Session: The Strategic Role of the Regulatory Professional

    Posted 08-Apr-2020 13:45
    Hi Amaris, thank you for your question! I think having to surprise the role of ''go-between'' has surprised me the most as a regulatory professional. Because we interface with so many different departments, often times we are looked upon as SMEs for topics that are outside regulatory scope, and handling those questions with grace and effectiveness while also not making any erroneous judgements outside of our scope can be a challenge.

    I do find that unwittingly we end up being able to integrate a lot of information from various SMEs after enough years of experience in the industry, which does become increasingly beneficial to us within our own scopes.

    ------------------------------
    Adriana Becker
    Los Angeles CA
    United States
    ------------------------------



  • 12.  RE: Ask Me Anything Session: The Strategic Role of the Regulatory Professional

    Posted 08-Apr-2020 13:50
    Hi Amaris,
    What is the role of Regulatory personal when drug development does not go in the right direction? How to motivate the cross-functional team and change the direction?
    Thanks,
    KJ

    ------------------------------
    [Kailash] [Jain]
    [Regulatory Project Manager]
    [Takeda]
    [Cambridge] [MA]
    United StatesKailashKailash
    ------------------------------



  • 13.  RE: Ask Me Anything Session: The Strategic Role of the Regulatory Professional

    Posted 08-Apr-2020 13:59
    Thanks for your question, @Kailash Jain. In those situations, I find it's best as the regulatory member of that development team to really emphasize the fact that you are member of that team and everyone is trying to achieve the same goals. Maybe development didn't go in the right direction but that doesn't mean everything stops. The regulatory team member can be creative and outline different potential pathways and engage the whole development team in coming up with solutions.

    ------------------------------
    Amaris Ajamil
    Senior Quality Assurance / Regulatory Affairs Engineer
    Lebanon NH
    United States
    ------------------------------



  • 14.  RE: Ask Me Anything Session: The Strategic Role of the Regulatory Professional

    Posted 08-Apr-2020 14:22
    Hello @Kailash Jain! Motivating a cross-functional team can always be challenging. Oftentimes tempers and emotions run high, so it is important to use emotional intelligence in order to maintain a calm demeanor and function as an adult. I find that asking a lot of questions regarding the frustrations of the other team members, while actively listening to their answers, really helps (active listening is a must!). Usually once things have calmed down after the disappointment, solutions for other possible directions can be provided and discussed. The most important thing a Reg professional can do (other than remain objective and ethical) is to really try to manage their own frustrations in order to present themselves as an open and collaborative team member, who desires the same goals. From that place, active engagement can be achieved. ​

    ------------------------------
    Adriana Becker
    Los Angeles CA
    United States
    ------------------------------



  • 15.  RE: Ask Me Anything Session: The Strategic Role of the Regulatory Professional

    Posted 08-Apr-2020 13:46
    Hey, I found the link!  I have another question. Data integrity, as well as all-around integrity, have increasingly been a problem. Corporate cultural problems are not limited to non-USA operations, as Theranos makes clear.  Entrepreneurs are hailed as heros of technology and business, and Reg professionals are riduculed as "the Department of Marketing Prevention." How do we get our value recognized (other than watching the compliance ball drop after the fact and saying "I told you so!")?  Is it even possible for a lone regulatory professional, or a lone reg department, to influence corporate culture? If so, how?

    ------------------------------
    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
    ------------------------------



  • 16.  RE: Ask Me Anything Session: The Strategic Role of the Regulatory Professional

    Posted 08-Apr-2020 13:57
    Edited by Adriana Gavrilciuc 08-Apr-2020 14:07
    Hello Andrea! I believe indeed with the exposure of non-ethical practices by businesses that the value of Regulatory becomes more recognized. After all, it is how the FDA was created, and more stringent regulations are developed reactively to public health scandals. However, it is possible for a regulatory professional or a regulatory department to influence corporate culture - I have seen it in practice. One of the most effective tactics is via corporate training and an ''open desk'' policy.

    Implementing high-level trainings within companies which are accessible and digestible for different departments to understand how/why regulatory oversight is important can really help to clear the impression of Regulatory being seen only as the policing department. A single regulatory professional can be proactive about pushing for this within their own department, and then wider within the company.

    Additionally, an ''open desk'' policy or ''office hours'' (similar to this AMA!), where it is publicized that employees are welcome to come in and ''ask anything'' or have a discussion about how the currently regulatory work is being done, or why the major stopgaps exist where they do, and so on, can really provide transparency and build trust within the company between the Reg department and everyone else.

    ------------------------------
    Adriana Becker
    Los Angeles CA
    United States
    ------------------------------



  • 17.  RE: Ask Me Anything Session: The Strategic Role of the Regulatory Professional

    Posted 08-Apr-2020 14:10
    Great question, @Andrea Chamblee. I absolutely agree with @Adriana Gavrilciuc when she says that trust is key. Companies need to cultivate a culture that encourages employees at all levels to voice their concern on a certain development or promotional ​​piece. Employees need to be able to trust that their voices will be heard and taken seriously. The regulatory professional is responsible for implementing such a process that continuously asks the employees to question the methods and risks and assumptions.

    ------------------------------
    Amaris Ajamil
    Senior Quality Assurance / Regulatory Affairs Engineer
    Lebanon NH
    United States
    ------------------------------



  • 18.  RE: Ask Me Anything Session: The Strategic Role of the Regulatory Professional

    This message was posted by a user wishing to remain anonymous
    Posted 08-Apr-2020 14:02
    This message was posted by a user wishing to remain anonymous

    @Amaris Ajamil In your opinion, when it comes to new product development, how soon should the regulatory professional (or regulations in general) become involved?


  • 19.  RE: Ask Me Anything Session: The Strategic Role of the Regulatory Professional

    Posted 08-Apr-2020 14:06
    Great question. In my experience, general awareness of the applicable regulations for the new product is needed as soon as you have a concept. The designers should be aware of the regulatory design requirements as they could influence the direction of an initial concept, but the designers shouldn't be burdened by meeting those requirements until after initial feasibility/proof-of-concept has passed.

    ------------------------------
    Amaris Ajamil
    Senior Quality Assurance / Regulatory Affairs Engineer
    Lebanon NH
    United States
    ------------------------------



  • 20.  RE: Ask Me Anything Session: The Strategic Role of the Regulatory Professional

    Posted 08-Apr-2020 14:08
    Hello Amaris! I wanted to know a bit more about your background in regulatory - do you work primarily with drugs or devices? How did you stumble onto your path in the profession?

    ------------------------------
    Adriana Becker
    Los Angeles CA
    United States
    ------------------------------



  • 21.  RE: Ask Me Anything Session: The Strategic Role of the Regulatory Professional

    Posted 08-Apr-2020 14:14
    Hi Adriana! I work in the medical device industry specializing in new product development and all the regulatory excitement that comes with it. I did indeed stumble into a career of regulatory affairs. I started out as a Research Engineer when one day my boss asked me to research what regulations and standards a product we were designing would need to comply with - and the rest is history!

    ------------------------------
    Amaris Ajamil
    Senior Quality Assurance / Regulatory Affairs Engineer
    Lebanon NH
    United States
    ------------------------------



  • 22.  RE: Ask Me Anything Session: The Strategic Role of the Regulatory Professional

    Posted 08-Apr-2020 14:20
    How can we be the best managers and mentors to the regulatory professionals, to our own staffs, and others who are newer than we are?

    ------------------------------
    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
    ------------------------------



  • 23.  RE: Ask Me Anything Session: The Strategic Role of the Regulatory Professional

    Posted 08-Apr-2020 14:24
    Thank you, Andrea, for your question. Preparing future regulatory professionals is no easy feat, especially in such a dynamic field such as ours. My advice to managers and mentors of newer regulatory professionals is to encourage them to develop a process that keeps them up-to-date with the latest regulations and trends of the industry. Awareness of what is developing in the field and how others are approaching complex situations can lead the new regulatory professionals to make strategic connections for their own applications.

    ------------------------------
    Amaris Ajamil
    Senior Quality Assurance / Regulatory Affairs Engineer
    Lebanon NH
    United States
    ------------------------------



  • 24.  RE: Ask Me Anything Session: The Strategic Role of the Regulatory Professional

    Posted 08-Apr-2020 14:27
    Hi Andrea! Being a manager and mentor wrapped up into one is no small feat. For the regulatory profession, I believe it is very important to encourage improving negotiation skills and cross-functional interpersonal relationships, at any level of the profession. Many regulatory professionals are very self-driven and can pick up the technical aspects of the job readily, even those who are newer to the profession but come from a scientific background. However, it can be difficult to manage the differing landscapes across various companies, and due to the many people we depend on and whose decisions depend on us, a manager's job as a mentor is very important in providing an example in how to build trust, open discussion and good interpersonal relationships within the company culture. This leads to faster processing of changes, faster signatures, and easier access to information required for regulatory submissions. Additionally, the better a reg professional gets at this, the more knowledge they absorb from clinical, engineering, marketing and other departments to use in future problem solving. It becomes a win-win.

    ------------------------------
    Adriana Becker
    Los Angeles CA
    United States
    ------------------------------



  • 25.  RE: Ask Me Anything Session: The Strategic Role of the Regulatory Professional

    Posted 08-Apr-2020 14:30
    Thanks for joining us for this wonderful session, and a big thank you to our experts @Amaris Ajamil and @Adriana Gavrilciuc.

    As a reminder, you can find the Regulatory Focus Article Series, The Strategic Role of the Regulatory Professional HERE.

    Feel free to keep the conversation going by adding your question to this thread.

    Thanks again!

    Annie ​​

    ------------------------------
    Annie O'Brien
    Community Manager
    Regulatory Affairs Professional Society
    regex@raps.org
    ------------------------------



  • 26.  RE: Ask Me Anything Session: The Strategic Role of the Regulatory Professional

    This message was posted by a user wishing to remain anonymous
    Posted 09-Apr-2020 11:44
    This message was posted by a user wishing to remain anonymous

    As a regulatory professional working in a device startup that is still in early product development, 90% of my time is dealing with quality questions and manufacturing operation questions like inventory control.  We don't have a dedicated manufacturing department. So by default, I am the go-to person for anything that is not engineering or business in the company. Engineering is handled by the engineers, and business is handled by the CEO and an assistant.  I have no experience in manufacturing. I always have trouble answering questions on manufacturing.  In the past companies, this was handled by a production manager or a process engineer.  I know the general outline of manufacturing (e.g. from receiving to shipping). I would think my role would be more regulatory focused and more strategic rather than focusing on QA 90% of my time,  but given what I've been doing, I am not sure what regulatory means.  Does anyone have suggestions on what I can do? Anyone have a better definition of a regulatory professional?


  • 27.  RE: Ask Me Anything Session: The Strategic Role of the Regulatory Professional

    Posted 09-Apr-2020 12:06
    Thank you for your question. This is a topic that I am very passionate about as I manage both the regulatory and quality aspects of our products. In this scenario of a early device development startup, the regulatory professional will also wear the quality assurance "hat" (assuming the startup is small and everyone wears multiple hats). But I think in this scenario, the regulatory professional that manages QA is a great asset, because as the regulatory expert, you know exactly what your Quality Management System needs to produce in order to have a successful submission. Your regulatory role comes into play when determining the required level of QMS controls and testing needs for that product's submission and then the actual submission itself. To me, in this scenario, regulatory = quality. My suggestion is Embrace it! The more control and awareness that you have over your QA processes in early product development, the better the submission will be. And that's what we all want right?

    ------------------------------
    Amaris Ajamil
    Senior Quality Assurance / Regulatory Affairs Engineer
    Lebanon NH
    United States
    ------------------------------



  • 28.  RE: Ask Me Anything Session: The Strategic Role of the Regulatory Professional

    Posted 09-Apr-2020 12:17
    Edited by Andrea Chamblee 09-Apr-2020 12:52
    Anonymous: The many hats we sometimes wear often don't fit as well as others, do they?

    I would familiarize myself with the FDA Quality Systems Inspection Guide, and QSIT Technique Manual. I see those are not specific to Inventory Control but the principles are very relevant to the design of the Inventory System.

    Take a look at some FDA WLs on Inventory Control to see what NOT to do, and what FDA looks for. Under the horrendous new FDA web reorganization, you can no longer sort these letters by particular QMP/QSR (or even find the older letters at all). But you can Google them by "inventory control" "warning letters" and site:fda.gov, e.g.:
    Cache commodities of 2018 and
    Syfrett Feed of 2014.

    The letters are also for sale in private industry. Here is one that put some letters on its blog:

    FDA Sent These 9 Warning Letters for Food Companies | October 2018 - Govzilla

    Good luck!


    ------------------------------
    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
    ------------------------------