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The BCG Bulletin                            

The Official Newsletter of the Biologics Consulting Group, Inc.

 

Issue 28

January 5, 2007

 

Bulletin Highlights

BCG Welcomes Bruno Gagnon to our CA Office

BCG Welcomes Michael Trapani to our MA Office

BCG Welcomes Wilson Bryan to our MA Office

Spotlight on BCG Regulatory Compliance Consulting

FDA Warning Letters by John R. Godshalk, MSE, MBA

Jim Kenimer, Ph.D. is presenting "Biologics Approval Process" course in Singapore

Advisory Committee Preparation Services

Your chance to meet with BCG representatives

 
Featured Stories

BCG Welcomes:
Bruno Gagnon to our CA office
Michael Trapani to our MA office
Wilson Bryan to our VA office

BRUNO GAGNON, BPharm, MSc
Mr. Gagnon joined the Biologics Consulting Group, Inc., as a Senior Consultant in December 2006. Bruno is a respected opinion leader in the field of Clinical Operations and has previously held various clinical positions at Chiron, PAREXEL International and Hoechst Marion Roussel. He is often invited as a speaker or facilitator at professional meetings, his favorite topics being Outsourcing, Clinical Supplies Management, Study Start-up and Training. He has been an instructor for various Clinical Trials certificates at Laval University (Quebec), the University of San Diego, UCSD Extension, and is currently on the faculty for the Clinical Trial Design and Management program at San Francisco State University, College of Extended Learning.

See Announcement

See Curriculum Vitae


MICHAEL TRAPANI, MS, MBA
Mr. Trapani will join Biologics Consulting Group, Inc., as a Senior Consultant in January 2007. He has extensive experience in regulatory affairs, new product registration and approval, regulatory compliance and quality assurance. He has held management positions in a broad selection of the industry including large pharmaceutical companies, biopharmaceutical groups, clinical research organizations (CRO) and diversified medical products companies and most recently was Vice President, Worldwide Regulatory Affairs for Ethicon Inc. Mr. Trapani started his career as an Investigator with the U.S. Food & Drug Administration.

See Announcement

See Curriculum Vitae


WILSON W. BRYAN, M.D.
Dr. Bryan will join Biologics Consulting Group, Inc., as a Clinical Consultant in February 2007. As a medical officer and team leader at FDA's CBER and CDER, Dr. Bryan was responsible for the clinical review of Investigational New Drug (IND) applications for drugs and biologics, including monoclonal antibody, cell, and gene therapies, for a wide range of neurologic indications, including cerebrovascular disease, multiple sclerosis, Alzheimer's disease, Parkinson's disease, other movement disorders (e.g., cervical dystonia), headache, amyotrophic lateral sclerosis and other neuromuscular disorders, insomnia and other sleep disorders, and a variety of other neurologic indications. As team leader, Dr. Bryan also ensured the quality and consistency of clinical reviews, actively participated in sponsor meetings, and was intimately involved with regulatory decisions and policy affecting the development and approval of numerous investigational products, primarily for neurology indications.

See Announcement

See Curriculum Vitae

 

Spotlight on BCG Regulatory Compliance Consulting

Achieving and maintaining compliance with FDA regulations is a complex undertaking, requiring diligent oversight by dedicated quality systems professionals. As a product moves through the various stages of development and testing, the FDA expects that the Quality Assurance/ Quality Control capabilities within the sponsor organization are also developing and maturing, such that by the time of submission of the marketing application (NDA, BLA, or PMA), the overall Quality System is sufficiently robust to pass FDA pre-approval inspection.

The September 2006 FDA guidance document Guidance for Industry: Quality Systems Approach to Pharmaceutical CGMP Regulations provides a good overview of the current FDA expectations for implementing a modern quality system and risk management approach to meeting FDA cGMP regulations. BCG consultants are experts in the assessment and development of FDA compliant quality systems. Since our consultants are also biologic product experts, we are uniquely qualified to assist you in the design and implementation of a quality system tailored to your particular product and to the phase of your development.

Our compliance staff includes ex-FDA auditors/reviewers as well as ex-biopharmaceutical industry Quality Assurance and Quality Control experts. We also work closely with several experienced lawyers with FDA compliance expertise. Whatever your need, from assessment of your existing quality system to design and development of a new quality system to assistance with FDA compliance problems (FDA 483s, warning letters (see following article), consent decrees), BCG has the expertise to provide you with the level of effort required to address your unique needs.

BCG Compliance Staff:

Pete Probst (ex-FDA inspector ) - GMP audits
John Godshalk, MSE, MBA (ex-FDA inspector) - GMP audits
Reggie Neal (ex-FDA inspector) - GMP audits
Tom Gerteisen, Ph.D. (ex-VP, Quality Operations, Genzyme) - Quality System Assessment/Development
Michael Trapani (ex-VP, Regulatory Policy and Quality Assurance, Covance) Quality System Assessment/Development
Lori Baranauskas (ex-Sr. Dir, Quality Systems & Compliance, Antigenics) - Quality System Assessment/Development
Larry Winberry, Ph.D. (ex-Director, QA & QC - Hyland-Immuno) - Quality Systems Assessment/Development
Stan Woollen (BCG Affiliate) (ex- Associate Director for Nonclinical Laboratory Compliance, ORA, FDA)
- GCP, GLP audits
John Jessop, MPH, Ph.D. (ex-FDA Pharm/Tox reviewer) - GLP audits
David Pepperl, Ph.D. (ex-industry toxicologist) - GLP audits
Tanya Kersten, Ph.D. (ex-industry research scientist) - GLP audits
Ruth Wolff, Ph.D. (ex-FDA Branch Chief) - GLP audits

FDA Warning Letters
Article by John Godshalk


Have you ever wondered if companies that are under an FDA consent decree got warning letters from the FDA first? The answer is YES. FDA uses warning letters as one of the many methods to bring firms into compliance with regulations. FDA's pattern in the past shows that multiple warning letters are issued before a consent decree is sought. Thus the warning letter is just that - it means that the firm is at risk for further regulatory action by FDA.

What does FDA issue warning letters for? As 2006 comes to a close, FDA has issued about 230 warning letters between CBER, CDER, and CDRH. Most of the warning letters were issued due to deficiencies in a firm's cGMP or Quality Systems Regulation. A quick analysis of the total number of warning letters issued for the three centers that regulate human drugs, biologics, and devices (excluding foods and vet products) shows that about 100 warning letters were issued by mid Dec 2006 for cGMP and QSR non-compliance. The second major category was labeling/misbranding/false and/or misleading claims, at about 68 warning letters through mid DEC 2006. These warning letters are often written by FDA in an attempt to reel in overzealous promotion or marketing materials that may promote a drug/biologic/device with a claim that go beyond what FDA approved, or what is supported by a clinical trials. The balance of the warning letters written by FDA is smaller in number, from only one (1) for HCTCPs to 22 for clinical investigators.

Continue Reading.....

Jim Kenimer, Ph.D. to present "Biologics Approval Process" course in Singapore, Mar. 19-20, 2007

This 2 day masterclass sponsored by IBC Asia Pte Ltd. and conducted by Dr James G. Kenimer will offer participants a complete overview of the regulatory requirements and processes in the US for biologic products.

The demand for biologics including therapeutic proteins, monoclonal antibodies, vaccines and cell-based therapies is on the increase worldwide and the US remains the largest and one of the most lucrative markets for these therapeutic products.

Learn More...

Advisory Committee Preparation Services


BCG has supplemented its advisory committee preparation services by teaming with the regulatory communication group Pharmapprove to assist companies in the preparation of high impact FDA advisory committee presentations. If you have an advisory committee appearance in your future, and would like to maximize the impact of your presentation, please contact Jim Kenimer.

Upcoming BCG Presentations
& Conference Appearances

BCG consultants attend numerous conferences every year during which they are available to provide company information or consulting expertise. Below are some conferences that BCG consultants will be attending in the near future. Please feel free to contact the attending consultant either before, or during the conference for company information or to discuss a business opportunity.

Date
Sponsoring Organization
Conference and Presentation Title
BCG Attendee(s)/ Speaker (s)
Location
Jan. 9-10, 2007 Cambridge Healthtech Institute PepTalk: Optimizing Protein and Antibody Therapeutics David T. Lin, Ph.D.
(speaker)
San Diego, CA
Jan. 22-24, 2007 IIR

4th Annual Forced Degradation Studies

David T. Lin, Ph.D.
(speaker)

Las Vegas, NV
Jan. 22-24, 2007 Phacilitate Cell & Gene Therapy Forum 2007 Darin Weber, Ph.D. Baltimore, MD
Feb. 28 - Mar. 2 Cambridge Healthtech Institute

2nd Annual Commercial Implications of Stem Cell Research

Track 6 at Molecular Medicine Tri-Conference; Panel Expert on Regulatory Issues for Neural Regeneration

Darin Weber, Ph.D.
(speaker)
San Francisco, CA
Mar. 19 - 22, 2007 Terapinn

World Vaccine Congress 2007

Agenda

Peter Patriarca, M.D.
(chairman)
Julia Barrett, M.D., MPH
David Pepperl, Ph.D.
Nadine Ritter, Ph.D.
Keith Wells, Ph.D.
(speakers)
Washington, DC
Mar. 23-27, 2007 AABB

Spring Cell Therapy Conference

Moderating session on Novel Cell Therapies

Ellen M. Areman, MS, SBB
John R. Godshalk, MSE, MBA
(speakers)
San Diego, CA
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