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Transcript of Federal agency for medicines and health products DG Inspection: A general overview Josiane Van der...
Federal agency for medicines and health products
DG Inspection: A general overview
Josiane Van der Elst – 26 June 2012
Subjectfamhp/entity/Division-Unit-Cell
DatePage number
The Agency and DG Inspection
Mission defining the main task of DG Inspection
Vision: philosophy and destination of DG Inspection
Strategic pillarsBe professional, dare to have strong objectivesA policy of control in pace with environmentBe in dialogue with stakeholdersHave strong internal backboneCommunicate when and where necessaryBe known - Visibility
Menu
The Agency
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Organisation chart FAMHP
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Organisation chart FAMHP
Directorate General Inspection: Mission and Vision
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• Safeguarding, from development to use, the quality of
medicines and health products by organising inspections
and controls in the different fields of competency of the
FAMHP
• Delivering authorisations, declarations, certificates, licenses
corresponding to the different fields of competency of the
DG Inspection
• Fighting against crime related to medicines and health
products
Mission of DG Inspection
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Inspections Autorisations
Medicines• GxP
Health Products• Medical Devices: Distributors and Class 1 manufacturers • Blood, Cell and Tissue Establishments
Promotional activities / advantages
Industry division
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Inspections Autorisations
• Authorisations manufacturing and distribution
• Declarations export declaration subcontracting declarationclinical trials declaration
• Certificates GMP certificates, including Eudra GMP Certificates for exportation:
CPP
• Accreditation Qualified Persons IndustryQualified Persons
PharmacoVigilancePersons Responsible for
Information
• Agreements Blood, Cell and Tissue Establishments
Industry division
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Inspections Administration
Pharmacies open to the public Opening, transfer and closure of
pharmacies Land Register
Hospital Pharmacies
Veterinary depots Notifications
Special regulated substances Authorisations narcotics and psychotropics Licenses
(import/export) precursors hormones
Dispensing Division
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Fighting crime related to the manufacturing,
distribution, dispensing of medicines and health products
• Counterfeit products trying to penetrate the legal circuit
• Illegal circuit, illicit products, for instance fighting illegal websites
Special Investigation Unit
Médicaments par internet ?
Ne surfez pas
avec votre santé !
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Vision: What is Inspection?
Wikipedia
An inspection is, most generally, an organized examination or
formal evaluation exercise.
The results are usually compared to specified requirements and
standards for determining whether the item or activity is in line
with these targets.
Inspections are used for the purpose of determining if a body iscomplying with regulations.
The inspector examines the criteria and talks with involvedindividuals. The result is an evaluation report.
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Vision: What is Inspection?
Inspection IS NOT
• inquisition
• only information
• consultancy
Inspection IS
• Verifying compliance with the law and guidelines
• According to standard procedures
• Result - driven, “finalité”
• Enforcement in case of intentional offences, intentional breach
of law
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Vision: Inspection in a changing environment The world is changing
New technologies and products are emerging
Globalisation
Societal implication is increasing
Demand for transparency is increasing
Complexity is increasing
Reaction: reality is changing:ignore or adapt
Darwinistic vision:
Inspection has to adapt in order to keep in touch with changing
reality, in order to be fit to perform its mission
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Vision: Style of inspection
AS IS: Gothic style
Strong vertical elements
One - to - one communication
Within DG Inspection: boxed
Inspection uniquely by competent autority
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Vision: Style of inspection
TO BE: Inspection” Art Nouveau”
Century turn 1890 – 1910
Curvilinear: both rigid and flexible
Harmonisation with environment
Within DG Inspection: Search linkage, thematic inspectionsAdopt attitude for more risk - based inspection
Combination of uniquely authority - executed control and “delegated” type of control but which stays authority - driven
Directorate General Inspection : Strategic pillars
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Strategic pillar 1: Strong objectives
• Specific surveillance leading to security:
• an inspection has a clearly pre-defined goal
• alert systems in place
• Pro-active product surveillance
• Time-bound:
• respect legal delays where of application
• timely interventions
• reasonable reaction time to complaints
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Strategic pillar 1: Strong objectives
• Result-oriented finality:
• is the law respected ? if not: deliberately or non-deliberately
• rationalise
• administrative simplification
• Open:
• understandable, no hidden agenda, what you see is what you get
• Service-oriented ; fee for service is justifiable
• Measurable
• Transparancy
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Strategic pillar 1: Strong objectives
• Negociable:
• in terms of having an attitude to set out acceptable and realistic
criteria for the parties involved
• not in terms of being bribable
• Good:
• give enough inspiration for the parties involved
• keep the spirit of wanting to evolve together
• instal climat of mutual trust within the limits of each’s playing field
Strategic Choice in order to keep in rythm with increasing complexity
Rethink methodology of inspection
Introduction of autocontrol
Trust = delegate part of the inspection to an interface with a feedback
Invest capacity rationally more in high risk fields
If trust is shamed: trial, no pardon, zero tolerance
If trust is honoured: reward
Introduction and promotion of transversal inspections
Equipe -based
A more rational use of capacity
Strategic pillar 2: control policy:trust and trial, ratio and reward
Strategic pillar 3: Partnership
Be in dialogue with stakeholders
Protocols of cooperation
Concertation platforms on important files, on changing legislation
Informal platforms
Fora (regulatory, scientific, industrial,…)
Meetings with Inspection to resolve specific questions
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Strategic pillar 4: Have a strong internal backbone
Strong internal structure and organisation allowing to be
performant in doing inspections
Based on the life cycle of an inspection
Planning of inspections
Execution of inspections
Issuing of authorisations and certificates
Intelligence input from the above for the planning of new
inspections
Based on equitable repartition of tasks
Divisions of Industry and Dispensing “overloaded”
DG Inspection: current structure
Director General
Division IndustryPlanning of inspections
Execution of inspectionsIssuing of
authorisations
Division DispensingPlanning of inspections
Execution of inspectionsIssuing of
authorisations
Special Investigation Unit
Control policy
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DG Inspection: new structure
Director General
Division Industry
Execution of inspections
Division Dispensing
Execution of inspections
Special Investigation Unit
Division Autorisations
Issuing of autorisations
Staff Inspection management
Planning of inspections(Ex - Control policy)
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Strategic pillar 4: Have a strong internal backbone
Work in a context of TQM
Rationalise meetings
Promote telework
Free zone office (Pilot for Agency)
Learning spirit
Valorise expertise
Soft skills
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Strategic pillar 5: Communicate
In a direct univocal way
Business rules of communication
On items important to the stakeholders
Unavailability of medicines
Counterfeit and illicit medicines
Feedback from international fora
Complaints
Know our faces
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Strategic pillar 6: Be known-Visibility
Inspection is out there on the streets
Representation at national fora
BRAS, UPIP/VAPI, MDHC, ICCF, ICCV, …
Response to parlimentary question
Representation at international fora
JAP
PIC/s
EMA / HMA / EC
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In other words, DG Inspection
A new structure
A new style
Federal agency for medicines and health products - famhp
Place Victor Horta 40/40 1060 Bruxelles
tel. 0032 2 524 80 00fax 0032 2 524 80 01
www.afmps.be
Contact
Subjectfamhp/entity/Division-Unit-Cell
DatePage number
Your medicines and health products,our concern