Tobacco

Corporate Compliance

Compliance Gurus can provide tobacco manufacturers with a comprehensive plan, to ensure adherence to the regulatory requirements of the Family Smoking Prevention and Tobacco Control Act (2009) and 21 CFR 1140. In addition, we can design and implement a corporate compliance program that conforms to the health information data reporting requirements of the FSPTCA.

Regulatory Submissions

Compliance Gurus can provide tobacco manufacturers with a regulatory strategy focused on introducing a new or modified tobacco product to market. We author premarket review applications, substantial equivalence and modified product submissions, after conducting an extensive review and compilation of submission based data. In addition, we can assist with company registration, product listing, post-market reporting, labeling, advertising and promotion.

cGMP (current Good Manufacturing Practices)

The Family Smoking Prevention and Tobacco Control Act mandates all tobacco manufacturers to comply with good manufacturing practices. Compliance Gurus can redesign your existing quality management system to conform to contemporary regulatory requirements. In addition, we are experienced with developing and implementing streamlined, cost-efficient quality plans for new businesses.

Computer System Validation

Compliance Gurus can assist your organization with your computer system validation needs.
We are experts at qualifying infrastructures and validating computerized systems, ranging from small desktop applications, through enterprise- wide applications deployed for global use. Furthermore, our staff has substantial experience validating a variety of GLP, GDP, GCP, and GMP systems and software applications.

Part 11

Tobacco organizations utilizing electronic systems to create, modify, maintain, archive, retrieve or transmit data records, mandated by the Federal Food, Drug and Cosmetic Act or FDA regulations, must comply with 21 CFR 11. Part 11 also applies to recordkeeping measures, which assign electronic signatures. Compliance Gurus can conduct a Part 11 assessment of your company’s electronic records and signatures, and revise or implement a compliant Part 11 protocol.

Auditing

The Compliance Gurus team are experts at auditing internal and external regulatory systems, processes and procedures. Whether you are preparing for an FDA Pre-Approval Inspection, have received an FDA 482: Inspection Notice, or need to perform an FDA mock audit, as part of your inspection readiness plan, we can assist you. We can provide a detailed, comprehensive gap analysis of your company and vendor regulatory requirements, to identify compliance related deficiencies. Upon discovery, regulatory gaps will be analyzed, from a risk management perspective, and can be addressed through the implementation of a corrective and preventive action plan.
Our auditing services span the entire tobacco product development and management lifecycle, from research and development, through post-marketing surveillance and promotion. In addition, we frequently audit 3rd party suppliers and vendors, such as contract research organizations, contract manufacturing organizations and contract packaging organizations.

Training

Compliance Gurus can provide employee training to small and large groups. All of our corporate trainers possess advanced degrees and have ample years of experience working in the FDA regulated industry. Tobacco organizations can customize their educational curriculum, by choosing from our comprehensive selection of FDA and tobacco related content.

Currently, our training topics include: FDA History, The Organization of the FDA, History of Tobacco Regulation, The Family Smoking Preventi on and Tobacco Control Act, 21 CFR 1140: Cigarettes and Smokeless Tobacco, Good Manufacturing Practices for the Tobacco Industry and Current Trends in Tobacco Regulation.

FDA Interaction and Remediation

Direct interaction with the FDA is a stressful, apprehensive experience, even when conducted under the best of circumstances. Compliance Gurus is available to alleviate your corporate anxiety, by offering support during this challenging time. If you have received a Form 482: Notice of Inspection, we can prepare you for the audit by providing pre-inspection guidance. In addition, we are available to accompany you, during the inspection, to help mediate any points of contention between the parties.

Compliance Gurus offers comprehensive remediation services for organizations receiving a Form 483 or Warning Letter, after FDA inspection. We can structure and implement an effective remediation plan to efficiently address any compliance deficiencies or violations. If your company has received a Warning Letter, we can author a satisfactory Company Response and devise a corrective action plan, in adherence to the 15-day response timeline.

In addition, our consultants are available to assist larger corporations with corporate compliance or regulatory remediation projects, which result from a signed Consent Decree or Corporate Integrity Agreement.