Computer System Audit Preparation Steps

The first and foremost step for a computer system audit is to prepare a robust computer system validation program which must include : Validation Policy – which talks about various policies you have internally which defines what are the processes you must have and as a company  what you will do. Validation Procedure – these Read more about Computer System Audit Preparation Steps[…]

Novel Foods Regulation

Novel Food defined as food that has not been consumed to a significant degree in the EU before May 15, 1997 AND falls within at least one of 10 categories listed in Article 3 of the new regulation. Determination of Novel Status – Guiding steps: 1.Assess whether the ingredient is excluded from the scope (food Read more about Novel Foods Regulation[…]

Food Supplement Manufacturing & Quality Assurance considerations in EU

Food supplements marketed in a EU Member State have to comply with all relevant aspects of EU food legislation and any specific EU Member State national legislation in terms of their composition, manufacture and control. Food Supplements are considered as “foodstuffs” under the EU General Food Law Regulation (EC) No 178/2002 Required to comply with Read more about Food Supplement Manufacturing & Quality Assurance considerations in EU[…]

FTC Evaluation Process for Advertising Dietary Supplements

The FDA and FTC work together under a long-standing liaison agreement governing the division of responsibilities between the two agencies. The FDA has primary responsibility for claims on product labelling, including packaging, inserts, and other promotional material. The FTC has primary responsibility for claims in advertising, in print and broadcast ads, informercials, catalogues, and digital Read more about FTC Evaluation Process for Advertising Dietary Supplements[…]

21 CFR 117- FSMA – Current GMPs, Hazard Analysis, and Risk-Based Preventive Controls for Human Food

While specifically exempted from Subparts C and G of 117, due to overlap with 111, dietary supplement manufacturers/companies have responsibility for compliance with subparts A (General Provisions), B (cGMPs), and F (Records that must be established and maintained).   FSMA spells out an exemption to subpart G, – Supply-Chain Program, but these exemptions apply only Read more about 21 CFR 117- FSMA – Current GMPs, Hazard Analysis, and Risk-Based Preventive Controls for Human Food[…]

21 CFR Part 111 – Good Manufacturing Practice (GMP) for Dietary Supplements

The bare minimum current good manufacturing practice for preparation of dietary supplements for human consumption consists of 16 subparts with 84 unique requirements. Key requirement below Manufacturers required to implement a system of production and process controls for all stages of the manufacturing, packaging, labeling, quality control, record-keeping, storing, and distributing of DS to ensure Read more about 21 CFR Part 111 – Good Manufacturing Practice (GMP) for Dietary Supplements[…]

BSA Risk Assessment Problems

A bank’s risk assessment should assist in effectively managing the BSA/AML risk and, therefore, is critical in the development of applicable internal controls, as required for your BSA/AML compliance program. Common Problems with Risk Assessments are: Incomplete Identification of relevant risk factors is . Insufficient detail of a risk factor to evaluate potential risk. Mitigating Read more about BSA Risk Assessment Problems[…]