training programs: what fda expects to see - foi … programs: what fda expects to see eleconf t...
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TC001539A
Training Programs:What FDA Expects to See
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Training Programs:Training Programs: What FDA Expects to Seep
P t d bPresented by: Nancy Singer, John Avellanet, Nicole Petty,
Catherine Crismon, Marla Phillips & Cap UldriksCatherine Crismon, Marla Phillips & Cap Uldriks
March 28, 2011An FOI Services, Inc. TeleconferenceAn FOI Services, Inc. Teleconference
Agenda• Training Requirements
N Si C li Alli– Nancy Singer, Compliance‐Alliance
• Training Records J h A ll t C l A i t LLC– John Avellanet, Cerulean Associates LLC
• Training Best Practices
Ni l P S k I– Nicole Petty, Stryker Instruments
• The MLS Training Program C th i C i M idi Lif S i– Catherine Crismon, Meridian Life Science
• Learning vs. Training M l A Philli Ph D X i U i it– Marla A. Phillips, Ph.D., Xavier University
• Training: A View from a Former FDA OfficialCap Uldriks Olsson Frank Weeda Terman Bode Matz PC– Cap Uldriks, Olsson Frank Weeda Terman Bode Matz PC
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Training:Training:FDA Requirements & q
Warning Letter Citations
Nancy SingerNancy SingerCompliance‐Alliance, LLCNancy Singer@juno [email protected]
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Device Regs: 21 CRF 820 20(b)Device Regs: 21 CRF 820.20(b)
(2) Resources. Each manufacturer shall provide adequate resources, including the assignment of trained personnel, for management, performance of work, and assessment activities, including internal quality audits, to meet the
i f hirequirements of this part.
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Device Regs: 21 CFR 820.25Sec. 820.25 Personnel. (a)General. Each manufacturer shall have sufficient personnel with the necessary education backgroundpersonnel with the necessary education, background, training, and experience to assure that all activities required by this part are correctly performed.(b)Training. Each manufacturer shall establish procedures for identifying training needs and ensure that all personnel are trained to adequately perform their assignedtrained to adequately perform their assigned responsibilities. Training shall be documented.
(1) As part of their training, personnel shall be made f d i d f hi h f haware of device defects which may occur from the
improper performance of their specific jobs.(2) Personnel who perform verification and validation ( ) e so e o pe o e ca o a d a da o
activities shall be made aware of defects and errors that may be encountered as part of their job functions.functions.
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Drug Regs 21 CFR 211 25(a)Drug Regs. 21 CFR 211.25(a)
Each person engaged in the manufacture, processing, packing, or holding of a drug product shall have d i i i d i bi ieducation, training, and experience, or any combination thereof, to enable that person to perform the assigned f ifunctions.
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Drug Regs: 21 CFR 211.25(a) g g(continued)
Training shall be in the particular operations that the employee performs and in current good manufacturing practice (including the current good manufacturing practice regulations in this chapter d itt d i d b thand written procedures required by these
regulations) as they relate to the employee’s functions Training in current good manufacturingfunctions. Training in current good manufacturing practice shall be conducted by qualified individuals on a continuing basis and with sufficient frequency o a co t u g bas s a d t su c e t eque cyto assure that employees remain familiar with CGMP requirements applicable to them.
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Drug Regs: 21 CFR 211 25(b)Drug Regs: 21 CFR 211.25(b)
Each person responsible for supervising the manufacture, processing, packing, or holding of a drug product shall have the education, training, and experience, or any combination thereof, to perform assigned functions in
h id h h dsuch a manner as to provide assurance that the drug product has the safety, identity, strength, quality, and
i h i i dpurity that it purports or is represented to possess.
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Establishment Inspection Reports (EIRs)
• Most EIRs contain a section on how the firm trains it personneltrains it personnel.
• The firm's training programs are of particular significance where inspectional findings find people may not be adequately trained.p p y q y
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November 2010 Warning Letter to Optilasa SA
Failure to establish and maintain adequate procedures for identifying training needs and ensure that all personnel are trained to adequately perform their assigned responsibilities, to include documentation of h i i i d b 21 820 25(b) F lthe training, as required by 21 820.25(b). For example, Procedure PC‐05, Training, includes requirements for employee training However there is no documentationemployee training. However, there is no documentation to show that employees were trained.
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December 2010 Warning Letterto Airgas, Inc.
In your firm's response, your firm proposes training employees in "all applicable CGMP requirements" as a corrective action. Your response is inadequate because you have not defined what specific information will be i l d d i CGMP i iincluded in your CGMP training.
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January 2011 Warning Letter to Lynn Peavey Company
F il t t bli h d f id tif i t i i d dFailure to establish procedures for identifying training needs and ensure that all personnel are trained to adequately perform their assigned responsibilities, as required by 21 CFR 820.25(b).
For example, your firm does not maintain a standard operating procedure for identifying personnel training needs and ensuring th t ll l t i d t d t l f th i i dthat all personnel are trained to adequately perform their assigned responsibilities with regard to the manufacturing of regulated medical devices including the Sexual Assault Evidence Collection Kit and the Blood Alcohol Collection Kit According to a documentand the Blood Alcohol Collection Kit. According to a document entitled: "Sexual Assault Assembly Certification" dated (b)(4). (b)(4)team members were certified to assemble Sexual Assault Evidence Collection Kits but the uncontrolled document does not identifyCollection Kits, but the uncontrolled document does not identify the training needs necessary for this certification.
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February 2011 Warning Letter to Sanofi‐Aventis Deutschland GmbHY fi f il d h h d i hYour firm failed to ensure that each person engaged in the manufacture, processing, packing, or holding of a drug product has the education, training, and experience, or any combination thereof, to enable that person to perform the assigned functions. [21 C.F.R. § 211.25(a)].
For example, on September 6 and 9, 2010, operators involved in the cleaning operations and aseptic connections during filling were observed demonstrating incorrect asepticfilling, were observed demonstrating incorrect aseptic techniques to prevent product contamination. We expect that operators who conduct operations within aseptic processing areas be properly trained and monitored to ensure thatareas be properly trained and monitored to ensure that proper aseptic techniques are utilized during all operations.
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February 2011 Warning Letter to Southern Implants (Pty) Ltd.
CAPA (b)(4) was opened in July 2010 as a preventive action regarding the lack of consistent procedures for applying laser marking on devices. The CAPA included categorizing laser marked products with information pertaining to the location of information for laser markings. The interim corrective action included using (b)(4) as guidance for the laser marking operators yet no documentation of the use of the (b)(4) or training of the operators on these revised procedures was made.
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February 2011 Warning Letter to RD Medical Manufacturing Holding Company
We found your response to this deficiency inadequate. You indicated that you have training records documenting the training of your personnel in specific functions and general g y p p gfunctions. Nevertheless, you failed to include evidence in your written response to show that your operators have been trained in the techniques described above. You also indicated qthat your training procedure will be revised to include a certification program as part of your training requirements. Your target completion date is the second quarter of 2011.Your target completion date is the second quarter of 2011. Please indicate which interim measures you have taken to ensure that your operators are adequately trained to perform the (b)(4) technique and the (b)(4). The release forperform the (b)(4) technique and the (b)(4). The release for distribution of several of your products depends in part on the operator's ability to adequately perform these tasks.
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John AvellanetJohn [email protected]
Cerulean Associates LLC
pathways to misfortune
US requirements
do’s and don’ts
TRAINING RECORDS
do’s and don’ts
lean compliance SOP elements
TRAINING RECORDS
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Typical SOP ElementsTypical SOP Elements
• Reasons for trainingStandard Operating Procedure
• Types of trainingQuality Management System
• Tracking of trainingTraining SOP
• Attendance sign‐in sheetCerulean
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Pathways to MisfortunePathways to Misfortune
Roles
• supervisor
Effectiveness
• learning
RecordsRetention
• company
ProcessLinks
• disciplinesupervisor• attendee
learning objectives
• metrics
company records
• personal records
• departmental
discipline• compliance• corporate
liabilityf ti l• departmental
records• cross-functional
activities• other QMS
processes
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Questions to ConsiderQuestions to Consider
S i R lSupervisor Role• does the supervisor discuss the training and results with the attendee?• does the supervisor evaluate the knowledge sufficiency of thedoes the supervisor evaluate the knowledge sufficiency of the
attendee?• does the supervisor document the training event?
d th i i di ll l t i di id l t i i d ?• does the supervisor periodically evaluate individual training needs?
Attendee RoleAttendee Role• does the attendee actively acknowledge and understand the training?• does the attendee transfer the training to job performance and/or does the attendee transfer the training to job performance and/or
product safety and efficacy responsibilities?
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Questions to ConsiderQuestions to Consider
Eff iEffectiveness• how are training needs identified?
• how is the transfer of trained knowledge into the attendee’s daily responsibilities measured or tracked during and/or immediately after training?
• how is the transfer of trained knowledge measured or tracked 30‐90 days after training?
• does the training SOP provide sample effectiveness measures for trainers to draw upon?
• how is a trainer selected?how is a trainer selected?
• how is are drafted training materials assessed for appropriateness, level of detail, accuracy, and learning objectives?
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U S Regulations & StatutesU.S. Regulations & Statutes• 21 CFR 58 195• 21 CFR 58.195• 21 CFR 110.10• 21 CFR 111.14• 21 CFR 211.25• 21 CFR 312.62
U.S. Code of Federal Regulations alone has
1 416 req irements• 21 CFR 600.10• 21 CFR 606.20• 21 CFR 812.140• 21 CFR 820.20, .25, .70
1,416 requirementsfor training records
retention!• 29 CFR 825.500• 29 CFR 1601.31• 29 CFR 1602.14, .31• 29 CFR 1627.3• 40 CFR 264 73
retention!
• 40 CFR 264.73• FDCA• FAAA• FLSA• ERISA• Title VII (ADEA, GINA, EPA)• UCC 2‐725 (contractors only)• State statute of limitations (contractors only)
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Example Retention PeriodsExample Retention Periods
UC 2‐725
Title VII
40 CFR 264
UC 2 725
29 CFR 1627
21 CFR 820
21 CFR 312
21 CFR 820
0 2 4 6 8 10 12 14
Required Years after Event22
TranslationTranslation
retain a person’s training records untilthe date they leave the organizationthe date they leave the organization
+ 6 years+ 6 years
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Certificate of UnderstandingCertificate of Understanding
Document• active attendee participatory role
• supervisory review & approvesupervisory review & approve
Support personnel actions
Help limit company liability
Foster personal sense of ibilit f liresponsibility for compliance
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Documentation Do’sDocumentation Do s
Wh d d h i iWho conducted the training
How the training was conductedHow the training was conducted
When the training occurred
Who attended the training
Summarize the training provided
Identify effectivenessmeasuresIdentify effectivenessmeasures
Why training related to job and/or product
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Documentation Don’tsDocumentation Don ts
Segregate training records by department
Retain materials with every individual record
Forget supervisory role to review and decide
I d i t k i f t i i t i lIgnore desire to keep copies of training materials• attendees
i di id l t i (SME)• individual trainer (SME)
Exclude 3rd party‐provided training• organization’s official record
• individual’s own record
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3rd Party Training Certificates3rd‐Party Training Certificates
Document attendance• may want to require agendas
Support personnel actions
Help limit company liability
Encourage individual responsibility for compliance
• continuous improvement
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More Documentation Do’sMore Documentation Do s
Retain 1 set of training materials for future use
Rely upon the training matrixRely upon the training matrix
Archive yearly copy of the training matrix
Audit annually your training records
• current set of training materials – discrepancies?
• personnel training records (ANZI z1.4 sampling)
• relationship to other cross‐functional controls
• retrieval speed vs. retrieval accuracy
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Lean Compliance Training SOPLean Compliance Training SOP
Elements• Supervisor’s roleStandard Operating Procedure
• Use of training matrix
• Effectiveness measuresQuality Management
System• Records to retain
• Training/re‐training triggersTraining SOP
• Roles of compliance teams
• Linkages to HR, IT, etc.
• Defining learning objectives
• 3rd party certificate usage
Cerulean
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More SOPs to ConsiderMore SOPs to Consider
• Developing training materials
• Training matrices – creation and maintenance
• Training records – retention and archival
• Verification of training effectiveness• Verification of training effectiveness
• Overview of the training cycle (guideline)
• Presentation design best practices (guideline)
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www ceruleanllc com/resources/foi2811/www.ceruleanllc.com/resources/foi2811/
14 i i SOP14‐step training SOP process map• from identifying training needs to storing the required records
Training program self‐assessment26 d il d i ( i h i l )• 26 detailed questions (with a ratings scale)on training programs taken from FDA inspector training, FDA & EMA inspection experiences and audit best practicesexperiences, and audit best practices
Regulations impacting trainingg p g g• common US regulations and laws affecting training records
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T i i B t P tiTraining Best Practices
Nicole PettySr. Manager Learning & Development
Stryker [email protected]
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S k I h ADDIEStryker Instruments uses the ADDIE model for our training programs
AAnalysis ‐ ‐ Annual Training Analysis to align training with budget and business strategy as well as at the individual training item level
DD i & DD l DDesign & DDevelopment ‐ ‐ Design training and evaluation plan and materials with SMEs ‐ ‐ including the appropriate method of training
IImplementation ‐ ‐ Learning Management System (LMS) coordinators communicate & assign training via curriculumsg g
EEvaluation ‐ ‐ Throughout the process, done both for individual training items as well as the overall training program
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Training Responsibilities ‐ EVERYONE plays a part in making training effectivemaking training effective
36
Who must comply?Who must comply?
CompanyCompany ContractorsContractorsTempsTempsConsultantsConsultantsCompany PersonnelCompany Personnel
ContractorsContractorsTempsTempsConsultantsConsultants
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Use curriculums to manage trainingUse curriculums to manage training assignments based on roles & responsibilities
Personal ComplianceDevelopmentPersonal ComplianceDevelopmentDevelopmentDevelopment
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Monitoring training and build a learning culture
Management can see who is past dueManagement can see who is past dueManagement can see who is past due on training with a click of a button.
Management can see who is past due on training with a click of a button.
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Working as a team to deliver effective training…
Annual employee survey for training,
Monitor training and give feedback through Annual Training Plan &
training evaluations, Individual
Development Plans
management review
Review training to ensure it will meet the need & that
Work together to provide
the need & that the training is assigned to the appropriate peopleto provide
appropriate learning solutions
people
Identify training needs for employees and help build training curriculums for their team
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The MLS Training Programbyy
Catherine Crismon, B.S. M.S, RABQSA‐LA
Quality Systems ManagerMeridian Life Science
[email protected] @901‐322‐9594
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MLS Training ProgramMLS Training Program
• Different Types and Levels of Training
• Company Wide versus Job Specific
• Establishing Training RecordsEstablishing Training Records
• Meeting ISO and Regulatory Requirements
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Taking Charge!Taking Charge!
• Who is in Charge of the Training Program?– Quality Assurance: task specific training, quality Q y p g, q yspecific training (ISO)
– Human Resources: EEOC and OSHA relatedHuman Resources: EEOC and OSHA related training
Wh i i Ch f M it i th T i i ?• Who is in Charge of Monitoring the Training?– Each supervisor: records must be reviewed at the end of each year at the same time performance evaluations are conducted.
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Take Charge!Take Charge!
• Who is in charge of conducting the training?– Quality Assurance and Human Resources Q y
• Work in tandem on safety and quality related subjects
• QA arrange in house training seminars (e.g., how toQA arrange in house training seminars (e.g., how to write a CAPA)
• HR conducts lunch and learn sessions (e.g., conducting ( g , geffective interviews)
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Who is Required to Be Trained?Who is Required to Be Trained?
• Everyone must attend the EEOC and OSHA related training.g
• Each employee must obtain training related to his or her job prior to doing that jobhis or her job prior to doing that job.
• No employee is exempt from getting the necessary training for his or her job or for EEOC/OSHA training.EEOC/OSHA training.
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Training EffectivenessTraining Effectiveness
• Some training sessions require a test upon completion. p
• All jobs and associated documentation and records are audited by the QA staff forrecords are audited by the QA staff for accuracy and completeness.
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Participation/Buy InParticipation/Buy‐In
• Work with upper management on the importance of training.p g
• Well‐trained employees affect the bottom line in a positive wayin a positive way.
• Poorly‐trained or untrained employees are problematic and create extra work, scrap, nonconformities and unsafe workingnonconformities and unsafe working conditions.
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Learningvs.
dBeing Trained
Marla A. Phillips, Ph.D.Xavier University
513‐745‐3073
wwwMedXU comwww.MedXU.com
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Typical Academic ModelsTypical Academic Models
• Grade School
– Teaching is focused on drilling information
– Teaching methods include projects, field trips, and hands‐on activities
• Undergraduate
– Increase in the amount of hands‐on learning and self‐discovery.
Teaching methods incl de papers st d– Teaching methods include papers, study groups, co‐ops, internships, laboratories, foreign exchange, residency, case studies, simulations, practicum, and seminars
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Adult EducationAdult Education
• Tie the information delivered to an experience that they have encountered or with which they can relate
• Adults learn best through discussion,Adults learn best through discussion, sharing own experiences and asking questions
• Include variety, interaction, “entertainment”
• Interestingly, adults do not follow directions very well/completely when compared to students. Why?
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Employee TrainingEmployee Training
• “Read and Understand” approachRead and Understand approach– What is the least effective academic learning model?
– Can be appropriate for very basic and simple processes
• Competency‐based training and qualification– Often not done properly
– Often not tied to a risk assessment model
• Example: Qualification of chemists on everyExample: Qualification of chemists on every analytical or microbiological method – All or nothing approach
– Why?
– It is harder to think through and justify the right course of action, so instead just have everyone train on everything.
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Risk ModelRisk Model
10
Qualification, Apprentice
Competency Based,Demonstrations
Probability
Read and C t B dRead andunderstand
Competency Based,Demonstrations
00
0 10
Impact
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Risk Based Employee TrainingRisk Based Employee Training1. Read and Understand
H d H i L D i– How to conduct pH testing, Loss on Drying
2. Competency Based Training or Demonstrating Proficiency– Case studies on proper investigation techniques to identify root cause– Case studies on proper investigation techniques to identify root cause
– Demonstrating that simple analytical methods can be run using a live sample
3. Qualification– Complex analytical methods – equipment, method, formulation
4 Assess effectiveness – monitor human errors4. Assess effectiveness – monitor human errors– Listen to employee suggestions
– Involve employees in the training process
Effective Training
• Optimize learning: self‐discovery, experiential
• Focus resources on areas of greatest impact 53
Training: A View from a FormerTraining: A View from a Former FDA Official
Cap UldriksOl F k W d T B d M PCOlsson Frank Weeda Terman Bode Matz PC
Formerly CDRH's Associate Director for Regulatory Guidance and Regulatory Affairs
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FDA PerspectiveFDA Perspective
• Why does FDA believe that training is critical t fi ’ ti i t t f t l?to a firm’s operating in a state of control?
• What questions will an FDA investigator ask to q gdetermine whether people have received adequate training?
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FDA PerspectiveFDA Perspective
• How should you respond to a 483 observation i l tt th t lor warning letter that says employees were
not trained adequately, if at all?
• How do FDA investigators feel when a firm’s hi h d i ihistory shows repeated promises to train or retrain employees, but no such training occurs?occurs?
56
FDA PerspectiveFDA Perspective
• Does FDA prefer one method of training over another (e.g., in‐person, online, read a ( g , p , ,document and take a test)?
• What is the best way to prove to an investigator that employees are trained?
57
FDA PerspectiveFDA Perspective
• If a trained employee makes a mistake, willIf a trained employee makes a mistake, will FDA automatically assume that the person was not trained?was not trained?
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Thank You!Thank You! Questions?
If you prefer to submit a question to the panel later, please email y p q p , pyour inquiry to Nancy Singer at [email protected] or
phone her at +1‐703‐525‐4159.
Your feedback is valued!
Please complete & return the evaluation to enter a drawing for a $100 amazon.com gift card and/or receive a certificate
if i 1 5 h f i i d iverifying your 1.5 hours of continuing education.
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Training Evaluation FormTraining Programs: What FDA Expects to SeeMarch 28, 2011 — Presented by a Distinguished Panel of Experts
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TC001539
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