FSMA Collaborative Training Forum: ‘Educate Before and While We Regulate’

By: Donald Kautter Jr. and Stephen Hughes

“We will educate before and while we regulate.”

That’s been a mantra for FDA as the rules that implement the FDA Food Safety Modernization Act (FSMA) have taken shape. Making sure that food producers understand the new requirements and have the knowledge they need to meet them is key to the success of this effort to prevent illnesses caused by domestic and imported foods.

However, FDA recognized early on that one size won’t fit all when it comes to training and that a variety of training options and delivery formats would be necessary to meet needs shaped by product, region, size, and other factors.

Enter the FSMA Collaborative Training Forum, convened in partnership by FDA and the U.S. Department of Agriculture. The forum is made up of the agencies, centers, associations, universities and others funded by FDA and USDA through cooperative agreements and grants to develop and deliver FSMA training. Communication between them is important to minimize overlap and improve coordination and efficiency.

The forum held its first meetings in April. Participants laid the groundwork for a vibrant collaboration that will support diverse food producers who are preparing to meet the FSMA standards.

photo of various produceThe diversity of the food producers is matched by the diverse community of training providers. The forum includes representatives of the public-private alliances funded primarily by FDA as a resource for industry: the Produce Safety, Food Safety Preventive Controls and Sprout Safety Alliances. It also includes the National Coordination Center (NCC) and four Regional Centers that were created in a partnership between FDA and USDA’s National Institute of Food and Agriculture to provide training opportunities for farmers, small food processors, and small produce merchant wholesalers.

In addition, the National Farmers Union Foundation and the University of Arkansas-Fayetteville, which entered into cooperative agreements with FDA to develop training curricula and delivery for local and tribal food producers, respectively, are among the training providers. The National Association of State Departments of Agriculture, which is engaged in a cooperative agreement with FDA to plan implementation of the produce safety rule, is also a member of the forum.

Last, but not least, there’s the Joint Institute for Food Safety and Applied Nutrition (JIFSAN), a partnership between the FDA and the University of Maryland that is focused on increasing global knowledge of effective food safety practices.

These first meetings focused on the new produce safety standards, which set science and risk-based requirements for the production of fruits and vegetables. All of these training programs are up and running, although they’re at different stages of development. But no matter where they are in this journey, they’re working together. The NCC, for example, has been coordinating with regional centers monthly and, through forum discussions, is now including those working with local and tribal food producers.

Everyone wants to measure success and to determine that they’re reaching the right audiences. Examining metrics and coordinating data will be a priority going forward so that all training providers have the same sense of what’s working and what isn’t.

Group members shared their experiences and knowledge in these first meetings. For example, a common experience has been that growers don’t use online training as much as other food producers. Lack of access to the internet or insufficient bandwidth to run the programs are the issues for some. We’ll reshape how the training is offered based on feedback as more data are collected.

This is just the beginning. There are plans to work with forum participants to post resource materials in a way that’s accessible to food producers around the world.

This is a great example of good governance – working in partnership and communicating across organizational boundaries to support those who will do the important work of strengthening our food safety system. The forum will meet every few months to help ensure that training programs meet the needs of those who must understand the new FSMA standards, no matter their size, nature, or location.

Donald Kautter Jr. is a Consumer Safety Officer in FDA’s Division of Plant Products and Beverages.

Stephen Hughes is a Team Leader in FDA’s Produce Safety Network.

They are the FDA co-leads of the FSMA Collaborative Training Forum, and partner closely with USDA to facilitate the forum.

‘Radiating Shoe Sales’

By: Vanessa Burrows

Since the discovery of X-rays in the late 19th century, the technology has enhanced health care in a variety of ways. Like many cutting-edge scientific developments, however, it also has inspired uses of uncertain therapeutic value. That was the case with the shoe-fitting fluoroscope, the subject of the latest episode of FDA’s history video series.

Vanessa Burrons

Vanessa Burrows, FDA Historian, next to a shoe-fitting fluoroscope

Marketed as a scientific method for optimizing shoe fit, the fluoroscope appeared in shoe stores nationwide from the 1920s to the 1960s. But the machines not only didn’t do what they promised, they also exposed children, their parents, and store clerks to unhealthy doses of radiation.

In the late 1940s, scientists and regulators began to raise serious concerns about the dangerous levels of radiation. Over the next two decades, individual states gradually took action to either ban or restrict the use of the device.

By the 1970s, concerns grew about radiation emitted from common appliances, such as televisions and microwave ovens. And in 1971, FDA was given authority to regulate radiation-emitting devices. The agency continues this oversight, working to protect consumers from harmful novelty devices like the shoe-fitting fluoroscope. FDA also sets standards for medical imaging, surgical and therapeutic equipment, security systems, and consumer products – all for the protection of the health of American consumers.

We hope you enjoy your visit to FDA’s HistoryVault.

Vanessa Burrows is an FDA Historian

Reducing Preventable Harm from Medications: Too Big for FDA to Do Alone

By: John J. Whyte, M.D., M.P.H.

Sometimes a drug can be used exactly as FDA approved it, taken just the way a doctor prescribed it, and a patient can still experience adverse events. When it comes to drugs, not all risks are known – even after approval.

John WhyteSadly, however, harm from medications also may come from known risks that could have been prevented. The Institute of Medicine (now called the National Academy of Medicine) estimated that at least 1.5 million preventable adverse drug events occur within our health care system each year. It’s a complex system where safety issues can arise at any turn.

Among the many challenges, prescribers and other providers often struggle with the intricacies of today’s health care system, patients can have difficulty following detailed directions, and manufacturers must carefully package and label their products to avoid confusion and misunderstanding for how they are used.

Even giving a child a dose of acetaminophen, the commonly-used over-the-counter pain reliever and fever reducer, can lead to tragic results. The product is available in a strongly concentrated form for infants so they can take a very small amount, as well as a much weaker form for older kids to swallow by the teaspoonful. Unfortunately, over the years, some parents have accidentally given their infants a full teaspoonful of the stronger concentrated form, resulting in serious liver damage and even death.

Safe Use blog imageReducing preventable harm from medications is a big part of FDA’s mission. It requires teamwork across all of health care and the medication manufacturing, distribution, and delivery system.

As one of many ways we facilitate that teamwork, FDA’s Center for Drug Evaluation and Research’s Professional Affairs and Stakeholder Engagement Staff is hosting a one-day public meeting on June 15, 2017, called “Safe Use Symposium: A Focus on Reducing Preventable Harm From Drugs in the Outpatient Setting.”

We’ll gather with patients, caregivers, prescribers, pharmacists, manufacturers, distributors, and others to discuss sources of preventable harm from drugs in the outpatient setting. Attendees will consider situations such as the use of inappropriate medications in certain age groups, the use of drugs that interact with one another, and unintended exposures of dangerous medications to children.

Those attending will include representatives from:

  • Federal agencies such as the Drug Enforcement Agency, the Agency for Healthcare Research and Quality, the Centers for Disease Control and Prevention, and the Centers for Medicare and Medicaid Services;
  • State regulatory bodies, including professional licensure and oversight boards;
  • Healthcare insurers; and
  • Patient advocacy organizations.

During this symposium, we want to generate ideas for specific solutions to reduce preventable harms and discuss how to evaluate the ideas’ effectiveness. These new ideas for future research can be funded by grants from FDA’s Safe Use Initiative. A variety of important research projects have been completed and FDA offers new opportunities on an ongoing basis.

There is no registration fee but early registration is recommended because seating is limited. More information about registration is available online.

We encourage all parties interested in the safe use of medications to attend. Some jobs, such as reducing the many forms of preventable harms from medication, are too big for one organization. It truly requires a communal and collaborative effort for success.

John J. Whyte, M.D., M.P.H., is Director of Professional Affairs and Stakeholder Engagement at FDA’s Center for Drug Evaluation and Research

FDA and NIH Release Final Template for Clinical Trial Protocols

By: Peter Marks, M.D., Ph.D.

A little more than a year ago, FDA and NIH announced the availability of a draft template for investigators to use when organizing clinical trial protocols, which are essentially roadmaps for conducting a clinical trial.

Peter MarksToday, we are excited to announce that the NIH-FDA Joint Leadership Council has issued a final version of the template, a development which is likely to contribute important efficiencies to the process of protocol development, saving medical product development time and money.

The final version is intended for clinical investigators who are writing protocols for phase 2 and phase 3 NIH-funded studies requiring investigational new drug or investigational device exemption applications, but could also be helpful to other investigators conducting studies of medical products that are not regulated by FDA. It provides both instructional and sample text and reflects input from the public, consisting of nearly 200 comments from over 60 individuals. Importantly, it also has been harmonized with a separate protocol template that was recently developed by the private sector organization, Transcelerate Biopharma, for industry-sponsored research.

Clinical trial protocols are critical components of any medical product development program, describing trial objectives, trial design, methodology, statistical considerations, and trial organization.

Having a standard protocol format will facilitate review of protocols by regulators and others (e.g., institutional review boards). We believe that the template will help investigators prepare protocols that are consistent and well organized, contain all the information necessary for the clinical trial to be properly reviewed, and follow the International Conference on Harmonisation (ICH) E6 Good Clinical Practice guidelines. By clarifying expectations, the template will contribute important time and money-saving efficiencies.

Guidance is available from FDA on the content that should be included in a protocol to help ensure human subject protection and high data quality, but the guidance does not describe a standardized format for presenting this information. Placing relevant information in a standardized location in a clinical trial protocol can expedite the development and review of protocols thus enabling a quicker start of a clinical trial, potentially leading to more timely completion of studies and getting important new treatments to patients more quickly. What’s more, with the increased complexity of clinical development, such as use of combinations of different medical products, it is more important than ever that investigators understand protocol development expectations and capture important components right from the start.

NIH, which supports and conducts biomedical research, and FDA, which evaluates the safety and effectiveness of medical products and depends on high-quality research to inform its decisions, agreed that developing a protocol template would be an excellent opportunity to help improve the design of clinical trials. Our agencies believe that the availability of this template and accompanying instructional information will be very useful to investigators in creating well-organized, high-quality protocols — a benefit to everyone involved in medical product development.

Peter Marks, M.D., Ph.D., is the Director of FDA’s Center for Biologics Evaluation and Research