Former FDA Investigator/Supervisory Investigator

EXPERIENCE SUMMARY

They have over 28 years of experience with the Food and Drug Administration of which 24 of them have been in the Regulatory Compliance field. They started with the Agency in February 1974.

In January 1977 they became a Consumer Safety Inspector, continuing as such until February 1979. In this capacity, they conducted cGMP inspections of food warehouses, bakeries, and food manufacturing facilities.  They were also involved with cGMP inspections of cosmetics and drug manufactures; recall effectiveness checks, field examinations, and investigations of consumer complaints and injury reports. Many of their inspections resulted in voluntary corrections and the issuance of FD-483’s, NAF and Regulatory Letters.

They were one of the members of the investigation team that participated in the generic drug scandal investigation in the 1990s.  This team was stationed in Rockville, MD and reported directly to the District Attorney, Department of Justice. In this capacity.  They were involved in highly profiled investigations and interrogations of individuals that were responsible for the misconduct and falsification of information presented to the agency in support of applications submitted for approval.

Starting in 1986, they concentrated in the drug and medical device fields conducting inspections of higher complexity with emphasis on sterile drugs and devices. These inspections included many NDA requested inspections, coverage of DPPR'S, MDRs and other special investigations.

In March 1988, they were selected to attend the eight-week Criminal Investigators School given at the Federal Law Enforcement Training Center, Glynco, Georgia. The school qualified them as a criminal FDA investigator. They were involved in several criminal investigations since the conclusion. Due to their specialized training in the drug and criminal fields they were selected by the San Juan District Director to travel to New York, and be a member of an inspection/investigation team together with investigators from the New York District office to participate in a high profile investigation. The investigation disclosed a major counterfeit operation by a generic firm that practically changed the way the agency evaluated ANDA’s and NDAs.

From 1988 to 1990 they performed over 50 comprehensive GMP inspections of manufacturers of bulk pharmaceutical chemical, non-sterile and sterile dosage form products. The types of products inspected included, among others, capsules, tablets, small and large volume parenteral, antibiotics sterile liquids, ointments, cream veterinary drugs. During these inspections, they reviewed a wide variety of manufacturing processes and standard operational procedures to determine adequacy of manufacturing practices and to assure product quality and manufacturing accordance with Current Good Manufacturing Practices.

They performed multiple team inspections with senior and junior investigators where they were the team leader. These inspections were planned strengthen the inspectional approaches and strategy of the team and to provide guidance on inspectional techniques, appropriate administrative procedures, interview techniques and adequate review/collection of records to support CGMP deviations.

During this period of time, they also conducted special assignments related to drug inspections as per specific FDA headquarters and field office requirements. These included limited inspections to investigate API related operations, Consumer Complaints, Drug Product Problem reports, New Drug Application inspections and Field Alerts related issues.

Of the 26 years as an investigator with the FDA 12 years were as a Supervisory Investigator.  In this capacity they led a group of 9 investigators and was their mentor, advisor in the Quality Assurance/ Compliance area for multiple pharmaceutical and medical device establishments.  They were also responsible for the review and endorsement of hundreds of pharmaceutical and medical device establishment reports to assure they adhere to cGMP regulations for each operation cover by the investigators.

Experience in Working with State. Local or other Federal Agencies

They have conducted various joint inspections with inspectors from the Puerto Rico and the U.S. Virgin Islands Health Departments to train them in inspectional sampling and investigation techniques including the proper use of sampling equipment such as UV lights, sieves, and others. At times, they have contacted these State Agencies for assistance in the immediate embargo of adulterated foods and drugs, to assure the holding of lots pending FDA action.

The experience with Federal Agencies has consisted of coordinating the cooperation of agencies such as the U. S. Customs, FBI, and USDA for the accomplishment of several inspections/investigations. For example, they worked extensively with some FBI agents during October 1987 to obtain information on a major counterfeit operations taking place in San Juan, Puerto Rico.

During 1986 and 1987 they participated with U.S. Customs agents in the investigation of smuggling of illegal conch meat from the Dominican Republic and the introduction of mercury contaminated swordfish into the U. S. market.

Experience in Monitoring FDA Programs and Managing Special Project

They were the Low Acid Canned Food Coordinator for the FDA San Juan District from 1982 to 2001 and as such they coordinated meetings with people from industry to give them information on the Low Acid Canned Food Regulation and requirements. They provided guidance and instructions for establishment registration and scheduled process filling.

They worked directly with the FDA San Juan District Director. They set priorities on the work assigned based on the nature of the assignment, the human resources available and the districts obligation under the different agency programs. They issued assignments and monitored their completion. They prepared action reports on the cases being handled by investigators. They attended the districts staff meetings and reported on the work being accomplished. Also they evaluated employees and made the selection to submit candidates for training. They prepared the quality assurance review and answered inquiries from consumers, industry and other government agencies.

They were the FDA San Juan District Import Program Manager from 1990 to 2001. In this capacity they had oversight of the entire FDA San Juan District Import program dealing with over 30 importers, entry filers and US Customs. They managed the FDA electronic systems (OASIS) that interfaces with the Customs System (ACS) and the Customs Brokers (ABI) to expedite the screening of FDA regulated entries.

After their retirement from FDA, They have provided professional services as a Senior Consultant to domestic and foreign Pharmaceutical plants in the area of CGMP compliance for finished drug products and APIs. They have also provided training in the areas of cGMP and regulatory compliance areas to operators.

 

PROFESSIONAL/FDA EXPERIENCE

Jun 2011 to present

Senior Compliance Consultant, Quality System and Compliance

  • Participated in a project of a large pharmaceutical firm relating to upgrading systems and programs in response to FDA 483 Observations issued during two inspections issued between June 2011 and July 2012.  The areas covered during this period were protocol execution relating to remediation in Consumer Complaint procedures/ investigations, CAPA’s and change control procedure evaluations and assessments.

Jan 2006-April 2006

Regulatory Compliance Consultant, GlaxoSmithKline

KEY RESPONSIBILITIES

  • Provide support to the QA CAPA/Investigations functional unit in gathering the evidence from the responsible units to close open corrective/preventive action deemed necessary as a result of events and event investigations action plans. Make sure such evidence meets regulations and resolve the situation they were designed to resolve.

2002 - 2005

Senior Regulatory Consultant, Schering-Plough, Manati, Puerto Rico.

KEY RESPONSIBILITIES

  • Assist firm's management in areas related to cGMP compliance to respond to the FDA Consent Decree and successfully obtain firm certification. 
  • Conduct internal audits of facility to assure compliance with cGMPs. 
  • Review documentation generated to respond to FDA observations to determine adequacy of response.
  • Prepare written responses to FDA observations presented to the agency 1990 – 2001

2001-1989

Supervisory Investigator/Import Program Manager FDA, San Juan District

KEY RESPONSIBILITIES

  • Coordinated and oversaw multiple inspections and investigations by staff.
  • Liaison person between San Juan District and the Puerto Rico Government agencies. Selected to be a member of the FDA/OIG Generic Drug Investigative Task Force.
  • Managed the district's import program operations.
  • Implemented the Imports OASIS electronic system to interface with the ACS/ABI systems to carry out import operations at the FDA, San Juan District Office.
  • Provided training relating to the OASIS system and general import
  • Regulations to the Sam Juan Import community including API registration and Listing and related regulation and guidelines.
  • Review and approved investigative reports of Pharmaceutical and Medical
  • Device industries written by FDA investigators to determine adherence to the CGMP requirements and agency policies.
  • Developed and presented training in the area of food and drug CGMPs to respective regulated industry.

1988 -1984 

Drug Specialist

FDA, San Juan District

KEY RESPONSIBILITIES

Conducted inspections and investigations of complex generic and brand name Drug establishments, developed investigative plans and collected samples to support findings applying CGMPs, Regulatory Agency Guidelines and Procedures.

1983 -1977

Consumer Safety Officer San Juan District, FDA

KEY RESPONSIBILITIES

  • Concentrated in the food program area with the emphasis given to The Low Acid Canned Foods (LACF) and food microbiological issues.
  • LACF coordinator and field contact person.

 1976 -1974

San Jua FDA District Office Consumer Safety Inspector KEY RESPONSIBILITIES

  • Collected hundreds of samples of food, cosmetics, and drug products.
  • Traced business transactions and gathered interstate documentation.
  • Conducted sanitary, inspections of warehouses, bakeries, and food manufacturing facilities.
  • Conducted basic GMP inspections of cosmetic and drug manufacturing plants.

1973-1972

District Purchasing Agent FDA, San Juan District

KEY RESPONSIBILITIES

  • Assisted the Administrative Officer in acquiring office and scientific supplies and equipment.
  • Maintained accountability records for office and scientific equipment.

EDUCATION and TRAINING

  • BS in Business Administration, Inter-American University -1972
  • Criminal Investigator's School, Federal Law Enforcement Training Center, Glynco, GA 1988
  • Auditing Pharmaceutical and Device Quality Systems, University of Rhode Island 2000
  • Quality Systems and Auditing, GMP Institute, 1998
  • Drug Manufacturing Quality Control, Ferris State College, Michigan, 1984
  • Food and Drug Law, Public Health Service, FDA, 1986, San Juan, PR
  • Seminar for Managers, 1994, Public Health Service, FDA, Oak Ridge, Tennessee
  • Process Control Systems, 1985, the Foxboro Company
  • Applied Epidemiology, Center for Disease Control, 1982, Columbus, Ohio
  • Pharmaceutical Manufacturing and Quality Control, Public Health Service, FDA, 1979, San Juan, PR
  • Legal Aspects of Enforcement, Public Health Service, FDA, San Juan, 1984
  • Import Enforcement Procedures, Public Health Service, FDA, 2000, Gaithersburg, MD

SENIOR QUALITY ASSURANCE AND COMPLIANCE PROFILE

  • A former FDA Investigator/Supervisory Investigator with 28 years of experience in the pharmaceutical, biotechnology and medical devices industries.  In addition, experienced in the Regulatory Industry to include Quality Assurance, Quality Control, Regulatory Compliance, and Manufacturing Operations...

TECHNICAL EXPERTISE

  • Auditing of the Pharmaceutical Industry (drugs, devices and biologics) to assure compliance with the Food and Drug Administration regulations and Policies 
  • Training and experience in the criminal investigations area focused in fraud and falsification of production records  
  • Experience in the Consent Decree environment as member of the certification team to the FDA for a large pharmaceutical plant   

LANGUAGES

Superior communication skills in both Spanish and English

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