The industry of products containing cannabis or related products like CBD has become increasingly popular and more available. One of the main catalysts for this cannabis business trend was The 2018 Farm Bill. The Farm Bill allowed for the agricultural production, transport and possession of hemp products, with some serious restrictions. The bill requires hemp to contain 0.3 percent or less of THC (the compound that can produce mind-altering effects) and also creates additional rules around the production of hemp.
Nevertheless, since the passing of the Farm Bill and since a growing interest in legalizing cannabis at the state level, both for personal and medical use, the marketplace has seen a big growth in Cannabidiol (CBD) and marijuana-based products. Despite this, businesses and consumers alike remain confused about what is and is not permitted by law.
Part of the challenge is that a gray area can exist between regulatory agencies, federal rules and state laws. This can cause confusion. Regulatory agencies and states are especially concerned with how companies market their product, so even a legal product can run afoul of regulations.
Regulatory Trends
Right now, some of the parallels in this industry include:
- FDA warning letters: The FDA is sending warning letters to businesses offering CBD and marijuana-based products in situations where unsubstantiated claims are made. The FDA is especially strict with products being classified as dietary supplements. In June 2019, for example, the FDA sent warning letters to Curaleaf, advising the company that its marketing does not comply with the Federal Food, Drug and Cosmetic Act.
- New testing needs: Products with CBD need to be tested in controlled, clinical based studies if businesses want to establish and confirm claims. However, federal regulations listing marijuana as a schedule 1 substance make such tests legally challenging for many businesses. In addition, the rules for testing and compliance are constantly changing, creating added confusion about what is needed in terms of testing, reporting and compliance in general.
- Some progress: In the industry, some are heartened by some signs of forward movement. The FDA did approve Epidiolex, a drug that contains CBD as a primary ingredient. The drug is used to treat Lennox-Gastaut syndrome or Dravet syndrome. The manufacturers of the medicine had to undergo testing and the approval process other drugs must undergo, so while the case sets the precedent that CBD and CBD-containing products can be classified as drugs, it does suggest manufacturers will need to undergo the same strict process.
- Projected future regulations: In May 2019, the FDA held a public meeting to discuss the safety, manufacturing, marketing, sale and use of drugs and products with cannabis or cannabis-derived compounds as ingredients. The meeting allowed experts and the public to express opinions, concerns and requests. In addition, industry insiders say the Current Good Manufacturing Practice (CGMP) regulations set by the FDA for drugs will soon likely include updated guidelines for CBD-containing drugs.
Stay on Top of Trends
Regulatory Compliance Associates helps companies stay compliant with changing FDA regulations surrounding the cannabis business. Whether you are producing CBD products or want to expand your current line of products, we help resolve regulatory and quality challenges to ensure compliance, even in an environment where gray areas still exist. Contact us at Regulatory Compliance Associates today for support.
About RCA’s Pharmaceutical Consulting Services
Regulatory Compliance Associates (RCA) has helped thousands of pharmaceutical companies meet regulatory, compliance, quality assurance, and remediation challenges. With more than 20 years of experience with FDA, Health Canada, EU and global regulatory agencies worldwide, Regulatory Compliance Associates® offers leading pharmaceutical consultants. We’re one of the few pharma consulting companies that can help you navigate the challenges associated with industry regulations.
Our pharmaceutical consulting firm includes over 500 seasoned FDA, Health Canada & EU compliance consultants and regulatory affairs experts who understand industry complexities. It’s a pharma consultancy founded by regulatory compliance executives from the pharmaceutical industry. Every pharmaceutical industry consultant on the Regulatory Compliance Associates team knows the unique inner workings of the regulatory process.
Client Solutions
Whether you’re in the product planning, development or pharmaceutical lifecycle management stage or need a remediation strategy for a compliance crisis, Regulatory Compliance Associates will guide you through every pharmaceutical consulting step of the regulatory process and create a customized approach depending on your product and your pharma company’s individual needs. Our regulatory compliance clients include:
- Companies new to FDA, Health Canada or EU regulations and regulatory compliance
- Start-up organizations with novel submissions to 510(k) submissions from multi-national corporations
- Investment firms seeking private equity due diligence for pre-acquisition and post-deal research
- Law firms seeking pharmaceutical consulting firm expertise in the remediation of warning letters, consent decrees, 483’s or import bans
Regulatory Affairs
Regulatory affairs is Regulatory Compliance Associates backbone. We exceed other pharma consulting companies with industry experts experienced in complexities of the pharmaceutical and biopharmaceutical industries. Our pharma consulting expertise spans all facets and levels of Regulatory Affairs, from Regulatory Support for New Products to Life Cycle Management, to other services like Outsourced Regulatory Affairs, Submissions, Training, and more.
As your partner, we can negotiate the potential assessment minefield of regulatory compliance services with insight, hindsight, and the clear advantage of our breadth and depth of knowledge and regulatory compliance consulting. We offer the following pharma consulting regulatory affairs services for pharmaceutical companies.
- New Product Support
- Product Lifecycle
- Other Regulatory Services
- Combination Products
Compliance Assurance
The regulations process surrounding pharmaceutical companies can be tricky for even the most experienced industry veteran to understand. Just one misstep could mean significant and lasting consequences for your business. At Regulatory Compliance Associates, we offer the pharma consulting experience and pharma consultants necessary to guide you through the quality compliance process.
- Assessments
- Audits
- Regulatory Agency Response
- Preparation and Training
- Inspection Readiness
- Data Integrity
Quality Assurance
Regulatory Compliance Associates Quality consulting includes assessments, strategy, implementations, staff augmentations, and identification of quality metrics to ensure continuous improvement. Our pharma consultants understand the strategic thinking needed to align your business needs and goals. Regulatory Compliance Associates quality assurance services include quality experts with experience spanning major corporations and start-ups. Our pharmaceutical consulting firm knows firsthand how to achieve, maintain, and improve quality, and we excel in transferring pharma consulting knowledge to your organization.
- 21 CFR Part 11
- Data Integrity
- Manufacturing Support
- Facility Support
- Quality Metrics
Remediation Services
Regulatory Compliance Associates has a proven remediation services approach to managing FDA Warning Letters, Consent Decrees, Remediation and other serious regulatory situations. Our pharma consultants know how to partner with executive, legal, and communication teams. Each RCA pharma consulting Expert will develop a response that will be accepted by the regulatory agency and be realistic to execute.
Regulatory Compliance Associates pharma regulatory consultants will develop a comprehensive proof book of documented evidence demonstrating the corrective action taken to remediate non-compliant issues. In addition, each Regulatory Compliance Associates pharma consulting Expert understands compliance enforcement. We’ll prepare a comprehensive pharma consulting strategy to assist in your remediation efforts, drive continuous improvement, and maintain regulatory compliance with the regulations.
- Regulatory Action
- Regulatory Compliance
- Regulatory Enforcement
- Warning Letter
- 483 Observation
- Oversight Services
- Risk Management Plan
About Regulatory Compliance Associates
Regulatory Compliance Associates® (RCA) provides pharmaceutical consulting to the following industries for resolution of life science challenges:
- Life Sciences
- Pharmaceutical
- Biologic & Biotechnology
- Sterile compounding
- Medical device
- Lab Testing
We understand the complexities of running a life science business and possess areas of expertise that include every facet of R&D, operations, regulatory affairs, quality, and manufacturing. We are used to working on the front lines and thriving in the scrutiny of FDA, Health Canada, MHRA and globally-regulated companies.
As your partners, we can negotiate the potential minefield of regulatory compliance and regulatory due diligence with insight, hindsight, and the clear advantage of our unique expertise and experience.
- Founded in 2000
- Headquartered in Wisconsin (USA)
- Expertise backed by over 500 industry subject matter experts
- Acquired by Sotera Health in 2021
About Sotera Health
The name Sotera Health was inspired by Soteria, the Greek goddess of safety, and reflects the Company’s unwavering commitment to its mission, Safeguarding Global Health®.
Sotera Health Company, along with its three best-in-class businesses – Sterigenics®, Nordion® and Nelson Labs®, is a leading global provider of mission-critical end-to-end sterilization solutions and lab testing and advisory services for the healthcare industry. With a combined tenure across our businesses of nearly 200 years and our industry-recognized scientific and technological expertise, we help to ensure the safety of over 190 million patients and healthcare practitioners around the world every year.
We are a trusted partner to 5,800+ customers in over 50 countries, including 40 of the top 50 medical device companies and 9 of the top 10 pharmaceutical companies.
Commitment to Quality
Our Certificate of Registration demonstrates that our Quality Management System meets the requirements of ISO 9001:2015, an internationally recognized standard of quality.
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