Professional Documents
Culture Documents
Reg Affairs Brief
Reg Affairs Brief
in Massachusetts
2017
MassBioEd engages teachers, inspires students, and guides the life sciences workforce. Our
BioTeach program supports Massachusetts teachers as they work to engage students
through lab-centered, inquiry-based learning. Our Job Trends initiative identifies
workforce needs and illuminates the pathway from the classroom to careers in the life
sciences.
The Regulatory Affairs brief is a part of MassBioEd’s ongoing Digest of Biotech Jobs Trends
in Massachusetts, which also includes Quarterly Reports, One-off Briefs, a Medical Device
Snapshot, and an annual Job Trends Forecast. The Briefs present basic data and analysis on
particular aspects of biopharma industry job trends. The initial 2015 Briefs are focused
upon entry level position job trends in the biopharmaceutical industry.
The objectives in publishing the Briefs is to provide basic information about job listings
trends, skills required of candidates, prevalence of degree requirements for high trending
occupations. The Annual Job Trends Forecast is intended to provide greater insight based on
additional study in these areas.
Acknowledgements
The analysis found in the 3-Month Report was conducted by Mark Bruso, Manager of
Workforce Research, under the direction of MassBioEd Foundation Executive Director,
Peter Abair. Erica Dickinson, Product Support Manager at Burning Glass provided able
assistance to the MassBioEd research team in effectively using data from Burning Glass
Technologies. MassBio, the industry council serving the biopharmaceutical community of
the Massachusetts region, provided support for this series and MassBioEd’s ongoing job
trends initiative. Many thanks to Stephen Amato, Joni Beshansky, Lynn Squillace, Michael
Drues, Paul Beninger, and many others for their guidance on training and education within
the regulatory profession.
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Regulatory Affairs Brief MassBioEd
Introduction
Among the issues raised in our survey of industry professionals ahead of our annual Job
Trends Forecast in May 2016, the competition for experienced workers in the Regulatory
and Compliance space ranked among the most pressing. In the survey, which respondents
from companies representing nearly 10,000 workers in the state replied, 20 percent stated
that “regulatory,” along with “research” and “process/product development” were the most
difficult-to-fill. 78% responded that it is more difficult now, compared to three years ago, to
hire qualified talent, regardless of experience level or functional area. This, along with the
fact that over 93% of respondents in the same survey stated that job openings for
experienced workers were more difficult to fill than entry level, reveal that employers face
increased challenges in finding qualified candidates.
The goal of this Brief is to place a spotlight on these job areas of concern within the
industry, as they are the most likely areas to experience staffing problems in the near
future. Using labor market data gleaned using Burning Glass’ Labor Insight program, along
with input from industry professionals, we intend to present an overview of the current
state of the labor market in these job areas, highlight problematic areas, and present
current and proposed methods of alleviating the hiring pressures experienced today.
Executive Summary
The Regulatory Affairs field within the biopharma industry is a critical area for any
company developing products toward commercialization. Securing qualified workers for
the array of positions within the field is a central task for human resource departments in
biopharma companies.
As the biopharma industry in Massachusetts has grown and matured, with more
companies at later stages of product development, the need for professionals with
regulatory skills and experience has increased substantially,
Between 2012 and 2015, job listings for regulatory affairs positions increased by
65% in Massachusetts,
90% of professionals in regulatory affairs begin in positions outside of regulatory
affairs,
Larger companies depend on developing talent for regulatory affairs positions from
within their company,
Smaller companies externally recruit talent for initial regulatory affairs hires,
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Regulatory Affairs Brief MassBioEd
The competition for more senior level regulatory professionals places a strain on
hiring, especially for smaller companies, which can result in a slower pace for
regulatory submissions and product development,
Training within companies for regulatory positions is largely driven by the product
centric focus of particular companies, making the development of pertinent external
training problematic,
A limited number of universities offer programming in regulatory affairs, but at the
graduate or graduate certificate level only,
Graduate programs in regulatory affairs are seen as skill enhancements to advance
incumbent regulatory affairs professionals, rather than preparatory programs for
new entries to the regulatory field,
Greater availability of educational programs introducing experienced non-
regulatory workers to concepts fundamental to the regulatory field would enable
companies to externalize basic training for workers they are developing for
regulatory positions.
While Regulatory and Compliance duties often overlap and are conflated, it is crucial to
first make a distinction between their essential functions. In their basic element,
Regulatory professionals are responsible for reporting to regulatory agencies,
communicating that activities taking place within their companies are within the bounds of
rules and regulations set forth by the FDA. Oftentimes, this means they communicate to
regulatory agencies regarding the technologies and techniques used and therapies being
developed within their organizations. Compliance professionals are more concerned with
accountability, meaning they are much more inward-facing, making sure that all activities
completed by their employees are in strict accordance with the rules and regulations in
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Regulatory Affairs Brief MassBioEd
place. It is easy to see why these roles are often grouped together, as they perform
intersecting functions.
For the purpose of this report, we seek to look at all occupations within biopharma whose
main duties place them either in a regulatory or compliance role, henceforth considered
“Regulatory Affairs.” Regulatory Affairs Specialists, Compliance Officers, Compliance
Managers, and Documentation Control Specialists are all occupations whose core duties are
devoted to regulatory functions at biopharma companies. A number of Technical Writers
find themselves in these roles. Not wanting to limit our scope to obvious occupations, we
scoured real-time labor market data to get a sense of other occupations in which a
contribution to regulatory or compliance activities is central to their position1. By doing
this, we believe we have isolated occupations outside the main basket of occupations that
are devoted to regulatory-related work. Some job openings tagged as Administration
Manager, Medical Director, and Project Manager were in actuality, regulatory positions.
This helps us in defining the space that is otherwise nebulous in structure.
The 2016 edition collected responses from 3,358 individuals in the profession,
approximately 2,500 of which originated from within the United States. The survey
provides a comprehensive overview of the profession, looking at educational and
professional backgrounds, compensation, work setting, time allocation, and job duties.
Survey respondents were asked to classify themselves into any professional class within
Regulatory Affairs. The most common self-selected job levels were Manager (24%),
Specialist (24%), Director (19%), Associate (8%) and Vice President (5%). A rough
hierarchy begins at Specialist and Associate, which are approximately equivalent in
earnings and duties, to Manager, Director, and finally Vice President. Using these self-
1
Using Burning Glass Technologies’ Labor Insight tool, we simply examined all job listings thus far in 2016 with the
keywords “regulatory” or “compliance” within their title, in occupational fields not listed above, in lieu of a keyword
search, which would have returned numerous false-positives (i.e. regulatory or compliance is mentioned in the duties of a
job listing, but it is not the focal point of the job).
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Regulatory Affairs Brief MassBioEd
assigned job levels, we can tease out differences in wages, duties, time allocation, and work
experience between the four main groups.
Time use was divvied up into five broad categories: business-related, regulatory strategy,
preapproval/approval, post-approval, and training/education. Furthermore, each job level
time allocation was dissected by workplace setting, which showed “no significant
variations by region.” What follows are the differences in time allocation by job level within
the industry in 2016.
The sole divergence this past year in time allocation occurs between Specialist/Associates
and Vice Presidents, where the former spends far more time in regulatory strategy in lieu
of business-related projects.
Major shifts in time allocation have occurred since 2012. Across-the-board increases in
emphasis on the regulatory strategy category occurred simultaneous to a drop in time
allotted to pre-approval activities, with much of the drop-off appearing between 2014 and
2016. This re-ordering of priorities may be due, in part, to “a more strategic approach to
the work undertaken by regulatory staff and a greater integration of regulatory strategy,
intelligence and operations into regulatory lifecycle management.i”
Hiring Trends
Limited Entry Level Positions in Regulatory Affairs
As noted above, hiring managers in the industry have listed regulatory positions among the
most difficult to fill. Unlike many other functional areas, such as Research or Quality, there
isn’t a direct pipeline from higher education into regulatory roles within the industry.
Typically, companies that do not contract out their regulatory duties to outside firms
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Regulatory Affairs Brief MassBioEd
The number of openings available to those lacking at least a four-year degree is low.
Excluding Document Control Specialists from the aggregate, approximately 1-2% of
openings allow for
applicants to possess Occupation Assoc. Bach. Grad
less than a bachelor’s Regulatory Affairs Specialist 0% 91% 9%
degree. For Document Compliance Officers 0% 96% 4%
Control Specialists, Compliance Manager 2% 81% 17%
however, 4-in-10 Documentation Control
42% 58% 0%
listings required less Manager/Specialist
Technical Writer 3% 93% 5%
than a bachelor’s
Miscellaneous Positions 2% 81% 17%
degree. Generally
speaking, the data reinforces the commonly held notion that entry level opportunities in
these occupations are difficult to come by.
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Regulatory Affairs Brief MassBioEd
Historically, Regulatory Affairs professionals were only necessary once a company had a
therapy in the clinical stages of development. But over the course of decades, the
regulatory environment has evolved to the point where those same professionals are
employed by companies at all phases along the discovery pipeline. As the size of research
Employment Growth, operations in the state has grown by approximately 30% in
Regulatory Affairs the past decade – from 24,565 employees in 2007 to 31,469 in
positions, 2012-15 2015 – the need for Regulatory Affairs professionals has
65% expanded as well. From 2012 to 2015, the number of
Regulatory Affairs Specialists and Compliance Officers (non-
management) employed by biopharma firms in the state has grown from 624 to 1,027 –a
compound annual growth rate of over 18% resulting in total growth over the three year
period of 65%. Curiously, over the same period in question the inflation-adjusted annual
median salary for those workers decreased slightly, from about $84,500 in 2012 to just
under $84,100 in 2015 – a decrease of 0.4%.
Standard economic models state that if demand for workers increases, as it has for those
two occupations since 2012, that a corresponding wage increase will occur if the supply of
workers does not keep pace. Even as employment in Regulatory Affairs Specialist and
Compliance Officer positions increased by almost two-thirds in the span of just three years,
companies did not have to raise
wages to attract workers. On the 2012 2013 2014 2015
$140,000
contrary, real wages declined by $120,000
0.4%. Wages at the lower end of $100,000
the spectrum – the 10th and 25th $80,000
percentiles – each witnessed an $60,000
This confirms the input received from our industry partners, gathered through our Skills
Advisory Group, which emphasized that finding willing workers for lower-level regulatory
affairs positions is not the concern – the problem presents itself when seeking to fill
positions with highly experienced workers. Larger companies are able to hire from quality
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Regulatory Affairs Brief MassBioEd
assurance, validation, clinical research, and drug development roles which operate within
the bounds of the regulatory environment. Companies that are seeking experienced
regulatory professionals – namely smaller companies looking to grow their nascent
regulatory apparatus – cannot look in-house. Since they must look towards other
companies with established regulatory affairs professionals they must pay a wage
premium in order to secure their services, thus driving up pay growth at the upper ends of
the wage distribution.
In management roles, i.e. Compliance Managers, the real (adjusted for inflation) growth in
pay between 2012 and 2015 was 27%, growing at a rate of over 8% per annum. These
workers experienced growth in compensation like their
Employment experienced counterparts in Regulatory Affairs Specialist and
Growth, Compliance Compliance Officer positions. Employment totals within the
Managers, 2012-15
occupational group in which Compliance Managers reside – the
111% SOC code Managers, All Other, grew 111% from 116 workers in
2012 to 245 workers in 2015. Compliance Managers, Regulatory
Affairs Specialists, and Compliance Officers were all forecasted to grow 6.5% by 2018 within
the biopharma industry; this far exceeded the rate of growth projected for these
occupations by the state for all industries through 2022, which stood at approximately 3%.
Isolating these three key regulatory/compliance positions from the rest of the regulatory
sphere reveals a noteworthy trend. Since 2013, the percentage of total postings for
candidates with 0 – 2 years’ experience – “entry level” – shrunk every year. In 2013, 15%
were available to entry level workers, in the ensuing three years it declined to 12%, 10%,
and to 6% in the first half of 2016. This is a shade below the experience requirements for
all regulatory positions. This is partly driven by what we know about where companies
look for entry-level talent – within – which may have the effect of obscuring how many
entry level openings there are as companies do not post them externally. In turn, it is easy
to see why experienced openings dominate job boards – when companies look to fill those
positions they have no choice but to look at workers from outside the company.
In-Demand Skills
Each of the occupational groups within the regulatory/compliance sphere exhibits their
own unique skill profiles. Below are the top ten in-demand technical skills by occupational
group in the past 12 months.
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Regulatory Affairs Brief MassBioEd
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Regulatory Affairs Brief MassBioEd
In Technical Writers, a relatively high concentration of in-demand skills signifies that open
positions within that occupation group are much more similar to each other than open
positions within other groups, meaning there is likely little variation throughout the
industry in what duties and tasks are requested of these workers. The opposite is so for the
grouping of miscellaneous positions.
The most requested baseline skills - broad groupings of underlying and foundational soft
skills - among biotech-related regulatory positions
Top Baseline Skills – Regulatory
in the past 12 months are shown at right. All of Positions, Past 12 Months
these soft skills were in far more demand in these Communication 58%
positions when compared with all statewide Writing 50%
positions during the same period of time – Writing Research 33%
and Research were more than twice as common, Collaboration 29%
while the other skills ranged from 28% more Organizational Skills 26%
concentrated (Problem Solving) to 80% more Detail-Oriented 24%
Planning 23%
(Detail-Oriented).
Above - Cutting Edge Information: “Regulatory Affairs Talent Gap is a Problem for Small Pharma”
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Regulatory Affairs Brief MassBioEd
This fact makes plain the struggles small companies face in ramping up regulatory
functions – many times they lack the infrastructure, specialized knowledge, or networks
required to take advantage of the expedition of submissions made possible by new FDA
rules and regulations. While smaller departments mean that regulatory professionals at
smaller-to-midsize companies are responsible for a wide swath of duties (operations,
strategy, etc.) and are by necessity more nimble, it does not result in faster submissions.
Particular to the biopharma industry is the duration of time it takes to fill a vacant position.
According to Randstad, the industry standard for filling any open position in 2016 was 105
days, or approximately 3 ½ monthsiii. This stands in great
Time To Fill Open contrast to the economy-wide lag between a job opening and a
Positions worker accepting an offer, which in September 2016 was 28
Biopharma All days, or approximately one monthiv. While the differences
105 days 28 days between large and small biopharma firms is not known at this
time, at the macro level smaller firms are able to fill vacant positions at a much quicker rate
than larger ones, reflecting in part a greater relative opportunity cost in letting a position
sit unfilled for a long time – which some estimate as a loss of $500 for every day a position
is unfilledv. Therefore small companies have a clear incentive to fill any position, and
regulatory positions specifically, as soon as they become available or necessary.
Once again, the 2016 Scope of Practice and Compensation Report for the Regulatory
Profession gives us a good idea of the prior experiences of regulatory professionals – both
in terms of where they worked and how long they worked there before entering the
profession.
Anecdotally, only large companies with therapies in multiple stages of development are
typically able to hire entry/associate level Regulatory Affairs or Compliance Specialists from
within. According to the 2016 Scope, approximately 90% of all regulatory professionals got
their start in other functional areas. The table below identifies the top areas from which
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Regulatory Affairs Brief MassBioEd
typically had 5-8 years of non-regulatory experience on their resumes 5-8 Years
before transferring into regulatory affairs. This confirms the widely held Experience
belief that entry into the profession remains difficult, and that most – if not Prior to 1st
Regulatory
all – regulatory professionals must build up years of related experiences
Position
before they are able to be considered for hire.
Back in 2011, RAPS reported the “feeder” areas for biopharma regulatory positions in
comaprison to medical devices and found that biopharma finds their new talent from R&D
and Clinical Research at similar rates, Quality and Engineering much less, and
Pharmacology and Drug Development at a much higher rate.
In hiring workers away from functional areas that may interface with regulatory on a
consistent basis, firms must train and develop these workers internally, as there are no
current academic programs at the undergraduate level that provide a breadth of regulatory
preparatory training for students or incumbent workers. Smaller-sized companies are
more apt to look towards outsourcing regulatory work to a third-party firm like a
contractor, CRO, or Contingent Resource Provider that can flexibly respond to ebbs and
flows in workload, e.g. submissions and filingsvi. These third-party firms provide a way for
inexperienced recent graduates from graduate programs in regulatory affairs to gain entry
into the profession on a non-permanent, contingent basis.
The key takeaway is that the dynamics of hiring large v. small firm is that this muddles the
pathways picture, as one would anticipate large disparities between the rates of entry level
openings at small- and large-sized companies. Two other core occupations – Document
Control Specialists and Technical Writers – seem to be islands unto themselves wherein
positions within that occupational group tend to be promoted within the occupational
group (i.e. a Document Specialist becomes a Document Specialist Lead). It becomes clear
that of the remaining core regulatory/compliance occupations that Regulatory Affairs
Specialists and Compliance Officer/Analysts are the gateway into the profession, each with
about one-fourth of their openings at the entry level since 2013 – level with the industry-
wide rate. Job titles ending with Specialist, Associate, and Officer come up frequently when
looking at this segment of job listings, eventually leading to job titles with Senior, Manager,
and Director affixed to it.
The following is an illustration of the hierarchy of titles within the regulatory space. It is
derived both from historical and real-time job market data, and is colored by commentary
gleaned for our industry insiders that reside on our Skills Advisory Group. Excluded from
this group are Technical Writers, which typically have I, II, etc. affixed to the end of their
title to signify the level of experience and responsibilities of the individual in the position.
The titles come from real job listings posted online in the past two years, and while this
should not be construed as the case at every company, it is a very close approximation of
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Regulatory Affairs Brief MassBioEd
the pathway into higher-level positions within regulatory and compliance departments at
biotechnology and pharmaceutical companies in the Commonwealth.
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Regulatory Affairs Brief MassBioEd
65% increase in employment totals, signifies that the recent influx of graduates of these
programs is meeting the needs for eligible workers to fill these open positions.
Generally, there are two tracks available – a full Master’s degree or a Graduate Certificate.
The Master’s programs are anywhere from 30 credits (10 courses) in length to 45 – taking
between two to three years to complete. In conversations with academics within these
programs, the importance of practical experience was highlighted. These come in the form
of practicums, case studies, internships/co-ops, etc. The academic programs are informed
of the need of these hands-on learning experiences through connections with industry, as
many programs are staffed with adjunct faculty members who simultaneously work full-
time in area biotech or pharmaceutical companies. Companies are reluctant to fill entry-
level positions within regulatory with candidates lacking industry experience, which
presents a catch-22 for workers outside the industry looking to gain entry into regulatory
roles.
Experiential learning, such as internships, were not required in any of the programs
surveyed, due in large part to the student body demographics – many were working
professionals unable to make the requisite time commitment. Representatives from the
academic programs in Massachusetts emphasized the availability of experiential learning
for those with the time and ability to complete them.
This enhanced emphasis placed upon pedagogy involving applied learning in lieu of a
textbook-centered approach reflects the very nature of the regulatory field. While it is
relatively straightforward to look up FDA regulations, it is another to apply and adapt the
knowledge to real-life examples, or to be embedded within a company as it develops and
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Regulatory Affairs Brief MassBioEd
employs regulatory strategy to its development pipeline. The unified concern with
providing students with these experiences shapes the regulatory educational landscape
within the Commonwealth.
More accelerated academic programs are available as well. All three schools offered
certificate tracks that students complete in approximately one-fourth of the time of the
Master’s programs. Incumbent workers see these programs as a vehicle for promotion, as
opposed to a program needed to gain entry into the profession. The certificate programs at
both Northeastern and Regis require the completion of four courses – three core classes
plus one elective at Regis, and two core classes and two electives at Northeastern.
There is no shortage of workers within the industry willing to transition into junior-level
regulatory affairs roles. But owing to its unique responsibilities, knowledge base, and
integral function along the pathway to commercialization of therapies, distinctive hurdles
obstruct the development of regulatory professionals. The onboarding of new hires in the
regulatory sphere takes a considerable amount of time before they are able to effectively
manage their job’s responsibilities. Effective training can take anywhere from six to twelve
months, with a considerable tail – meaning workers must continually learn on the job to
adapt to changes in regulations or to learn the numerous nuances of the job. Making this all
the more difficult is the fact that there is hardly any uniformity in regulatory positions –
there are not insignificant differences in tasks and duties depending on the therapeutic
area, stage, or countries/markets a company is doing business in. This, in turn, makes it
difficult, through an industry-academic collaboration to streamline training, education, and
professional development.
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Regulatory Affairs Brief MassBioEd
A large influx in graduate-level educated workers in regulatory affairs programs in the past
decade has presented a nascent issue – an increase in job candidates with educational
qualifications simultaneous to a decrease in job postings for entry level regulatory affairs
openings. While there has been an increase of those entering straight into regulatory affairs
from outside the industry – most likely graduates of regulatory affairs academic programs -
in the past half-decade, there is still room for the industry and academia to raise the
marketability of recent graduates for junior-level regulatory affairs openings.
Larger companies will continue to develop talent in non-regulatory areas for regulatory
positions. The availability for additional external training resources for these candidates,
introducing fundamental concepts across the regulatory environment, should be helpful
transitioning incumbent workers into new roles in regulatory affairs
Companies and their employees in regulatory positions should explore existing graduate
programs as valuable opportunities to enhance and refine regulatory skills toward
attaining higher levels or responsibilities and performance.
The availability of training for particular, stackable skills (as seen on Page 8, above), such
as technical writing, GMP, GCP, GLP, and FMEA, can be expanded by introducing more of
these training program areas to the state’s Workforce Training Express program, which is
easily navigable and accessible to employers looking to enhance the skills of employees in
early- to mid-transition into regulatory roles.
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Appendix
MassBioEd utilizes Burning Glass Labor Insight for the bulk of its real-time online job
listing data. Per the description on Burning Glass’ website, their Labor Insight software,
“collects millions of online job postings [everyday] from close to 40,000 sources and
applies [their] patented technology to mine and code detailed data from each posting
describing the specific skills, education, experience, and work activities required for the job
– going well beyond the occupation and industry codes offered in other sources.”
All job listings data is sourced from Burning Glass Labor Insight, unless otherwise noted.
Employment numbers were derived from the Department of Labor, Bureau of Labor
Statistics’ Quarterly Census of Employment and Wages (QCEW), a survey of employers that
covers 98 percent of all workers in the country.
Staffing patterns, or the count of individual occupations by industry in the state, were
found by using Department of Labor, Bureau of Labor Statistics’ Occupation Employment
Statistics (OES) Research Estimates. These are derived from sample surveys and thus are
approximations subject to sampling error, as well as non-sampling errors by respondents
filling out the surveys.
The Regulatory Affairs Professional Society (raps.org) was an invaluable resource for scope
of practice data, and a range of other workplace trends within regulatory affairs. Data
regarding time allocation, previous employment, education, etc. were sourced from their
website and reports.
i
RAPS SoP 2016, pg. 7, http://stage.raps.org/twoColDetail.aspx?id=10555
ii
Cutting Edge Information, https://www.cuttingedgeinfo.com/2012/regulatory-affairs-talent-gap-is-a-problem-
for-small-pharma/
iii
Randstad Life Sciences/Pharma Workplace Trends Guide,
https://www.randstadusa.com/workforce360/recruitment-retention/life-sciences/
iv
Nov 2016 DHI-Hiring Indicators Charts, http://dhihiringindicators.com/
v
CEB and National Mean Vacancy Report (via Randstad)
vi
Thayer J, Falchuk J. “Transforming Temporary Resourcing into Strategic Resourcing.” Regulatory Focus. March
2014. Regulatory Affairs Professionals Society. Page 2
vii
SoP 2016
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