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How well has the pharma industry implemented regulations?

February 25th, 2017 by

This has always been a question people ask.  As a consultant i see a slice of the industry that interacts and works with me, so I have my opinions.  However, a company that employs me may not represent the average company.  So a colleague of mine, Peiyi Ko, and I decided to conduct a survey asking these questions.  we used Survey Gizmo as the survey tool and LinkedIn Groups as the interface.  These 40 questions were posed and because of the interesting answers we got, we are publishing them in two parts.  This post has the first part published in Pharmaceuticalonline.  In this part, we examine the implementation of various guidances and regulations.  The second will feature how ell they have impacted the company Quality Management System.

The second part will be published in a couple of months.  Bookmark my website so you will see it when the next is posted.

Happy reading

EMA issues new annexes and guidances

June 21st, 2016 by

During the last few months the European Medicines Agency (EMA) has issued a series of revisions to Annexes and Guidances

Specifically, the following

Annex 15 – Validation and Qualification

Annex 16 – Certification by a Qualified Person and Batch  Release

Annex 17 – Real Time Release Testing

Guidance to Industry: Guideline on process validation for the manufacture of biotechnology-derived active substances and data to be provided in the regulatory submission

To understand what they contain and what it means, I refer you to an article I wrote recently in

Pharmaceutical on line  and

Bioprocess on line

 

Single use components in biopharm – a regulatory perspective

February 4th, 2016 by

Single use components have been used in operations for decades but their use is expanding rapidly.  The agencies are taking a closer look.  Just published an interesting article on the topic in BioPharmaceutical International . Enjoy the read

Managing a CMO can be tricky

June 15th, 2015 by

Much has been talked about choosing a CMO, developing contracts and establishing a quality agreement.  But that is not all.  It involves the establishment of operations and the development of a relationship and developing trust between both parties.  I have just written and had published an article on this topic.  It’s in the May issue of Pharmaceutical Outsourcing.  the article is entitled “Maintaining the relationship with a CMO”.  The link to the article is here

QA and Manufacturing should be working on the same team

May 15th, 2015 by

During the last couple of months I have been working with a company that is undergoing a transition as products move through their pipeline – quite a radical shift in strategy.  Over the years, their Quality Management System (QMS) has evolved.  But as with all evolution, the small incremental changes that occur might lead along a path to an improved system or an evolutionary dead end.  With this radical shift, they invited me to come in and assess what they are doing right, what they are doing badly and what, perhaps, they are not doing.

So the first step is a gap analysis which entails reading documents and records and interviewing people.  Fortunately, management is highly supportive of this exercise so I got extreme cooperation from all parties.  Documents (SOPs policies, quality manuals and quality plans) were supplied to illustrate the systems.  In addition, I requested records which were supplied readily.  These included deviation investigations, CAPAs and change controls, to name just three types.  While I cannot look at all, I asked that typical examples be shown.  I want to see the average type record – neither the best nor the worst.  During discussions, which ranged from 1 on 1s to small groups, people felt comfortable describing what they liked and what they found frustrating.  The interesting feature I noted was that the same frustrations were felt universally across the organization.  It did not matter whether it was QA, QC, engineering or production: all felt the same.

The analysis revealed that the three systems described were all weak.  While the company used an electronic system to track and manage the system, the end result, the reports, did not meet the requirements of either the practitioners or me.  That is, they were neither well written nor clear.  They lacked the clear logic to explain what had happened and why for deviations, how the CAPAs linked back to the deviations and the rationale for the change in the change controls.  And why was this?  In a way the people involved had treated their systems as hurdles that had to be overcome to move to the next step, rather than the tools they should be.  With the e-system, it appeared the goal was to move the document from their inbox to next person’s inbox.

They had lost sight that an investigation’s goal should be to:

  • Uncover what went wrong, identifying the factors that contributed to the issue (they got some of the factors but not all).
  • Recover the material or data (they were good at that)
  • Prevent it from happening again (not good at that)
  • Prevent similar things from happening elsewhere (almost totally absent)

In this case, the e-system had done a grave disservice to the company.  It had taken the thinking out of the process; it had subverted the process from serving the operations to a system that had to be served.  It had also driven behavior into short term thinking versus long term.  They had cultivated a fire-fighting mentality.

The exact same thing had happened in the change control system.  There was not a critical evaluation of any of the changes.  The changes were made to save materials rather than build a rugged process or system.

To combat this systemic problem (and all three areas were linked), we embarked on a training session.  It included three elements

  1. Back to basics of the three systems – explaining what the desired state was and how to get there.
  2. Teamworks which had real life examples of challenges using some of the principles and skills learnt.
  3. Practical examples from their company. I selected examples of deviations/investigations and CAPAs and change controls and worked through with the group some examples. After I gave my read on the situations, I let them loose to try out the new skills themselves.

During the second round, there was a breakthrough by one of the staff members.  Suddenly, the light bulb went off.  I have never seen such an excited person in all my years training.  I am going back in a couple of weeks to see how things are going.  I am quite optimistic.  I will keep you posted.