When Generalists Are Better Than Specialists, and Vice Versa

It depends on how fast their field is changing.
— Read on hbr.org/2018/07/when-generalists-are-better-than-specialists-and-vice-versa

The specialist vs generalist approach is one I see a lot in quality. Some interesting information here.

Press Announcements > Statement by FDA Commissioner Scott Gottlieb, M.D., on formation of a new drug shortages task force and FDA’s efforts to advance long-term solutions to prevent shortages

FDA Commissioner Scott Gottlieb, M.D., on new drug shortages task force and work towards long-term solutions to prevent shortages
— Read on www.fda.gov/NewsEvents/Newsroom/PressAnnouncements/ucm613346.htm

Learning Culture

Over at the Harvard Business Review there is a great article on 4 Ways to Create a Learning Culture on Your Team. A learning culture is a quality culture, and enabling a learning culture should be a key element of a robust knowledge management system.

Frankly, this is an attribute that I think needs to be better reflected in the QBok, as it is a core trait of a successful quality leader. And supporting learning is a core element of any professional society.

ALCOA or ALCOA+

My colleague Michelle Eldridge recently shared this video for the differences between ALCOA and ALCOA+ from learnaboutgmp. It’s cute, it’s to the point, it makes a nice primer.

As I’ve mentioned before, the MHRA in it’s data integrity guidance did take a dig at ALCOA+:

The guidance refers to the acronym ALCOA rather than ‘ALCOA +’. ALCOA being Attributable, Legible, Contemporaneous, Original, and Accurate and the ‘+’ referring to Complete, Consistent, Enduring, and Available. ALCOA was historically regarded as defining the attributes of data quality that are suitable for regulatory purposes. The ‘+’has been subsequently added to emphasise the requirements. There is no difference in expectations regardless of which acronym is used since data governance measures should ensure that data is complete, consistent, enduring and available throughout the data lifecycle.

Two things should be drawn from this:

Data Integrity is a set of best practices that are still developing, so make sure you are pushing that development and not ignoring it. Much better to be pushing the boundaries of the “c” then end up being surprised.
I actually agree with the MHRA. Complete, consistent, enduring and available are really just subsets of the others. But, like they also say the acronym means little, just make sure you are doing it.

Data Integrity, it’s the new quality culture.

Master and Transactional Data Management

Mylan’s 483 observation states that changes were being made to a LIMS system outside of the site’s change control process.

This should obviously be read in light of data integrity requirements. And it looks like in this case there was no way to produce a list of changes, which is a big audit trail no-no.

It’s also an area where I’ve seen a lot of folks make miss-steps, and frankly, I’m not sure I’ve always got it right.

There is a real tendency to look at the use of our enterprise systems and want all actions and approvals to happen within the system. This makes sense, we want to reduce our touch points, but there are some important items to consider before moving ahead with that approach.

Changes control is about assessing, handling and releasing the change. Most importantly it is in light the validated and regulatory impact. It serves disposition. As such, it is a good thing to streamline our changes into one system. To ensure every change gets assessed equally, and then gets the right level of handling it needs, and has a proper release.

Allowing a computer system to balkanize your changes, in the end, doesn’t really simplify. And in this day of master data management, of heavily aligned and talking systems, to be nimble requires us to know with a high degree of certainty that when we apply a change we are applying it thoroughly.

The day of separated computer systems is long over. It is important that our change management system takes that into account and offers single-stop shopping.