The Future of Quality Control

While most of the advanced technologies already exist today, few pharmaceutical companies have yet to see any significant benefits. On one side, quality leaders struggle to define a clear business case for the technological changes, and thus fail to bring to management attention to the significant impact potential associated with lab digitization or automation. On the other side, companies often neglect the development of a clear long-term lab evolution strategy and blueprint, which can lead to some costly investments with unclear benefits.
— Read on https://www.pharmamanufacturing.com/articles/2018/the-future-of-quality-control/

Good overview of some current trends in QC labs.

How we tell our story

“If it Isn’t Written Down, then it Didn’t Happen” is a guiding principle of the quality profession.

There are four major types of writing in quality: instructional, informational, persuasive and transactional. When evaluated against the three major document types instructional is a functional document, informational is a report and transactional is a record. This is not to say that all transactional business writing should be considered a record, the traditional argument against emails in quality systems for example.

It is important to understand these differences as they require differences in writing style, format and grammar. An SOP (instructional/functional) is very different that an informational/report). When building your writing competencies it is important to remember these are different (with a common foundation).

We utilize reports in our quality systems (and everywhere else) to act, to communicate information, to capture work completed, to record incidents, to finalize projects and recommendations, and to act as an archive. A well written report allows the reader to easily grasp the content and, if applicable, make informed decision. Report writing is a cornerstone of a CAPA system (from incident identification to root cause through CAPA completion and effectiveness review), validation, risk management and so much more.

In short, reports are our stories, they form the narrative. And how we tell that narrative determines how we think of an issue, and how we will continue to thing of it in the future.

We tend to mix and match two modes in our report writing — Story thought and system:

  • Story thought emphasizes subjective human experience, the primacy of individual actors, narrative and social ordering, messiness, edge cases, content, and above all meaning.
  • System thought emphasizes 3rd-person descriptions of phenomena from a neutral perspective, the interchangeability of actors and details, categorical or logical ordering, measurements, flow, form, and above all coherence.

We tend to lean more heavily on system thought in quality,the roots of the discipline and the configuration of our organizations make us predisposed to the system thought mode. This means that over time, best practices accumulate that favor system thought, and many of our our partners (regulatory agencies, standard setting bodies, etc) favor the measurable and the reducible. However, by favoring the system thought mode we are at jeopardy of missing how human beings function in our organizations and how our organizations need to deal with society. And we make mistakes. Me make bad decisions. We fail to deal with the truly complicated problems.

It is time to learn how to utilize story though more in quality.

PDF fillable forms

On my.ASQ.org the following question was asked “The Device History Record is a form in fillable PDF format. Worker opens the PDF from a secure source within the local network. The only thing they can change is checkmark Pass/Fail, Yes/No and enter serial numbers in the allowed fields. Then after the assembly process is done for each procedure, the worker prints the DHR, signs and dates it by hand, to verify the accuracy of data entered. No re-printing or saving PDF’s is allowed.”

This comes up a lot. This is really a simple version of a hybrid situation, where both electronic and paper versions of the record exists.

Turning to the PIC/S draft guidance we find on page 44 of 52 “Each element of the hybrid system should be qualified and controlled in accordance with the guidance relating to manual and computerised systems”

Here would be my recommendation (and its one tried and tested).

The pdf form needs to be under the same document management system and controls as any other form. Ideally the exact same system. This provides version control and change management to the form. It also allows users to know they have the current version at all times.

Once it is printed, the paper version is the record. It has a wet-signature and it under all the same predicate record requirements. This record gets archived appropriately.

Where I have seen companies get messed up here is when the pdf exists in a separate, usually poorly controlled system from the rest of your document management. Situations like this should really be evaluated from the document management perspective and not the computer systems life-cycle perspective. But its all data integrity.

Q13 and Q14 path forward

Final concept papers have been published for the next two ICH quality guidelines. In both cases we can hope to see drafts in the first half of 2020. Both guidelines are intended to supplement the existing documents ICH Q8 – ICH Q12, reinforcing the principles of a risk based quality by design (QbD).

ICH Q13: Continuous Manufacturing of Drug Substances and Drug Products

Final concept paper and business plan. This new quality guideline will:

  • capture key technical and regulatory considerations including certain CGMP elements specific to continuous manufacturing
  • allow drug manufacturers to employ flexible approaches to develop, implement, or integrate continuous manufacturing for the manufacture of small molecules and therapeutic proteins for new and existing products
  • provide guidance to industry and regulatory agencies regarding regulatory expectations on the development, implementation, and assessment of continuous manufacturing technologies.

ICH Q2/Q14: Analytical Procedure Development

Concept paper and business plan. Q14 will bring the QbD principles to analytical development.

In the course of the preparation of this new guideline, ICH Q2 (Validation of Analytical Procedures) will also be revised. It will be adapted to the state of the art to include modern analytical methods in the future..

It’s stated that the Expert Working Group (EWG) will evaluate combining Q2 and Q14 into one document. Here’s hoping.

Warren bill would get feds into generic drug manufacturing – POLITICO

Warren is one of several senators eyeing White House runs who have introduced bills targeting the pharmaceutical industry. Just last week, Sens. Jeff Merkley (D-Ore.), Kamala Harris (D-Calif.) and Amy Klobuchar (D.-Minn.) introduced the CURE High Drug Prices Act, which would allow the federal government to block price increases on certain drugs. Merkley put forward separate legislation, the Low Drug Prices Act, weeks earlier. And Sen. Bernie Sanders (I-Vt.) introduced his own bill, the Prescription Drug Price Relief Act, in November.

The flurry of bills suggests that the powerful pharmaceutical industry will be a major populist target during the Democratic presidential primary and possibly the general election, as millions of Americans struggle with rising health care costs.
— Read on www.politico.com/story/2018/12/17/elizabeth-warren-bill-drug-manufacturing-prices-1067916

An Office of Drug Manufacturing. That could be interesting.