4th GxP Cloud Compliance Summit – September 5-7

I am looking forward to speaking at the GxP Cloud Compliance Summit in Boston in September on Implementing a Lifecycle Risk Management Approach to the Cloud. I’ll be discussing some of my favorite topics:

  • Best practices to harness a life cycle risk management approach to protect product quality and patient data
  • What does a living risk assessment look like when key parts of your IT infrastructure is maintained by cloud service providers
  • How does Q9 R1 impact functional and usage assessments around cloud applications

I am looking forward to meeting and discussing some of the critical questions in our heady embrace of the cloud.

Cloud based GxP systems have shifted in the last few years from “Something I guess we should figure out” to “Well guess we have it now” to “Well that is all I seem to have now.” And where 5 years ago it seemed we were obsessed about the fine details of Open vs Closed systems and what cloud-based applications are, we are now looking at much more mature questions around a risk based strategy that evaluates and ensures appropriate controls around Data Integrity, Privacy, and Security. Through a risk-based approach, we drive activities such as auditing, change control, qualification/validation, and oversight.

I am looking forward to having this discussion with my peers and sharing best practices and experiences. It is only though this type of event that we can grow as a professional.

I hope to see you there.

Build Your Knowledge Base

Engaging with knowledge and Knowledge Management are critical parts of development. The ability to navigate the flood of available data to find accurate information is tied directly to individuals’ existing knowledge and their skills at distinguishing credible information from misleading content.

There is ample evidence that many individuals lack the ability to accurately judge their understanding or the quality and accuracy of their performance (i.e., calibration). To truly develop our knowledge, we need to be engaged in deliberative practice. But to truly calibrate requires feedback, guidance, and coaching that you may not have access to within our organizations. This requires effort and deliberate building of a system and processes.

Information can be found with little mental effort but without critical analysis of its legitimacy or validity, the ease of information can actually work against the development of deeper-processing strategies. It is really easy to go-online and get an answer, but unless learners put themselves in positions to struggle cognitively with an issue, and unless they have occasions to transform or reframe problems, their likelihood of progressing into competence is jeopardized.

The more learners forge principled knowledge in a professional domain, the greater their reported interest in and identity with that field. Therefore, without the active pursuit of knowledge, these individuals’ interest in professional development may wane and their progress toward expertise may stall. This is why I find professional societies so critical, and why I am always pushing people to step up.

My constant goal as a mentor is to help people do the following:

  • Refuse to be lulled into accepting a role as passive consumers of information, striving instead to be active producers of knowledge
  • Probe and critically analyze the information they encounter, rather
    than accepting quick, simple answers
  • Forge a meaningful interest in the profession and personal connections to members
    of professional communities, instead of relying on moment-by-moment stimulation and superficial relationships

If we are going to step up to the challenges ahead of us, to address the skill gaps we are seeing, we each need to be deliberate in how we develop and deliberate in how we build our organizations to support development.

Expert Intuition and Risk Management

Saturday Morning Breakfast Cereal source http://smbc-comics.com/comic/horrible

Risk management is a crucial aspect of any organization or project. However, it is often subject to human errors in subjective risk judgments. This is because most risk assessment methods rely on subjective inputs from experts. Without certain precautions, experts can make consistent errors in judgment about uncertainty and risk.

There are methods that can correct the systemic errors that people make, but very few organizations implement them. As a result, there is often an almost universal understatement of risk. We need to keep in mind a few rules about experience and expertise.

  • Experience is a nonrandom, nonscientific sample of events throughout our lifetime.
  • Experience is memory-based and we are very selective regarding what we choose to remember,
  • What we conclude from our experience can be full of logical errors
  • Unless we get reliable feedback on past decisions, there is no reason to believe our experience will tell us much.

No matter how much experience we accumulate, we seem to be very inconsistent in its application.

Experts have unconscious heuristics and biases that impact their judgment, some important ones include:

  • Misconceptions of chance: If you flip a coin six times, which result is more likely (H= heads, T= tails): HHHTTT or HTHTTH? They are both equal, but many people assume that because the first series looks “less random” than the second, it must be less likely. This is an example of representativeness bias. We appear to judge odds based on what we assume to be representative scenarios. Human beings easily confuse patterns and randomness.
  • The conjunction fallacy: We often see specific events as more likely than broader categories of events.
  • Irrational belief in small samples
  • Disregarding variance in small samples. Small samples have more random variance that large samples is considered less than it should be.
  • Insensitivity to prior probabilities: People tend to ignore the past and focus on new information when making subjective estimates.

This is all about overconfidence as an expert, which will consistently underestimate risks.

What are some ways to overcome this? I recommend the following be built into your risk management system.

  • Pretend you are in the future looking back at failure. Start with the assumption that a major disaster did happen and describe how it happened.
  • Look to risks from others. Gather a list of related failures, for example, regulatory agency observations, and think of risks in relation to those.
  • Include Everyone. Your organization has numerous experts on all sorts of specific risks. Make the effort to survey representatives of just about every job level.
  • Do peer reviews. Check assumptions by showing them to peers who are not immersed in the assessment.
  • Implement metrics for performance. The Brier score is a way to evaluate the result of predictions both by how often the team was right and by the probability the estimated for getting a correct answer.

Further Reading

Here are some sources that discuss the topic of human errors and subjective judgments in risk management:

State of the Organization

Even a criminal organization like McKinsey can be occasionally right. So ocasionally I’ll read their stuff for free, but any organization that pays them is basically just paying the mob and should be ashamed of themselves and stop it.

In the McKinsey report The State of Organizations 2023: Ten shifts transforming organizations (April 2023) the authors Patrick GuggenbergerDana MaorMichael Park, and Patrick Simon (all of which we can assume would probably be liable for some RICO charges if the Justice Department had any courage) lay out 10 key shifts:

  • Increasing speed, strengthening resilience
  • ‘True hybrid’: The new balance of in-person and remote work
  • Making way for applied AI
  • New rules of attraction, retention, and attrition
  • Closing the capability chasm
  • Walking the talent tightrope
  • Leadership that is self-aware and inspiring
  • Making meaningful progress on diversity, equity, and inclusion
  • Mental health: Investing in a portfolio of interventions
  • Efficiency reloaded

This closely aligns with the key challenges facing Quality.

A few thoughts.

Resiliency takes time and effort to build. I discussed how Business Continuity Planning is critical to an organization (and a regulatory requirement in Pharma). Building resilience deliberately, and leveraging it as part of change management, allows us to ensure our organizations can meet the challenges ahead of them and continue to transform. The conditions for building resilience and scaling up an organization’s change capacity are speed, learning, and integration. These three conditions are the principles of transformation. When organizations build around these first principles, they can enable the understanding, engagement, adoption, and endorsement needed for successful organizations. They can also simultaneously lay the foundation to achieve the speed, learning and integration needed to evolve.

I assume the majority of the quarter of respondents seeing their leaders as inspirational and fit-for-purpose were in fact the leaders in their respective organizations.

We shouldn’t talk about organization efficency without talking about effectiveness and excellence. I relly wish folks would widely adapt the principles of organizational excellence.

As usual, interesting information with some poor or impartial takes published by an organization that should be RICO’ed out of existence and join the Arthur Anderson graveyard of consulting companies.

You, Yes You! Speak at a Conference

The process of writing and speaking is a core part of the Quality profession. Only through these activities can we truly contemplate and learn from our accomplishments to propel us forward to new heights.

There are some great speaking opportunities for folks around the Boston area coming up:

BOSCON is November 6 and 7th and is looking for speakers. I’m a huge fan of this regional convention and strongly recommend it. Submissions are due August 15th, 2023.

The ASQ’s Quality Innovations Summit (formerly the Quality 4.0 Summit) is September 19–21 in Boston, MA with a theme of “Innovations and Future Trends for Excellence.” Submission deadline is June 9th, 2023, with more information here.

I’m quite happy to help coach potential new speakers, both in the development of your proposal and in your presentation.