Design Lifecycle within PDCA – Planning

In the post “Review of Process/Procedure” I mentioned how the document draft and review cycle can be seen as an iterative design cycle. In this post I want to expand on the design lifecycle as a fundamental expression of PDCA that sits at the heart of all we do.

PDCA, a refresher

PDCA (and it’s variants) are a pretty tried and true model for process improvement. In the PDCA model a plan is structured in four steps: P (plan) D (do) C (check) A (act). The intention is create a structured cycle that allows the process to flow in accordance with the objectives to be achieved (P), execute what was planned (D), check whether the objectives were achieved with emphasis on the verification of what went right and what went wrong (C) and identify factors of success or failure to feed a new process of planning (A).

Conceptually, the organization will be a fast turning wheel of endlessly learning from mistakes and seeking to maximize processes in order to remain forever in pursuit of strategic objectives, endlessly searching for the maximum efficiency and effectiveness of the system.

PDCA cycle driving continuous improvement

Design Lifecycle

This design lifecycle just takes the PDCA spiral and spreads it across time. At the same time it breaks down a standard set of activities and recognizes the stage gates from moving between startup (or experiment) and continuous improvement.

Design Lifecycle

Identifying the Problem (Plan)

At it’s heart problem-solving requires understanding a set of requirements and building for success.

I always go back to the IEEE definition of “A requirement is a condition or capability needed by a user to solve a problem or achieve an objective; a condition or capability that must be met or possessed by a system or system component to satisfy a contract ,standard, specification , or other formally imposed document; a document representation of condition or capability “

A requirement can be explicitly stated, implicit, inherited or derived from other requirements.

The first place to look for requirements is the organization itself.

Understanding the needs of the organization

The cultural needs of the organization drives the whole problem-solving and requirement gathering activity and it starts by being clear on Strategy and understanding the goals and objectives and how these goals percolate to the different business processes that we are improving. This gives a good starting point to focus on what opportunities to be explored and what problems to be solved.

It is not uncommon in the problem-solving phase that the objectives/needs are not known, so we must work our way through figuring out what the initial need is. Go back to the fundamentals of understanding the business processes “as-is” and review existing regulations, standards, guidelines and other internal sources of requirements followed currently. This is the time to interview stakeholders and go the GEMBA.

We state the problem, and re-frame it. And now we can move on to Requirement Elicitation.

Identifying the Problem

Requirement Elicitation

Requirement Elicitation is the process of probing and facilitating the stakeholders to provide more clarity and granular details pertaining to the (usual) high-level requirement gathered so far. This is a discovery process, exploratory in nature, focusing on finding enough details so that a solution can be envisioned and developed. Elicitation is not an isolated activity, and has been happening throughout the process by all the discussion, interaction, analysis, verification and validation up to now.

You should be engaging with knowledge management throughout the cycle, but ensure there is specific engagement here.

It is a progressive process where the requirement clarity ushers in increments and may need multiple rounds of probing/discussions. As the new details are uncovered the requirements are further elaborated and detailed. There are a whole toolbox of elicitation techniques and like any engagement it is important to properly prepare.

Requirement Elicitation

Requirement Analysis

Requirement Analysis pertains to extracting the requirement out of the heaps of information acquired from various stakeholders and communicated and turned into documentation in a form that is easily understood by the stakeholders, including the project team. Here we are engaging in requirement refinement, modification, clarification, validation & finalization and engaging in extensive communication.

A requirement can be classified as:

We build for traceability here, so as we build and test solutions we can always trace back to the requirements.

Design the Solution

Building for the solution includes change management. Any solution focuses both on the technical, the organization and the people.

Ensure you leverage risk management.

Change Management Approach

The Place of Empathy

In this design process, we address and use empathy to acquire insight into users’ (stakeholders) needs and inform the design process and create a relevant solution. Using an approach informed by cognitive empathy, we apply different methods to build up that competence and insight, enabling us to prioritize the needs of the users and make the results of the process more desirable.

Psychological safety, reflexivity and sense-making inform our work.

Prepare for Startup

By engaging in Design Thinking we are ready for Startup. Moving through the three steps of:

We have created a plan to execute against. Startup, which can often be Experimentation, is it’s own, future, post.

2020 FDA 483s around change

The yearly database of 483s has been updated by the FDA. Lots will be written on themes as we end the year, so I decided to give a few of my immediate observations.

I find that over time what I focus in on changes, as my jobs evolve and change, and the interests I have shift. However, some things never change, so let us talk change.

Reference NumberShort DescriptionLong Description2020 Frequency2019 Frequency2018 Frequency
21 CFR 211.100(a)Changes to Procedures Not Reviewed, ApprovedChanges to written procedures are  not [drafted, reviewed and approved by the appropriate organizational unit] [reviewed and approved by the quality control unit].  Specifically, ***8139
21 CFR 211.160(a)Lab controls established, including changesThe establishment of [specifications] [standards] [sampling plans] [test procedures] [laboratory control mechanisms] including any changes thereto, are not [drafted by the appropriate organizational unit] [reviewed and approved by the quality control unit].  Specifically, ***41817
21 CFR 212.20(c)Adverse effects of changes madeYou did not demonstrate that any change does not adversely affect the [identity] [strength] [quality] [purity] of your PET drug. Specifically,***111
483s related to changes

I think its fair to say the decreases as a result of the pandemic and the reduced inspections.

Over on the device side of things we see:

Reference NumberShort DescriptionLong DescriptionFrequency
21 CFR 820.30(i)Design changes – Lack of or Inadequate ProceduresProcedures for design change have not been [adequately] established.  Specifically,***26
21 CFR 820.40(b)Document change records, maintained.Records of changes to documents were not [adequately] maintained.  Specifically, ***6
21 CFR 820.70(b)Production and Process Change Procedures, lack of or Inad.Procedures for changes to a [specification] [method] [process] [procedure] have not been [adequately] established.  Specifically, *** 5
21 CFR 820.75(c)Process changes – review, evaluation and revalidationA validated process was not [reviewed and evaluated] [revalidated] when changes or process deviations occurred. Specifically, ***5
21 CFR 820.40(b)Change records, contentRecords of changes did not include [a description of the change] [identification of the affected documents] [the signature of the approving official(s)] [the approval date] [when the change became effective].  Specifically, ***



3
21 CFR 820.50(b)Supplier notification of changesThere is no agreement with [suppliers] [contractors] [consultants] to notify you of changes in the product or service.  Specifically, ***3
21 CFR 820.75(c)Documentation – review in response to changes or deviationsThere is no documentation of the [review and evaluation of a process] [revalidation of a process] performed in response to changes or process deviations.  Specifically, ***1
Device 473s around change

I’m a firm believer that pharma should always pay attention to the medical device side for 483s. A lot of us are combination products now (or will be) and there is always good trends to be aware of.

My key takeaways:

  1. Think change management and not just change control and document control
  2. Computer change controls need to be holistic and system orientated
  3. Have a process that ensures changes are appropriately reviewed and approved
  4. Risk based and evaluate validation
  5. A robust supplier management program is critical, plan for change

Here’s a more detailed checklist to help you evaluate your change system.

Understanding the Levers of Change

As part of my presentation “Sustaining Change – Executing a Sustainability Plan” at the ASQ Lean and Six Sigma Conference tomorrow I’ll be talking about levers of change.

Understanding the change landscape

Change Management practitioners usually talk about seven levers:

  1. Infrastructure – Investing in the tools, processes, and other resources that employees need to be successful with the change initiative.
  2. Walk the Talk – active leadership is about ownership; it includes making the business case clear, modeling behaviors, clearing obstacles and making course corrections.
  3. Reward and Recognition – acknowledgement and compensation for employees who work to move the initiative forward
  4. Mass Exposure – getting out information about the change through broadcast messages and other communication pathways
  5. Personal Contacts – creating opportunities for advocates to share their experience of the change with peers who feel disengaged
  6. Outside advocates – bringing in resources (internal or external) to gain expertise for the change initiative
  7. Shift Resisters – moving people to areas less affected by the initiative.
7 levers of change

Conference Speaking -2020 Lean and Six Sigma

In February I will be presenting at the 2020 ASQ Lean and Six Sigma Conference in Phoenix on Sustaining Change – Executing a Sustainability Plan.

Here’s the presentation summary:

For Lean and Six Sigma projects a central question should always be “how do we sustain this change?” Sustainability is a major part of all the major change models but is often the easiest to neglect. This session will engage the participant in building a Sustainability Plan, a key tool to ensure the change is anchored and embedded in the organization. Through three case study examples of changes at the three major change levels -transactional, organizational and transformational – the participant will gain the knowledge to create and execute an effective change plan.

During this session examples will be given for each component of a sustainability plan:

  • Communication: Mechanisms for persuasive communication and ongoing socialization of the change, rites of parting (saying goodbye to the old ways of doing things), and rites of enhancement (acknowledgment of quick wins and continued adoption)
  • Metrics Tracking: How to identify and execute consistent and effective ongoing measurement and results reporting to track progress and ensure sustained results • Performance Management: Process for observing and objectively measuring desired behaviors and attitudes, including performance appraisal process, promoting, demoting and transferring, and training and development
  • Rewards and Recognition: Program of intrinsic and extrinsic incentives to reinforce desired behaviors and attitudes
  • Sustaining Ownership: Consistent process for ensuring sustained ownership of the change through the ongoing transfer of experience and knowledge
  • Continuous Improvement: Mechanisms for responding to changing requirements and implementing improvements based on feedback, observations, and metrics

The following questions will be explored, and tools for finding answers will be provided:

  • How should organizational achievements reinforcing the change be commemorated
  • What behaviors should be observed and measured on a regular basis?
  • What results should be observed and measured on a regular basis?
  • What metrics should be used for measuring behaviors and results?
  • What mechanisms should be used for reporting results? • What criteria should be used to allocate rewards and promotion?
  • What mechanisms should be used for training, coaching, and role modeling?
  • What processes and procedures should be put in place to ensure sustained ownership of the change?
  • What continuous improvement mechanisms will address low adoption rates and ensure the change becomes part of the organization’s normal functioning?

At the end of the session the user will have a template for creating a sustainability plan and will have been provided tools to successfully execute the sustainability phase of a change.

Learning Objectives 1. Assess the role of sustainability in the major change management methodologies and apply to lean and six sigma projects. 2. Facilitate the sustainability phase of change management. 3. Compose a sustainability plan.