GAMP’s Biggest Problem is the Name

GAMP5 is pretty clear in its ambition:

This Guide applies to computerized systems used in regulated activities covered by:

•Good Manufacturing Practice (GMP) (pharmaceutical, including Active Pharmaceutical Ingredient (API), veterinary, and blood)

•Good Clinical Practice (GCP)

•Good Laboratory Practice (GLP)•Good Distribution Practice (GDP)

•Good Pharmacovigilance Practices (GVP)

•Medical Device Regulations (where applicable and appropriate, e.g., for systems used as part of production or the quality system, and for some examples of Software as a Medical Device (SaMD1))

GAMP 5: A Risk-Based Approach to Compliant GxP Computerized Systems (2nd edition),

The biggest problem with GAMP is when you search GAMP you get:

That’s right, the ISPE telling you that GAMP is all about manufacturing. A point that Wikipedia is more than happy to reinforce: https://en.wikipedia.org/wiki/Good_automated_manufacturing_practice

This means that I spend a lot of time explaining why GAMP is relevant outside of manufacturing, to a lot of skeptical people who already struggle with the idea that GCP or GLP isn’t some special and unique flower.

To add to that, it is structured like a GxP. I see a G-some letters-P I instantly think Good <something> Practices. It is how my brain and the brain of every single person who works in the GxPs have been trained.

Second, what is that 5? What does it mean? It’s such a bit of esoteric lore that I have to spend more time explaining. For absolutely no value.

And then last, I inevitably have to deal with skepticism about something published by the International Society of Pharmaceutical Engineering being even remotely relevant to the work a study investigator is doing.

Without a doubt, GAMP is a powerful methodology and toolbox. It just shoots itself in the foot every time. It is unfortunate that with the 2nd edition the ISPE did not take a big breath and successfully rebrand as maybe GDIP or something.

Roche Limit – a Powerpoint Game

My fellow PowerPoint jockies, we have been outdone by ROCHE LIMIT, a surrealist point and click horror adventure that was created (and is played in) Microsoft PowerPoint.

The current build of ROCHE LIMIT takes around 20 minutes to play through and features one of the multiple planned endings to the full game. The actual narrative is quite Lynchian and appears to revolve around you accepting your (and possibly the human race’s) inevitable demise and a higher power’s ambivalence towards it. It’s a fun, quick little game, with excellent audio design and pixel art animation throughout. 

Our PowerPoint presentations have a new standard, and that standard is this wild little game.

Follow The Development of ROCHE LIMIT Here

Check Out a Gameplay Video Here

Download The ROCHE LIMIT Beta Here (Requires Microsoft PowerPoint to Run)

Choose Your Font!

For a lot of reasons paper (and paper-on-glass) documents are with us for a long time. So it continually surprises me when I see documents in some basic, reduced readability font .

Even when we go to electronic systems that choice of font is going to be an important one. And it’s probably not the same font as what worked for you in a paper world.

And then there is all that training material and presentations (including conference material).

So spend some time and choose the fonts that works for you and your users. But please for goodness sake don’t default to a font because it is what you have always used.

I’m a huge fan of Roboto.

There was a nice writeup on fonts on SlideModel: 20 Best PowerPoint Fonts to Make Your Presentation Stand Out in 2023

21st Anniversary

I don’t write much about personal stuff on my blog, but today is my 21st anniversary, so I think it’s appropriate.

I think any good relationship is an exercise in continuous improvement. There are mistakes made, people grow in different ways, things change, and let’s be honest we grow a lot in understanding of the other person. I think that understanding never ever ends.

When you start a relationship, you don’t really know the other person. It is only through time and experiences do you get to know them. And maybe you don’t always like what you get to know. And in my relationship with Jess that’s been the case. And again being honest, it has really been on both sides (maybe a little more towards me).

For me, it has really become a joy in discovering new levels, new details, and new depths to my partner. I love what it means to be in a relationship with a person who is continually growing and continually has new things, and new depths to discover.

So happy Anniversary Jess. I Love you.

The Supreme Court’s Decision in Dobbs v. Jackson Women’s Health is a Bleak One for the Life Sciences Industry

I think it is no secret that I inherently view Quality as a progressive endeavor, and do not see eye-to-eye with colleagues who are conservative. How anyone can take our anti-Taylorist endeavor and not get to stands like the importance of human rights and the need to center those whose rights are challenged – like women – is beyond me. How can we stand for autonomy and not fight for the autonomy of all.

The silence of quality organizations is deafening.

What I want to write about now is how the roll-back of Roe in Dobbs should be a real clarion call to the life science industry, which needs to stop funding conservative politicians because those politicians do not have our best interests at heart.

The fight over Mifepristone and Misoprostol has already begun. The religious conservatives will go after it, and this reactionary court will need to gut the FD&C and the rest of the regulatory regime behind drugs in this country to let that happen. This will be really bad. It will cause life science companies to pull research, clinical trials, and manufacturing from this country as we will no longer be the gold standard in the life sciences. We will be a joke.

Take action:

  • Give to abortion funds
  • Check your company’s PAC and see exactly who it is giving to and make noise that funding anti-abortion, anti-science politicians is not acceptable
  • Support your colleagues. If you are male-identifying realize that most of your colleagues just got gut-punched today. Support them.