The Challenges Ahead for Quality

Discussions about Industry 4.0 and Quality 4.0 often focus on technology. However, technology is just one of the challenges that Quality organizations face. Many trends are converging to create constant disruption for businesses, and the Quality unit must be ready for these changes. Rapid changes in technology, work, business models, customer expectations, and regulations present opportunities to improve quality management but also bring new risks.

The widespread use of digital technology has raised the expectations of stakeholders beyond what traditional quality management can offer. As the lines between companies, suppliers, and customers become less distinct, the scope of quality management must expand beyond the traditional value chain. New work practices, such as agile teams and remote work, are creating challenges for traditional quality management governance and implementation strategies. To remain relevant, Quality leaders must adapt to these changes..

The traditional Value Proposition of quality management is no longer sufficient to meet the expectations of stakeholders. With the rise of a digitally native workforce, there are new expectations for how work is done and managed. Business leaders expect quality leaders to have full command of operational data, diagnosing and anticipating quality problems. Regulators also expect high data transparency and traceability.

The value proposition of quality management lies in predicting problems rather than reacting to them. The primary objective of quality management should be to find hidden value by addressing the root causes of quality issues before they manifest. Quality organizations who can anticipate and prevent operational problems will meet or exceed stakeholder expectations.

Our organizations are on a journey towards utilizing predictive capabilities to unlock value, rather than one that retroactively solves problems. Our scope needs to be based on quality being predictive, connected, flexible, and embedded. For me this is the heart of Qualty 4.0.

Quality management should be applied across a multitude of systems, devices, products, and partners to create a seamless experience. This entails transforming quality from a function into an interdisciplinary, participatory process. The expanded scope will reach new risks in an increasingly complex ecosystem. The Quality unit cannot do this on its own; it’s all about breaking down silos and building autonomy within the organization.

To achieve this transformation, we need to challenge ourselves to move beyond top-down and regimented Governance Models and Implementation Strategies. We need to balance our core quality processes and workflows to achieve repeatability and consistency while continually adjusting as situations evolve. We need to build autonomy, critical thinking, and risk-based thinking into our organizational structures.

One way to achieve this is by empowering end-users to solve their own quality challenges through participatory quality management. This encourages personal buy-in and enables quality governance to adapt in real-time to different ways of working. By involving end-users in the process of identifying and solving quality issues, we can build a culture of continuous improvement and foster a sense of ownership over the quality of our products and services.

The future of quality management lies in being predictive, connected, flexible, and embedded.

Predictive: The value proposition of quality management needs to be predicting problems over problem-solving.
Connected: The scope of quality management needs to extend beyond the value chain and connect across the ecosystem
Flexible: The governance model needs to be based on an open-source model, rather than top-down.
Embedded: The implementation strategy needs to shift from viewing quality as a role to quality as a skill.

By embracing these principles and involving all stakeholders in the process of continuous improvement, we can unlock hidden value and exceed stakeholder expectations.

Deaing with these challenges and implications requires the Quality organization to treat transformation like a Program. This program should have four main initiative areas:

Build the capacity for targeted prevention through targeted data insights. This includes building alliances with IT and other teams to have the right data available in flexible ways but it also includes the building of capacity to actually use the data.
Expand quality management to cover the entire value network.
Localize Risk Management to Make Quality Governance Flexible and Open Source.
Distribute Tasks and Knowledge to Embed Quality Management in the Business.

Across these pillars the program approach will:

Assess the current state: Identify areas requiring attention and improvement by examining existing People, Processes, Policies and Platforms. This comprehensive assessment will provide a clear understanding of the organization’s current situation and help pinpoint areas where projects can have the most significant impact
Establish clear objectives: Establish clear objectives to h provide a clear roadmap for success.
Prioritize foundational elements: Prioritize building foundational elements. Avoid bells-and-whistles for their own sake.
Develop a phased approach: This is not an overnight process. Develop a phased approach that allows for gradual implementation, with clear milestones and measurable outcomes. This ensures that the organization can adapt and adjust as needed while maintaining ongoing operations and minimizing disruptions.
Collaborate with stakeholders: Engage stakeholders from across the organization,to ensure alignment and buy-in. Create a shared vision for the initiative to ensure that everyone is working towards the same goals. Regular communication and collaboration among stakeholders will foster a sense of ownership and commitment to the transformation process.
Continuously monitor progress: Regularly review the progress, measuring outcomes against predefined objectives. This enables organizations to identify any potential issues or roadblocks and make adjustments as necessary to stay on track. Establishing key performance indicators (KPIs) will help track progress and determine the effectiveness of the Program.
Embrace a culture of innovation: Encourage a culture that embraces innovation and continuous improvement. This helps ensure that the organization remains agile and adaptive, making it better equipped to take advantage of new technologies and approaches as they emerge. Fostering a culture of innovation will empower employees to seek out new ideas and solutions, driving long-term success.
Invest in employee training and development: It is crucial to provide employees with the necessary training and development opportunities to adapt to new technologies and processes. This will ensure that employees are well-equipped to handle the changes brought about by these challenges and contribute to the organization’s overall success.
Evaluate and iterate: As the Program unfolds, it is essential to evaluate the results of each phase and make adjustments as needed. This iterative approach allows organizations to learn from their experiences and continuously improve their efforts, ultimately leading to greater success.

To do this leverage the eight accelerators to change.

Interim Controls within a Change Control

The PIC/S recommendation on change control section 5.3 “Change Planning & Implementation” recognizes that changes often address issues that need to be remediated:

Potential risks with the current state (until changes are implemented) and any risks that might be temporarily introduced during the change process are adequately assessed.
Interim controls (short-term measures), as needed, are identified and implemented in a timely manner to monitor/mitigate risks associated with the current situation (until change implementation).

This section also recognizes that changes introduce an interim set of conditions that lead to implementation – from opening a machine through massive construction activities, and just about anything else.

A good change control does not just address what is necessary to implement the desired future state. It also contains interim controls for managing the current state until the future is implemented, and addresses all of the potential risks during the process of implementation.

Change plans address current, interim, and future states

Often the change control stems from an action plan in a CAPA record, where the interim controls are specifically called out and detailed. These may be adequate for a relatively brief period but are not realistically sustainable. Remember that these interim controls must also go through the appropriate change control process. Which may have been a separate change control or be part of this change control. In all cases, the change control should either determine that the CAPA plan is adequate or identify additional risks that were identified during change planning.

Risk assessments for change control should really have three basic risk questions:

What are the risks of the current state as we implement the change?
What are the risks of the implementation process?
What are the risks of the future state?

As discussed elsewhere, these questions are really branching trees.

Interim controls in a change are usually little temporary changes in the change plan that either mitigate occurrence or impact.

Interim Control Type	Mitigate Occurrence	Mitigate Impact
Examples	Every record processed will be reviewed for the event error before completion. Revised preventive maintenance procedure to require vibration test at next preventive maintenance. Increase cleaning frequency of incubator.	Add emergency response steps to address a valve that is malfunctioning. Add engineering check for pump prior to each use. Perform cleaning log review prior to use.

As temporary changes, it is important to determine how they will be implemented, if they require monitoring, and how they will go away. Often the process of implementation of the change removes the temporary changes, but that is not always the case.

Changes that impact multiple product

Dear all, regarding question 20 “Is the effective date of the change (completion date) recorded and when appropriate the first batch manufactured recorded?” we are not sure how to handle it for multi-product changes. At our site we manufacture products of different customers. Sometimes we have changes, where f.e. documents of several products need to be adapted. How are the requirements defined in such cases? Do we need to report the first batch only once or for each product
Correspondent

This request comes from my post “29 questions to ask about your change management/change control system.”

At heart, this requirement is to help meet the regulatory requirement that “After implementation, an evaluation of the change should be undertaken to confirm the change objectives were achieved and that there was no deleterious impact on product quality.” (ICH Q9 part IV.B.3.d)

In order to perform an evaluation, you must be able to know when to start. This evaluation must be able to be performed on each and every product. It is from here we can settle on 1st batch. There are lots of ways to do this. The requirement is, for each and every product, to be able to state definitively when the change was first applied to the product.

We can drill down to the most definitive guidance on GMP Change Control, the PIC/S Recommendation “How to Evaluate and Demonstrate the Effectiveness of a Pharmaceutical Quality System in relation to Risk-based Change Management” which further strengthens the requirement:

Section	Requirement	Means
5.4. Change Review and Effectiveness	Changes are monitored via ongoing monitoring systems to ensure maintenance of a state of control, and lessons learned are captured and shared/communicated. (Note: Activities such as Management Review, Annual Product Quality Review, Continuous Process Verification, Deviation Management and Complaint Monitoring can be useful in this regard.)	Having that definitive point allow all these activities to be effective.

The requirement is clear. We need to be able for any given change identify when it started impacting product.

All of the various Annual Product Review/Product Quality Review requirements also require the ability to evaluate all changes to the product in a given time frame.

There is also the need, for release purposes, to determine if a batch is impacted by a change.

Like many such requirements, there are multiple ways to do this. I think the requirement to capture first batch in a change control really stems from it, in many ways, being the easiest to do as you only have to manage it in the change control workflow. Though, in all honesty, it is also darn annoying with changes potentially being open more than a year to capture all possible products.

Based on our core requirement, there are several factors to consider:

There must be a way for a user to easily determine when a given change impacted a given product and to determine if a given batch was impacted by the changes
The user must be able to link any batch to all the changes that impacted it
The user must be able to run a report of all changes that impacted a product in a time frame

There are multiple ways of solving for this from the put a field in the change control to set of interfaces between the ERP and eQMS (and maybe MES).

Change Management is Bigger than Change Control So Think Beyond Individual Changes

As a pharmaceutical GXP professional with one foot in the GXP Quality camp and another in the organizational change management camp, I have a few pet peeves. And one of my biggest is whenever someone uses a phrase like “Change management may be known by different terminologies (e.g., change control, change requests, change orders).” That’s a reductionist statement that can really lead to a lot of confusion in an organization.

Change management is the how of change – assess, handle and release. Change control is the what, the execution steps. Change management is a big picture system that looks systematically at people, technology, process, and organization. Change control is the set of mechanisms for controlling the introduction of that change to the organization.

A lot of different systems and processes have change control elements. As many of these processes are supported with specific technologies, it can be very important to think about how they fit together like a puzzle.

This puzzle is usually made up of core requirements. Based on how much the change impacts them decides the rigor of the change control process.

Take for example a pharmaceutical manufacturing site. It is fairly typical to have one process for maintenance, another for IT, another for documents, etc. And then you have a change control system for things that impact established conditions, including validated state and regulatory submissions. Maybe you work at some technological utopia with a single system that manages all changes with all the deliverables, but at most places, you are trying to balance efficiency with effectiveness, and have a real need to avoid unnecessary duplication.

ICH Q12 helps by giving a nice breakdown of the major families of changes.

This helps somewhat, but for the average user it is not very specific. We need to translate it. First, we establish that only one system will be used for regulatory impact (“Tell and Do”, “Do and Tell” “Do and Report” and some of “Do and Record”), then we put the major activities that go into it. This breakdown might look like:

We are utilizing a few major criteria:

Impact of regulated state
Impact of validated state
Risk level of change
Scale of change to the organization

Using these criteria we can even drill down further, for example:

It is usually a good idea to go down to an even deeper level to help the end-user.

Requires CCR	Does Not Require CCR
Any change that impacts the integrity of controlled classified areas, including all room and equipment surfaces	Changes that do not impact integrity of controlled classified areas by meeting the following criteria: · Does not change airflow · Does not impact structural integrity and maintains a smooth cleanable surface · Does not change means of ingress/egress · Does not impact current sampling sites from the Environmental Monitoring Program · Materials used are resistant to cleaning agents used in the area as defined in the building specifications · Materials are included in disinfectant effectiveness study
Any change that impacts air balancing	Work that is part of routine or preventive maintenance or calibration
Changes to equipment or replacements with a functional equivalent or different component	Changes to equipment with an exact component
Changes to facility floor layout	Instrument calibration including adjustments to field instrumentation
Changes to equipment operating and control parameters	Removal/storage of portable equipment
Changes to equipment, material and personnel ingress, egress and flow procedures	Replacement of system instrument hardware with exact components (hardware)
Changes to room classifications	Engineering studies that do not change the validated state or change anything requiring a CCR per this procedure
Changes that impact the environmental integrity of a room	Alarm set point changes that return to the previous qualified/validated state
Replacement and/or decommissioning of equipment, utilities or facilities	Remediation work (such as mechanical polishing, weld repairs, electro-polishing, filling of pits, de-rouging and chemical cleaning with already approved material)
Alarm set point or classification changes	Addition, modification or deletion to Potable Water, Plant Steam, Chilled Water, Cogeneration System, or pre-treatment reverse-osmosis
Changes in intended use of a room or area	Modification to piping tied to Potable Water, Plant Steam, Chilled Water, Cogeneration System, or pre-treatment reverse-osmosis
Changes to Preventive Maintenance that includes: · Decreasing frequency of preventive maintenance (i.e. making less frequent) · Change in intent of a preventive maintenance task · Adding or removing tasks	Changes to Preventive Maintenance that include: · Increasing frequency of preventative maintenance (i.e. making more frequent) · Administrative changes · Adding clarity to a task (e.g. changing instructions on how to execute a task without altering the intent of the task) · Reordering task(s) without changing intent of the task(s) · Changes of tools needed to execute a task; room dedicated tools must remain in the designated area · Changes to quantity of materials
Changes that decrease the calibration frequency (i.e. make less frequent) for GMP Critical equipment (e.g. directly related to operational control of the product)	· Changes that increase calibration frequency (i.e. make more frequent) for GMP Non-Critical equipment (e.g. indirectly related to operational control of the product)
Tuning parameter, adjustment to the gain, reset and rate of a PID controller	New or replacement analytical equipment or instruments identified as Category A or Category B-Calibration Only with an exact component
Changes to the calibration frequency of GMP critical equipment (e.g. directly related to operational control of the product)	Changes to manufacturing report properties
Changes to the Environmental Monitoring Program, including addition, deletion or change to a sample location	Changes to alarm paging/notification recipients
Changes to the program for disinfection of a facility or equipment exterior	Creating/modifying individual user accounts
Change of materials of construction or class of polymeric materials (e.g. elastomers, tubing, gaskets and diaphragms)	Add an instrument to the calibration system during pre-commissioning
Changes to hardware or infrastructure associated with a validated system, equipment or utility	Changes to requalification frequency that do not change the intended use or validated state of the equipment or utility
Upgrade of application software or operating system for validated systems, equipment or utility	Corrective changes to an SOP to align it to the validated state
Changes to an SOP to align it to the validated state with impact to one or more regulatory filings	A corrective change to alarm set points to align with the validated state
Creating user groups and/or modifying user group privileges as part of a larger process change associated with validated systems, equipment, or utilities	Addition of a new calibration standard to be used with a new type of instrument at the Alachua site
Creating user groups and/or modifying user group privileges associated with validated systems, equipment, or utilities	Changes to alarm paging/notification recipients
Addition of a new calibration standard to be used with a new type of instrument at the Cambridge and Lexington sites
Modifying a phase prompt or message associated with validated systems, equipment, or utilities
Addition / change of a graphic associated with validated systems, equipment, or utilities
Addition or changing an interlock/permissive trigger
Addition/removal of I/O of validated systems
Changes to the Environmental Monitoring Program, including addition, deletion or change to a sample location
Changes to alarm paging/notification functionality
Historical data collection configuration
Change of equipment and spare parts storage site, including transfers between facilities and transfers to a contracted third party

All of this is change management. We utilize multiple change control mechanisms to manage the change.

Also, don’t forget that change controls can nest. For example a change to the EQMS has IT changes, document changes, training changes, and probably more.

Implementing a Quality Ambassador Program

Quality ambassadors can influence their peers to prioritize quality, thereby strengthening the culture of quality in the organization. Quality leaders can use this guide to develop a quality ambassador program by identifying, training, and engaging ambassadors.

Utilizing Kotter’s eight accelerators for change, we can implement a Quality Ambassador program like this:

Accelerator	Actions
Create a strong sense of urgency around a big opportunity	Demonstrate the organizational value of Ambassadors by performing a needs analysis to assess the current state of employee engagement with quality.
Build and evolve a guiding coalition	Bring together key stakeholders from across the organization who will provide input in the program’s design and support its implementation.
Form a change vision and strategic initiatives	Identify the key objectives for implementing a Quality Ambassador program and outline the lines of effort required to successfully design and pilot it.
Enlist a volunteer army	Reach out and engage informal leaders at all levels of the organization. Find your current informal Ambassadors and draw them in.
Enable action by removing barriers	Be vigilant for factors that impede progress. Work with your Ambassadors and senior leaders to give teams the freedom and support to succeed.
Generate and celebrate short-term wins	Pilot the program. Create success stories by looking at the successful outcomes of teams that have Quality Ambassadors and by listening to team members and their customers for evidence that quality culture is improving. Your goal will be to create an environment where teams that do not have Quality Ambassadors are asking how they can participate.
Sustain acceleration	Scale the impact of your program by implementing it more broadly within the organization.

Define the Key Responsibilities of Quality Ambassadors


What activities should Quality Ambassadors focus on?	Example: Reinforce key quality messages with co-workers. Drive participation in quality improvement projects. Provide inputs to improve culture of quality. Provide inputs to improve and maintain data integroty
What will Quality Ambassadors need from their managers?	Example: Approval to participate, must be renewed annually
What will Quality Ambassadors receive from the Quality team?	Example: Training on ways to improve employee engagement with quality. Support for any questions/objections that ariseTraining on data integrity
What are Quality Ambassadors’ unique responsibilities?	Example: Acting as the point of contact for all quality-related queries. Reporting feedback from their teams to the Quality leadership. Conveying to employees the personal impact of quality on their effectiveness. Mitigating employee objections about pursuing quality improvement projects. Tackling obstacles to rolling out quality initiatives
What responsibilities do Quality Ambassadors share with other employees?	Example: Constantly prioritize quality in their day-to-day work
Expected time commitment	Example: 8-10 hours/month, plus 6 hours of training at launch

Metrics to Measure Success

Type of Metrics	List of Metrics	Direct Impact of Ambassador’s work	Recommendations
Active Participation Levels	Percentage of organizational units adopting culture of quality program. The number of nominations for quality recognition programs. Quality observations were identified during Gemba walks. Participation or effectiveness of problem-solving or root-cause processes. The number of ongoing quality improvement projects. Percentage of employees receiving quality training	High	Ambassadors should be directly held responsible for these metrics
Culture of Quality Assessments	Culture of quality surveys. Culture of quality maturity assessments	Medium	The Quality Ambassador program is a factor for improvement.
Overall Quality Performance	Key KPI associated with Quality. Audit scoresCost of poor quality	Low	The Quality Ambassador program is a factor for improvement.

Challenge	Means	Impact to Quality Management	How to Prepare
Advanced Analytics	The increase in data sources and improved data processing has led to higher expectations from customers, regulators, business leaders, and employees. They expect companies to use data analytics to provide advanced insights and improve decision-making.	Requires a holistic approach that allows quality professionals to access, analyze and apply insights from structured and unstructured data Quality excellence will be determined by how quickly data can be captured, analyzed, shared and applied	Develop a talent strategy to recruit, develop, rent or borrow individuals with data analytics capabilities, such as data science, coding and data visualization
Hyper-Automation	To become more efficient and agile in a competitive market, companies will increasingly use technologies like RPA, AI, and ML. These technologies will automate or enhance tasks that were previously done by humans. In other words, if a task can be automated, it will be.	How to ensure these systems meet intended use and all requirements Algorithm-error generated root causes	Develop a hyperautomation vision for quality management that highlights business outcomes and reflects the use cases of relevant digital technology Perform a risk based assessment with appropriat experts to identify critical failure points in machine and algorithm decision making
Virtualization of Work	The shift to remote work due to COVID-19, combined with advancements in cloud computing and AR/VR technology, will make work increasingly digital.	Rethink how quality is executed and governed in a digital environment.	Evaluate current quality processes for flexibility and compatibility with virtual work and create an action plan. Uncover barriers to driving a culture of quality in a virtual working environment and incorporate virtual work-relevant objectives, metrics and activities into your strategy.
Shift to Resilient Operations	Prioritizing capabilities that improve resilience and agility.	Adapt in real-time to changing and simultaneously varying levels of risk without sacrificing the core purpose of Quality	Enable employees to make faster decisions without sacrificing quality by developing training to build quality-informed judgment and embedding quality guidance in employee workflows. Identify quality processes that may prevent operational resilience and reinvent them by starting from scratch, ruthlessly challenging the necessity of every step and requirement. Ensure employees and new hires have the right skill sets to design, build and operate a responsive network environment.
Rise of Inter-connected Ecosystems	The growth of interconnected networks of people, businesses, and devices allows companies to create value by expanding their systems to include customers, suppliers, partners, and other organizations.	Greater connectivity between customers, suppliers, and partners provides more visibility into the value chain. However, it also increases risk because it can be difficult to understand and manage different views of quality within the ecosystem.	Map out the entire quality management ecosystem model and its participants, as well as their interactions with customers. Co-develop critical-to-quality behaviors with strategic partners. Strengthen relationships with partners across the ecosystem to capture and leverage relevant information and data, while at the same time addressing data privacy concerns.
Digitally Native Workforce	Shift from digital immigrants (my generation and older) to digital natives who are those people who have grown up and are comfortable with computers and the internet. Unlike other generations, digital natives are so used to using technology in all areas of their lives that it is (and always has been) an integral, necessary part of their day-to-day.	Increased flexibility leads to a need to rethink the way we monitor, train, and incentivize quality. Connecting the 4 Ps: People, Processes, Policies and Platforms	Identify and target existing quality processes to digitize to offer desired flexibility. Adjust messages about the importance of quality to connect with values employees care about (e.g., autonomy, innovation, social issues).
Customer Expectation Multiplicity	Customer expectations evolve quickly and expand into new-in-kind areas as access to information and global connectedness increases.	Develop product portfolios, internal processes and company cultures that can quickly adapt to rapidly changing customer expectations for quality.	Identify where hyperautomation and predictive capabilities of quality management can enhance customer experience and prevent issues before they occur.
Increasing Regulatory Complexity	The global regulatory landscape is becoming more complex as countries introduce new regulations at different rates. Increased push for localization.	Need strong system to efficiently implement changes across different systems, locations, and regions while maintaining consistent quality management throughout the ecosystem.	Coordinate a structured regulatory tracking approach to monitor changing regulatory developments — highly regulated industries require a more comprehensive approach compared to organizations in a moderate regulatory environment