Documents and the Heart of the Quality System

A month back on LinkedIn I complained about a professional society pushing the idea of a document-free quality management system. This has got to be one of my favorite pet peeves that come from Industry 4.0 proponents, and it demonstrates a fundamental failure to understand core concepts. And frankly one of the reasons why many Industry/Quality/Pharma 4.0 initiatives truly fail to deliver. Unfortunately, I didn’t follow through with my idea of proposing a session to that conference, so instead here are my thoughts.

Fundamentally, documents are the lifeblood of an organization. But paper is not. This is where folks get confused. But fundamentally, this confusion is also limiting us.

Let’s go back to basics, which I covered in my 2018 post on document management.

When talking about documents, we really should talk about function and not just by name or type. This allows us to think more broadly about our documents and how they function as the lifeblood.

There are three types of documents:

  • Functional Documents provide instructions so people can perform tasks and make decisions safely effectively, compliantly, and consistently. This usually includes things like procedures, process instructions, protocols, methods, and specifications. Many of these need some sort of training decision. Functional documents should involve a process to ensure they are up-to-date, especially in relation to current practices and relevant standards (periodic review)
  • Records provide evidence that actions were taken, and decisions were made in keeping with procedures. This includes batch manufacturing records, logbooks and laboratory data sheets and notebooks. Records are a popular target for electronic alternatives.
  • Reports provide specific information on a particular topic on a formal, standardized way. Reports may include data summaries, findings, and actions to be taken.

The beating heart of our quality system brings us from functional to record to reports in a cycle of continuous improvement.

Functional documents are how we realize requirements, that is the needs and expectations of our organization. There are multiple ways to serve up the functional documents, the big three being paper, paper-on-glass, and some sort of execution system. That last, an execution system, united function with record, which is a big chunk of the promise of an execution system.

The maturation mind is to go from mostly paper execution, to paper-on-glass, to end-to-end integration and execution to drive up reliability and drive out error. But at the heart, we still have functional documents, records, and reports. Paper goes, but the document is there.

So how is this failing us?

Any process is a way to realize a set of requirements. Those requirements come from external (regulations, standards, etc) and internal (efficiency, business needs) sources. We then meet those requirements through People, Procedure, Principles, and Technology. They are interlinked and strive to deliver efficiency, effectiveness, and excellence.

So this failure to understand documents means we think we can solve this through a single technology application. an eQMS will solve problems in quality events, a LIMS for the lab, an MES for manufacturing. Each of these is a lever for change but alone cannot drive the results we want.

Because of the limitations of this thought process we get systems designed for yesterday’s problems, instead of thinking through towards tomorrow.

We get documentation systems that think of functional documents pretty much the same way we thought of them 30 years ago, as discrete things. These discrete things then interact through a gap with our electronic systems. There is little traceability, which complicates change control and makes it difficult to train experts. The funny thing, is we have the pieces, but because of the limitations of our technology we aren’t leveraging them.

The v-model approach should be leveraged in a risk-based manner to the design of our full system, and not just our technical aspects.

System feasibility matches policy and governance, user requirements allow us to trace to what elements are people, procedure, principles, and/or technology. Everything then stems from there.

Process, Procedure and Task

A task is the steps for doing a particular piece of work.

Procedure are activities made up of a series of tasks.

A process is an upper level description of a series of activities required to accomplish an objective. Processes are made up of procedures or tasks. They have inputs and outputs.

Flow of sequences of activities that transform input elements into resultsSpecific and required way to carry out a processDescribe the correct steps to perform a specific task
What we do By Whom Where it takes place When it happensHow the work must be performedHow to accomplish a specific task within a process with very detailed directions
Orchestration the workMandatory methodMandatory guidance
Can link to 0, 1 or more proceduresIt may consist of 0, 1 or more task instructionsFocus on the instructions of 1 task
Transversal by business unitsCross functional or only 1 business unitOnly 1 business unit
Participate more than one roleParticipate more than one roleParticipate only one role
Encapsulates activitiesExplains how to do but doesn’t get to all the details of how it is doneAll of the detail of all the steps to follow in an activity
Provides the workflow model at the highest level using  BPMNDocument with both narrative and images, usually in the form of use cases and workflow diagramsDocument with the maximum detail that explains step by step the instructions that must be carried out in an activity
Process, Procedure and Task Differences

This is the middle of a traditional document hierarchy and form the Functional set of documents,

References and Related Documents in Procedural Documents

It is pretty standard advice that relevant references to other documents should be listed in a separate section of the procedure. The reasoning is that when some standard operating procedures are intimately linked to others – the information contained in more than one document is necessary to complete a task – it is useful to include a cross-reference section in each document. Many also say that this section reinforces the SOP’s authority.

Another fairly common piece of advice is to have this, or another, section in the procedure identify the documents used in the development of the procedure, such as regulatory documents or technical/validation reports.

My take is that neither belongs in a process/procedure (SOP/WI). We should be looking to streamline requirements documents, and these sections are just cruft.

If you have electronic document control systems then cross-references should be handled trough hyperlink. Users are quite comfortable with hyperlinks and will easily navigate between documents.

Listing of regulations and other requirements belongs in a separate design document (ideally part of the document control system), and again add little value to the execution of the document.

There are a lot of so-called “best practices” about documents that stem from the days where everything is paper, and it is okay to move beyond them.

Review of Process/Procedure

Review of documents are a critical part of the document management lifecycle.

Document Lifecycle

In the post Process/Procedure Lifecycle there are some fundamental stakeholders:

  • The Process Owner defines the process, including people, process steps, and technology, as well as the connections to other processes. They are accountable for change management, training, monitoring and control of the process and supporting procedure. The Process Owners owns the continuous improvement of the overall process.
  • Quality is ultimately responsible for the decisions made and that they align, at a minimum, with all regulatory requirements and internal standards.
  • Functional Area Management represents the areas that have responsibilities in the process and has a vested interest or concern in the ongoing performance of a process. This can include stakeholders who are process owners in upstream or downstream processes.
  • A Subject Matter Expert (SME) is typically an expert on a narrow division of a process, such as a specific tool, system, or set of process steps. A process may have multiple subject matter experts associated with it, each with varying degrees of understanding of the over-arching process.

A Risk Based Approach

The level of review of a new or revised process/procedure is guided by three fundamental risk questions:

  • What might go wrong with the associated process? (risk identification)
  • What is the likelihood that this will go wrong? (risk analysis)
  • What are the consequences? How severe are they if this goes wrong? (risk analysis)

Conducting risk identification is real about understanding how complicated and complex the associated process is. This looks at the following criteria:

  • Interconnectedness: the organization and interaction of system components and other processes
  • Repeatability: the amount of variance in the process
  • Information content: the amount of information needed to interact with the process

What Happens During a Review of Process and Procedure

The review of a process/procedure ensures that the proposed changes add value to the process and attain the outcome the organization wants. There are three levels of review (which can and often do happen simultaneously):

  • Functional review
  • Expert review by subject matter experts
  • Step-by-step real-world challenge

Functional review is the vetting of the process/procedure. Process stakeholders, including functional area management affected by the change has the opportunity to review the draft, suggest changes and agree to move forward.

Functional review supplies the lowest degree of assurance. This review looks for potential impact of the change on the function – usually focused on responsibilities – but does not necessarily assures a critical review.

In the case of expert review, the SMEs will review the draft for both positive and negative elements. On the positive side, they will look for the best practices, value-adding steps, flexibility in light of changing demands, scalability in light of changing output targets, etc. On the negative side, they will look for bottlenecks in the process, duplication of effort, unnecessary tasks, non-value-adding steps, role ambiguities (i.e. several positions responsible for a task, or no one responsible for a task), etc.

Expert review provides a higher degree of assurance because it is a compilation of expert opinion and it is focused on the technical content of the procedure.

The real-world challenge tests the process/procedure’s applicability by challenging it step-by-step in as much as possible the actual conditions of use. Tis involves selecting seasoned employee(s) within the scope of the draft procedure – not necessarily a SME – and comparing the steps as drafted with the actual activities. It is important to ascertain if they align. It is equally important to consider evidence of resistance, repetition and human factor problems.

Sometimes it can be more appropriate to do the real-world test as a tabletop or simulation exercise.

As sufficient reviews are obtained, the comments received are incorporated, as appropriate. Significant changes incorporated during the review process may require the procedure be re-routed for review, and may require the need to add additional reviews.

Repeat as a iterative process as necessary.

Design lifecycle

The process/procedure lifecycle can be seen as the iterative design lifecycle.

Design Thinking: Determine process needs.

  • Collect and document business requirements
  • Map current-state processes.
  • Observe and interview process workers.
  • Design process to-be.

Startup: Create process documentation, workflows, and support materials. Review and described above

Continuous Improvement: Use the process; Collect, analyze, and report; Improve

MHRA 2019 GMP Inspection Data and Documentation observations

Transparency is something that regulatory agencies need to get better at, both in sharing more and doing it in a timely manner. The fact that the 2019 data from the MHRA was released in October of 2020 is pretty poor. As a reference, the FDA releases their data pretty reliably at the end of the calendar year for the given year.

Been evaluating the MHRA’s 2020 data on Chapter 4 Documentation, which is the 2nd largest category of observations in 2019 (and in 2018 before it).

80 different inspections cited comments against the Principles section

Good documentation constitutes an essential part of the quality assurance system and is key to operating in compliance with GMP requirements. The various types of documents and media used should be fully defined in the manufacturer’s Quality Management System.

Documentation may exist in a variety of forms, including paper-based, electronic or photographic media. The main objective of the system of documentation utilized must be to establish, control, monitor and record all activities which directly or indirectly impact on all aspects of the quality of medicinal products. The Quality Management System should include sufficient instructional detail to facilitate a common understanding of the requirements, in addition to providing for sufficient recording of the various processes and evaluation of any observations, so that ongoing application of the requirements may be demonstrated.

There are two primary types of documentation used to manage and record GMP compliance: instructions (directions, requirements) and records/reports. Appropriate good documentation practice should be applied with respect to the type of document.

Suitable controls should be implemented to ensure the accuracy, integrity, availability and legibility of documents. Instruction documents should be free from errors and available in writing. The term ‘written’ means recorded, or documented on media from which data may be rendered in a human readable form.

Principles, Chapter 4 Documentation

The Principles section then goes on to lay out the required document types.

I would love to see more. Is this 80 companies who don’t known what a SMF is? Good documentation practices? Don’t have SOPs and batch records? Have errors in their documents? Don’t approve them? More transparency would be valuable here.

We can learn more by drilling down in the document.

  • There are 87 inspections with 4.1 in section “Generation and Control of Documents”. 1 is critical and 25 are major. Here we see failures in understanding types of documents and controlling them, or maybe just having them in the first place.
  • The 82 against 4.2 (1 critical and 20 major) are more about having the manufacturing and testing process defined (and matching the filing).
  • 103 inspections with observations against 4.3 (23 major) show companies that do not have appropriate approval and release controls
  • 14 for 4.4 (6 major) means there are 14 companies out there who can’t write a good process and procedure. 4.4 has one of my favorite requirements “written in an imperative mandatory style”
  • 60 against 4.5 (13 major) demonstrates a lack of review and keeping documents up-to-date.
  • 12 companies (6 major) have terrible handwriting and cannot stick to ballpoints, yes in fact 4.7 states “Handwritten entries should be made in clear, legible, indelible way.”
  • 103 against 4.8 (1 critical and 28 major) is ALCOA focused on contemporaneous, attributable and accurate.
  • 18 for 4.9 (6 major) is for not correcting data correctly. That’s right 18 companies do not know how to comment correctly.
  • 22 for 4.10 (1 critical and 9 major) is for not clearly laying out the manufacturing records and keeping them for the retention period.
  • 19 for 4.29 (5 major) is a lack of process and procedure for a grab-bag of quality processes from change control to equipment management to cleaning

There are more, but we are in single digit observation territory.

Useful things to be evaluating in your own organization. As a good place to start, here are some questions to ask when contemplating data integrity.