PIC/S on Change Review and Effectiveness

Starting from the end, let’s review some of the requirements in the new draft PIC/S guidance.

Prior to change closure

Requirement	Important Points
Changes meet their intended objectives and pre-defined effectiveness criteria. Any deviations from those criteria are adequately assessed, accepted and managed/justified. Whenever possible, quantitative data are leveraged to objectively determine change effectiveness (e.g. statistical confidence and coverage).	Clearly delineating what effective means as a date is critical to generate data. CQV activities can tell you if the intended objective is met. Effectiveness reviews must be made up of: Sufficient data points, as described in the implementation plan, gathered to a described timeline, before an assessment of the change is made. The success criteria should be achieved. If not, reasons why they have not been achieved should be assessed along with the mitigation steps to address the reasons why, including reverting to the previous operating state where appropriate. This may require the proposal of a subsequent change or amendment of the implementation plan to ensure success. Data and knowledge gathered from implementation of the change should be shared with the development function and other locations, as appropriate, to ensure that learning can be applied in products under development or to similar products manufactured at the same or other locations
As part of the quality risk management activities, residual risks are assessed and managed to acceptable levels, and appropriate adaptations of procedures and controls are implemented.	These are action items in the change control. As part of the closure activities, revise the risk assessment, clearly delineating risk assessment in two phases.
Any unintended consequences or risks introduced as a result of changes are evaluated, documented, accepted and handled adequately, and are subject to a pre-defined monitoring timeframe.	Leverage the deviation system.

Prior to or after change closure

Requirement	Important Points
Any post-implementation actions needed (including those for deviations from pre-defined acceptance criteria and/or CAPAs) are identified and adequately completed.	If you waterfall into a CAPA system, it is important to include effectiveness reviews that are to the change, and not just to the root cause.
Relevant risk assessments are updated post-effectiveness assessments. New product/process knowledge resulting from those risk assessments are captured in the appropriate Quality and Operations documents (e.g. SOPs, Reports, Product Control Strategy documents, etc.)	Risk management is not a once and done for change management.
Changes are monitored via ongoing monitoring systems to ensure maintenance of a state of control, and lessons learned are captured and shared/communicated.	Knowledge management is critical as part of the product management lifecycle. Lessons learned are critical.

Lessons Learned and Change Management

One of the hallmarks of a quality culture is learning from our past experiences, to eliminate repeat mistakes and to reproduce success. The more times you do an activity, the more you learn, and the better you get (within limits for simple activities). Knowledge management is an enabler of quality systems, in part, to focus on learning and thus accelerate learning across the organization as a whole, and not just one person or a team.

This is where the” lessons learned” process comes in. There are a lot of definitions of lessons learned out there, but the definition I keep returning to is that a lessons learned is a change in personal or organizational behavior as a result from learning from experience. Ideally, this is a permanent, institutionalized change, and this is often where our quality systems can really drive continuous improvement.

Lessons learned is activity to lessons identified to updated processes — Lessons Learned

Part of Knowledge Management

The lessons learned process is an application of knowledge management.

Lessons identified is generate, assess, and share.

Updated processes (and documents) is contextualize, apply and update.

Lessons Learned in the Context of Knowledge Management

Identify Lessons Learned

Identifying lessons needs to be done regularly, the closer to actual change management and control activities the better. The formality of this exercise depends on the scale of the change. There are basically a few major forms:

After action reviews: held daily (or other regular cycle) for high intensity learning. Tends to be very focused on questions of the day.
Retrospective: Held at specific periods (for example project gates or change control status changes. Tends to have a specific focus on a single project.
Consistency discussions: Held periodically among a community of practice, such as quality reviewers or multiple site process owners. This form looks holistically at all changes over a period of time (weekly, monthly, quarterly). Very effective when linked to a set of leading and lagging indicators.
Incident and events: Deviations happen. Make sure you learn the lessons and implement solutions.

The chosen formality should be based on the level of change. A healthy organization will be utilizing all of these.

Level of Change	Form of Lesson Learned
Transactional	Consistency discussion After action (when things go wrong)
Organizational	Retrospective After action (weekly, daily as needed)
Transformational	Retrospective After action (daily)

Successful lessons learned:

Are based on solid performance data: Based on facts and the analysis of facts.
Look at positive and negative experiences.
Refer back to the change management process, objectives of the change, and other success criteria
Separate experience from opinion as much as possible. A lesson arises from actual experience and is an objective reflection on the results.
Generate distinct lessons from which others can learn and take action. A good action avoids generalities.

In practice there are a lot of similarities between the techniques to facilitate a good lessons learned and a root cause analysis. Start with a good core of questions, starting with the what:

What were some of the key issues?
What were the success factors?
What worked well?
What did not work well?
What were the challenges and pitfalls?
What would you approach differently if you ever did this again?

From these what questions, we can continue to narrow in on the learnings by asking why and how questions. Ask open questions, and utilize all the techniques of root cause analysis here.

Then once you are at (or close) to a defined issue for the learning (a root cause), ask a future-tense question to make it actionable, such as:

What would your advice be for someone doing this in the future?
What would you do next time?

Press for specifics. if it is not actionable it is not really a learning.

Update the Process

Learning implies memory, and an organization’s memories usually require procedures, job aids and other tools to be updated and created. In short, lessons should evolve your process. This is often the responsibility of the change management process owner. You need to make sure the lesson actually takes hold.

Differences between effectiveness reviews and lesson’s learned

There are three things to answer in every change

Was the change effective – did it meet the intended purposes
Did the change have any unexpected effects
What can we learn from this change for the next change?

Effectiveness reviews are 1 and 2 (based on a risk based approach) while lessons learned is 3. Lessons learned contributes to the health of the system and drives continuous improvements in the how we make changes.

Citations

Lesson learned management model for solving incidents. (2017). 2017 12th Iberian Conference on Information Systems and Technologies (CISTI), Information Systems and Technologies (CISTI), 2017 12th Iberian Conference On, 1.
Fowlin, J. j & Cennamo, K. (2017). Approaching Knowledge Management Through the Lens of the Knowledge Life Cycle: a Case Study Investigation. TechTrends: Linking Research & Practice to Improve Learning, 61(1), 55–64.
Michell, V., & McKenzie, J. (2017). Lessons learned: Structuring knowledge codification and abstraction to provide meaningful information for learning. VINE: The Journal of Information & Knowledge Management Systems, 47(3), 411–428.
Milton, N. J. (2010). The Lessons Learned Handbook : Practical Approaches to Learning From Experience. Burlington: Chandos Publishing.
Paul R. Carlile. (2004). Transferring, Translating, and Transforming: An Integrative Framework for Managing Knowledge across Boundaries. Organization Science, (5), 555.
Secchi, P. (Ed.) (1999). Proceedings of Alerts and Lessons Learned: An Effective way to prevent failures and problems. Technical Report WPP-167. Noordwijk, The Netherlands: ESTEC

Change Management – Post Change Evaluation and Action

In “Change Management – Post Change Evaluation and Action” John Hunter (of CuriousCat) writes a nice post on the The W. Edwards Deming Institute Blog on linking change management to the PDSA (PDCA) lifecycle focusing on Act.

Post Change Evaluation is often called the effectiveness review, and is a critical part of change in the pharmaceutical quality system, and frankly is important no matter the industry.

An effectiveness review is the success criteria of the change viewed over enough data points based on a methodology informed by the nature of the change and risk.

The success criteria should be achieved. If not, reasons why they have not been achieved should be assessed along with the mitigation steps to address the reasons why, including reverting to the previous operating state where appropriate. This may require the proposal of a subsequent change or amendment of the implementation plan to ensure success. Here we see the loop aspects of the PDSA lifecycle.

All changes should have a way back into knowledge management. The knowledge gathered from implementation of the change should be shared with the development function and other locations, as appropriate, to ensure that learning can be applied in products under development or to similar products manufactured at the same or other locations.

When choosing success criteria always strive for leading indicators that tell you how the change is working. Deviations are an awful way to judge the effectiveness of the change. Instead look for walkthroughs, checklists, audits, data gathering. Direct observation and real-time gathering and analysis of data of any sort is the best.

As mentioned above, ensure the change management/change control system is set up to deal with the inevitable change that does not work. Have a clear set of instructions on how to make that decision (returning to the success criteria), what steps to take to mitigate and what to do next. For example having guidance of when to create a deviation and on how to make a decision to rollback versus implement another change.