Design Problem Solving into the Process

Good processes and systems have ways designed into them to identify when a problem occurs, and ensure it gets the right rigor of problem-solving. A model like Art Smalley’s can be helpful here.

Each and every process should go through the following steps:

  1. Define those problems that should be escalated and those that should not. Everyone working in a process should have the same definition of what is a problem. Often times we end up with a hierarchy of issues that are solved within the process – Level 1 – and those processes that go to a root cause process (deviation/CAPA) – level 2.
  2. Identify the ways to notice a problem. Make the work as visual as possible so it is easier to detect the problem.
  3. Define the escalation method. There should be one clear way to surface a problem. There are many ways to create a signal, but it should be simple, timely, and very clear.

These three elements make up the request for help.

The next two steps make up the response to that request.

  1. Who is the right person to respond? Supervisor? Area management? Process Owner? Quality?
  2. How does the individual respond, and most importantly when? This should be standardized so the other end of that help chain is not wondering whether, when, and in what form that help is going to arrive.

In order for this to work, it is important to identify clear ownership of the problem. There always must be one person clearly accountable, even if only responsible for bits, so they can push the problem forward.

It is easy for problem-solving to stall. So make sure progress is transparent. Knowing what is being worked on, and what is not, is critical.

Prioritization is key. Not every problem needs solving so have a mechanism to ensure the right problems are being solved in the process.

Problem solving within a process

Escalation of Critical Events

Event management systems need to have an escalation mechanism to ensure critical events are quickly elevated to a senior level to ensure organization-wide timely reactions.

Consistent Event Reporting

There are many reasons for a fast escalation.

  • Events that trigger reporting to Regulatory Agencies (e.g. Serious Breach, Urgent Safety Measures (UK), Field Alerts, Biological Product Deviation, Medical Device Report)
  • Events that require immediate action to prevent additional harm from across the organization
  • Events that require marshalling resources from large parts of the organization







         Impact to data integrity

       Impact to product quality/supply

       Impact to data integrity

       Data/privacy breach

       Event impacting on-time compliance rates (not isolated/steady state)

       Impact to data integrity

       Impact to data integrity

       Reference GxP area for Impact resulting from/linked to system error/failure

       Product Quality/ CMC events in accordance with MRB criteria (or other events of similar scope of impact)

       Impact to study integrity

       Impact to subject’s safety, rights or welfare

       Gaps in reporting/ collection of potential AEs

       Impact to study integrity

       Impact to study integrity

       System design, testing, deployment, upgrade, etc. event impacting GxP data integrity or regulatory compliance

       Recurring event with broad scope of impact

       Recurring event with broad scope of impact

       Recurring event with broad scope of impact

       Recurring event with broad scope of impact

       Recurring event with broad scope of impact

       Recurring event with broad scope of impact

       Impact to program milestones & corporate goals

       Impact to program milestones & corporate goals

       Impact to program milestones & corporate goals

       Impact to program milestones & corporate goals

       Impact to program milestones & corporate goals

       Potential Falsified or Counterfeit Product

       Potential Fraud or Misconduct

       Potential Fraud or Misconduct

       Credible Risk of Product Shortage

       Quality event with patient safety risk/gap

       GxP Data Breach

       Potential Product Recall

       Significant Quality Event Notified to Regulatory Authority

       System error or failure with significant GxP compliance impact

·       Potential Critical Finding Resulting from Regulatory Authority Inspection or Audit by External Body/Third Party

·       Quality Event/Observation Classified as Critical (Event or Internal Audit) Notification from Regulatory Authority or other External Authority of Findings of Significant/Critical Quality Deficiency (inspection or other than through inspection)

o   e.g.; Refusal to File, Notification of Inadequate Response to Inspection Findings (e.g.; Other Action Indicated (FDA classification), Warning Letter


You can drill down to a lower, more practical level, like this

Escalation Criteria

Examples of Quality Events for Escalation

Potential to adversely affect quality, safety, efficacy, performance or compliance of product (commercial or clinical)

       Contamination (product, raw material, equipment, micro; environmental)

       Product defect/deviation from process parameters or specification (on file with agencies)

       Significant GMP deviations

       Incorrect/deficient labeling

       Product complaints (significant PC, trends in PCs)

       OOS/OOT (e.g., stability)

Product counterfeiting, tampering, theft

       Product counterfeiting, tampering, theft reportable to Health Authority (HA)

       Lost/stolen IMP

       Fraud or misconduct associated with counterfeiting, tampering, theft

       Potential to impact product supply (e.g., removal, correction, recall)

Product shortage likely to disrupt patient care and/or reportable to HA

       Disruption of product supply due to product quality events, natural disasters (business continuity disruption), OOS impact, capacity constraints

Potential to cause patient harm associated with a product quality event

       Urgent Safety Measure, Serious Breach, Significant Product Compliant, Safety Signal that are determined associated with a product quality event

Significant GMP non-compliance/event

       Non-compliance or non-conformance event with potential to impact product performance meeting specification, safety efficacy or regulatory requirements

Regulatory Compliance Event

       Significant (critical, repeat) regulatory inspection findings, lack of commitment adherence

       Notification of directed/for cause inspection

       Notification of HA correspondence indicating potential regulatory action