Tag: verification

Subject Matter Expert in Validation

In ASTM E2500, a Subject Matter Expert (SME) is an individual with specialized knowledge and technical understanding of critical aspects of manufacturing systems and equipment. The SME plays a crucial role throughout the project lifecycle, from defining needs to verifying and accepting systems. They are responsible for identifying critical aspects, reviewing system designs, developing verification strategies, and leading quality risk management efforts. SMEs ensure manufacturing systems are designed and verified to meet product quality and patient safety requirements.

In the ASTM E2500 process, the Subject Matter Experts (SME) has several key responsibilities critical to successfully implementing the standard. These responsibilities include:

  1. Definition of Needs: SMEs define the system’s needs and identify critical aspects that impact product quality and patient safety.
  2. Risk Management: SMEs participate in risk management activities, helping to identify, assess, and manage risks throughout the project lifecycle. This includes conducting quality risk analyses and consistently applying risk management principles.
  3. Verification Strategy Development: SMEs are responsible for planning and defining verification strategies. This involves selecting appropriate test methods, defining acceptance criteria, and ensuring that verification activities are aligned with the project’s critical aspects.
  4. System Design Review: SMEs review system designs to ensure they meet specified requirements and address identified risks. This includes participating in design reviews and providing technical input to optimize system functionality and compliance.
  5. Execution of Verification Tests: SMEs lead the execution of verification tests, ensuring that tests are conducted accurately and that results are thoroughly reviewed. They may also leverage vendor documentation and test results as part of the verification process, provided the vendor’s quality system and technical capabilities are deemed acceptable.
  6. Change Management: SMEs play a crucial role in change management, ensuring that any modifications to the system are properly evaluated, documented, and implemented. This helps maintain the system’s validated state and ensures continuous compliance with regulatory requirements.
  7. Continuous Improvement: SMEs are involved in continuous process improvement efforts, using operational and performance data to identify opportunities for enhancements. They also conduct root-cause analyses of failures and implement technically sound improvements based on gained product knowledge and understanding.

These responsibilities highlight the SME’s integral role in ensuring that manufacturing systems are designed, verified, and maintained to meet the highest standards of quality and safety, as outlined in ASTM E2500.

The ASTM E2500 SME is a Process Owner

ASTM E2500 uses the term SME in the same way we discuss process owners, or what is sometimes called product or molecule stewards. The term should probably be changed to reflect the special role of the SME and the relationship with other stakeholders.

A Molecule Steward has a specialized role within pharmaceutical and biotechnology companies and oversees the lifecycle of a specific molecule or drug product. This role involves a range of responsibilities, including:

  1. Technical Expertise: Acting as the subject matter expert per ASTM E2500.
  2. Product Control Strategies: Implementing appropriate product control strategies across development and manufacturing sites based on anticipated needs.
  3. Lifecycle Management: Providing end-to-end accountability for a given molecule, from development to late-stage lifecycle management.

A Molecule Steward ensures a drug product’s successful development, manufacturing, and lifecycle management, maintaining high standards of quality and compliance throughout the process.

The ASTM E2500 SME (Molecule Steward) and Stakeholders

In the ASTM E2500 approach, the Subject Matter Expert (Molecule Steward) collaborates closely with various project players to ensure the successful implementation of manufacturing systems.

Definition of Needs and Requirements

  • Collaboration with Project Teams: SMEs work with project teams from the beginning to define the system’s needs and requirements. This involves identifying critical aspects that impact product quality and patient safety.
  • Input from Multiple Departments: SMEs gather input from different departments, including product/process development, engineering, automation, and validation, to ensure that all critical quality attributes (CQAs) and critical process parameters (CPPs) are considered.

Risk Management

  • Quality Risk Analysis: SMEs lead the quality risk analysis process, collaborating with QA and other stakeholders to identify and assess risks. This helps focus on critical aspects and consistently apply risk management principles.
  • Vendor Collaboration: SMEs often work with vendors to leverage their expertise in conducting risk assessments and ensuring that vendor documentation meets quality requirements.

System Design Review

  • Design Review Meetings: SMEs participate in design review meetings with suppliers and project teams to ensure the system design meets the defined needs and critical aspects. This collaborative effort helps in reducing the need for modifications and repeat tests.
  • Supplier Engagement: SMEs engage with suppliers to ensure their design solutions are understood and integrated into the project. This includes reviewing supplier documentation and ensuring compliance with regulatory requirements.

Verification Strategy Development

  • Developing Verification Plans: SMEs collaborate with QA and engineering teams to develop verification strategies and plans. This involves selecting appropriate test methods, defining acceptance criteria, and ensuring verification activities align with project goals.
  • Execution of Verification Tests: SMEs may work with suppliers to conduct verification tests at the supplier’s site, ensuring that tests are performed accurately and efficiently. This collaboration helps achieve the “right test” at the “right time” objective.

Change Management

  • Managing Changes: SMEs play a crucial role in the change management process, working with project teams to evaluate, document, and implement changes. This ensures that the system remains in a validated state and continues to meet regulatory requirements.
  • Continuous Improvement: SMEs collaborate with other stakeholders to identify opportunities for process improvements and implement changes based on operational and performance data.

Documentation and Communication

  • Clear Communication: SMEs ensure clear communication and documentation of all verification activities and acceptance criteria. This involves working closely with QA to validate all critical aspects and ensure compliance with regulatory standards.

Crafting Good User Requirements

The User Requirements are a foundational document identifying the system’s product and process requirements. These product quality-related user requirements are based on product knowledge (CQAs), process knowledge (CPPs), regulatory requirements, and organization/site quality requirements. Writing a good user requirement for quality requirements involves several critical steps to ensure clarity, specificity, and effectiveness.

Understand the User Needs

Start by thoroughly understanding the user’s needs. This involves engaging with the end users or stakeholders to gather insights about their expectations, pain points, and the context in which the system will be used. This foundational step ensures that the requirements you develop are aligned with actual user needs and business goals.

Be Specific and Use Clear Language

Requirements should be specific and clearly stated to avoid ambiguity. Use simple, direct language and avoid technical jargon unless it is widely understood by all stakeholders. Define all terms and ensure that each requirement is phrased in a way that leaves no room for misinterpretation.

Make Requirements Measurable and Testable

Each requirement should be measurable and testable. This means stating requirements so one can verify whether they have been met. For example, instead of saying, “The system should load fast,” specify, “The system should load within 3 seconds when the number of simultaneous users is less than 10,000”.

Avoid Using Ambiguous Terms

Avoid terms open to interpretation, such as “user-friendly” or “fast.” If such terms are necessary, clearly define what they specifically mean in the context of your project. For instance, “user-friendly” is “the user can complete the desired task with no more than three clicks”.

Use the SMART Criteria

Employ the SMART criteria to ensure that each requirement is Specific, Measurable, Achievable, Relevant, and Time-bound. This approach helps set clear expectations and facilitates easier validation and verification of the requirements.

Make Requirements Concise but Comprehensive

While keeping each requirement concise and to the point is important, ensure all necessary details are included. Each requirement should be complete and provide enough detail for designers and developers to implement without making assumptions.

Prioritize Requirements

Not all requirements are equally important. Prioritize them based on their impact on the users and the business objectives. This helps manage the project scope and focuses on delivering maximum value.

It is good to categorize the user requirements here, such as:

  • Quality
  • Business
  • Health, Safety, and Environmental (HSE)

Review and Validate with Stakeholders

Review the requirements regularly with all stakeholders, including end-users, project managers, developers, and testers. This collaborative approach helps identify gaps or misunderstandings early in the project lifecycle.

Maintain a Living Document

Requirements might evolve as new information emerges or business needs change. Maintain your requirements document as a living document, regularly update it, and communicate changes to all stakeholders.

Use Models and Examples

Where applicable, use diagrams, mock-ups, or prototypes to complement the written requirements. Visual aids can help stakeholders better understand the requirements and provide feedback.

When writing user requirements for quality requirements, it’s crucial to avoid common pitfalls that can lead to misunderstandings, scope creep, and, ultimately, a product that does not meet the needs of the users or stakeholders. Here are some of the most common mistakes to avoid:

Ambiguity and Lack of Clarity

One of the most frequent errors in writing requirements is ambiguity. Requirements should be clear and concise, with no room for interpretation. Using vague terms like “user-friendly” or “fast” without specific definitions can lead to unmet expectations because different people may interpret these terms differently.

Incomplete Requirements

Another common issue is incomplete requirements that do not capture all necessary details or scenarios. This can result in features that do not fully address the users’ needs or require costly revisions later in development.

Overlooking Non-Functional Requirements

Focusing solely on what the system should do (functional requirements) without considering how it should perform (non-functional requirements), such as performance, security, and usability, can jeopardize the system’s effectiveness and user satisfaction.

Failure to Involve Stakeholders

Not involving all relevant stakeholders in the requirements gathering and validation process can lead to missing critical insights or requirements important to different user groups. This often results in a product that does not fully meet the needs of all its users.

Scope Creep

Without a clear definition of scope, projects can suffer from scope creep, where additional features and requirements are added without proper review, leading to delays and budget overruns. It’s important to have a well-defined project scope and a change management process in place.

Not Prioritizing Requirements

Not all requirements are equally important. Failing to prioritize requirements can misallocate resources and efforts on less critical features. Using prioritization techniques like MoSCoW (Must have, Should have, Could have, Won’t have this time) can help manage and focus efforts on what truly matters.

Lack of Validation and Verification

Skipping the validation (ensuring the product meets the intended use and needs of the stakeholders) and verification (ensuring the product meets the specified requirements) processes can lead to a final product not aligned with user needs and expectations.

Poor Documentation and Traceability

Inadequate documentation and lack of traceability can lead to confusion and errors during development. Maintaining detailed documentation and traceability from requirements through to implementation is crucial to ensure consistency and completeness.

Ignoring the Importance of Clear Communication

Effective communication is essential throughout the requirements process. Miscommunication can lead to incorrect or misunderstood requirements being developed. Regular, clear communication and documentation updates are necessary to keep all stakeholders aligned.

 Not Considering the Testing of Requirements

Considering how requirements will be tested during the definition phase is important. This consideration helps ensure that requirements are testable and that the final product will meet them. Planning for testing early can also highlight any potential issues with clarity or feasibility of requirements.