I am often called into companies to identify opportunities for improvement in processes, products and also the Quality Management System as well. These projects give an opportunity to learn how an organisation ticks, its strengths and its weaknesses. Often management initiates the process by giving me their list of systems that they believe are broken or at least not operating as efficiently as they would like. But not always.  They want these worked on but sometimes are reluctant to consider the systems they consider working well.  Or maybe these “working systems” are the ones without the loud squeaky wheel attached.  That is, the one flying under the radar and silently deficient.

I usually take these lists and negotiate with the company that I should look broader than those that they have identified.  That is not to create billable hours but rather because of efficiency. While they may have identified some of the deficient systems, they may not have all.  Also it may be that the ones they consider working well are in fact not working well at all or they may have a system with overkill in place.  Now, if there are some very good systems, you can learn a lot about an organisation if you can understand why some are good and others not.  What causes this?  it can be an uneven management or a pocket of progressive people who are 100% dedicated in the face of adversity.

The key is to bring me in once to identify all the opportunities rather than bring me in twice.  It costs more.  It adds months to the timeline if I have to do it twice.

So what do I usually find?  First, management often does have a good perspective of the “bad” systems.  Often they have identified the very painful ones – the ones in dire need of improvement.  But not always.  This has to be teased out by careful interview of process owners and stakeholders and users alike.  In the interview, it is critical that it is the system that is examined and not the person who runs it.  These people are trying their hardest (in most cases), its just the tools, resources and environment that prevents them from running a successful process.  In 90% of the time it’s not people but the environment they are working in that causes the problem.  Most of these organisations are working at 100 mph with compulsory overtime needed to just get the basics done.  There is no time for future thinking, the fires are burning out of control and there are just not enough firemen to keep the place from burning down to the ground.

What I also find are organisations that are reluctant to change.  The last time somebody took a risk and it failed, they were punished.  You can bet the next time they don’t risk going out on a limb.  When I talk with these folk, I often find processes that are unwieldy, overly complex.  It’s not uncommon to see SOPs of 40, 50, 60 pages long.  No wonder there is a deviation at every turn.  These deviations then flood the investigation system.  With a 30 day to complete the investigation and a backlog, what happens next.  Well, they wait to day 28 or 29 because they are working on other things and are caught between a rock and a hard place.  Got to get it completed or I miss my goal of 30 days.  Get it signed off and off my desk and get the CAPA in place.  And what is the CAPA?  It’s usually retrain operator or rewrite SOP.  These are easy to think up and everybody is familiar with these.

And do you really believe that these two CAPAs are going to work and prevent a recurrence?  Absolutely not.  I was auditing a company recently and over 80% of CAPAs were retrain operator or rewrite SOP and that was for a set of recurring issues that did not go away over a 4 year period.  Complacency had set in.  Are we really that bad at training and writing that it does not solve the problem?  Or is the CAPA not directed at the right thing?  I think we all know the answer.

So what is my job?  First to look at systems and get them into three categories.

1. Ones that are clearly deficient – these need major surgery.  Or they may not even be in place.
2. Ones that are overkill – look for ways to back off what is being done
3. Ones that meet the need – they are adequate although they may not be world class or one that you can proudly say are a 10/10 system.  At this stage, if it works at the right level, leave it. It does not have to be perfect.

Category 1 and 2 need the major work. These systems are really tools in a tool box to allow us to operate our business and these tools have lost the vision of what they were intended.  Instead of serving us to help us get the work done, they take on a life of their own.  These tools now control us and make us jump through hoops.

However, as my father once said, “If you can identify a problem, you are 50% on the way to the solution” And that is when the fun begins with getting these overworked people together to look for opportunity to eliminate non-value added work which will free up resources to put on the other Towering Inferno areas.  And its contagious.  Solve a problem once and the next problem is much easier to solve.

It’s these moments I really cherish.  When I see surgery on an overly complex process that brings a breath of fresh air to the people involved, those are the moments I look forward to.  The look in the eyes of the staff is what this job is all about.  And its fun.

Posted in audits, Clinical Manufacturing, Commercial Manufacturing, GMP, News, Quality Management Systems, Risk Management| Tags: Services, SOPs|Leave a comment

There appears to be a continual debate as to where we need to set the bar for quality and compliance in the Pharma industry.  There are a number of strategies I have seen over the years but they all fall into the following in reality;

1. We will meet what the regulations tell us – no more, no less – it’s what is required.
2. We will exceed what the regulations say – they are minimum requirements – it will give us a business advantage over our competitors.
3. We will not meet the requirements to save money and if we get caught we will pay the price.  It is the cost of doing business.

You can probably guess  which your company fits into.  If not, it might be worth thinking this through because, if they have a different strategy than the one you are comfortable with, it might be a frustrating place to work.

The logic, I believe, these strategies use is the following:

The higher we raise the bar, the more cost it is to operate!

But is that hypothesis true? Does it cost more to operate higher on the curve?  I contend – not necessarily so.

This came out when I was teaching a course on the cost of quality recently and one of the attendees was arguing that in their business, margins were small so everything they spent on quality was directly from the bottom line.  Spend more and profits go down.

While this appears logical on the surface, I do not believe it tells the whole story.  It assumes that money spent on quality to raise the bar is simply an overhead and does not impact anything else.  In other word, spend money on quality and it has no impact on efficiency or losses etc.

Rather, I believe that if you spend money on quality systems, it will result in decrease cost of operation, higher throughput in the plant and will lead to a more efficient operation.  One example might be to improve the way investigations are performed.  This should result in more efficient and effective investigations.  This results in true root causes being identified and hence more effective CAPAs which lead to less repeat deviations.  The improved investigation system would require less resources to operate, be done quicker and hence cost less.  And if the investigation actually got to the root cause the CAPA has a higher probability to prevent repeat observations. That is to name just one system.  You could construct scenarios for complaints, change control, lot disposition and validation with similar conclusions.  I believe investing in quality improvements (raising the bar), should be viewed as an investment rather than an overhead.

It took  about three days in the class before the proverbial light bulb went off in his head.  I don’t know if he will take that message back to the plant and even if he does, will they believe and introduce some of this thought process into their operations.  Time will tell.

Posted in Commercial Manufacturing, GMP, News, Quality Management Systems, Risk Management| Tags: Services|Leave a comment

It’s been about 1 year since the FDA issued its Guidance on Contract Manufacturing.  Based on what I read in blogs and social media like LinkedIn, I am sure not all companies are really up to speed. At an IBC conference recently, I presented a paper on the guidance and putting it into practice.  It was so well received, I was asked to write an article on the topic by Bioprocessing International and here it is.  Good reading!!

Posted in Clinical Manufacturing, Commercial Manufacturing, Contract Manufacturing, FDA Guidance, GMP, News, Quality Agreements, Quality Management Systems, Vendor Qualification| Tags: Services|Leave a comment

One of the clients of a colleague of mine is undergoing a culture change in their operations from the “old-style” quality to a newer style.  What do I mean by that?  The old style is characterized by the Silo mentality, the us versus them, distrust, Quality that can be characterized as a Dr. No approach.  I think you know what I mean.  You may have worked at a company like that in your career.  Actually you can see them and the results in warning letters posted by FDA if you have never experienced this before.  Although all do not end up with warning letters.  Many operate for years this way.

This will be a long journey involving a lot of small steps.  It is not something that happens overnight.

To embark on this type of transformation requires several elements

1. A detailed knowledge of how they work and where there is opportunities for improvement.  A simple gap analysis and interviews (not an audit) will give you the answers you need.  The important thing is that you need management support for the change.  In the interviews, you need the employees to open up and speak honestly.  I pledge that management will see the results of the interviews but not who said what.  It will be sanitized (made anonymous). Trust has to be there.
2. You must have a good interview skill.  If you have gone through Kepner-Tragoe training you are well on the way.  The key is to keep asking why.  If you have kids, you know what that is.  It’s the 6 year olds approach to learning. “Why is xxxx daddy?”  You answer and they respond “Why is YYYY daddy?”
3. You must listen and think how all the outcomes link back to behavior which then links back to the systems that are not working or are in need of improvement.
4. And above all Management support for the change.  They have to understand why the old will not sustain them and the new might and they must create a blame-free culture where speaking out is the norm.

It reminds me of the old realty axiom.

Its all about

Location, Location, Location.

here it is

Management, Management, Management

 

It is these system failures that help you solve things and change culture.  Pick a key system that is not operating well (and everybody knows which ones they are), create a team of owners and customers and start a discussion forum for all to articulate the frustrations.  Don’t let it get to a simple whining event.  List the issues and ask how we might do it differently.  Let each articulate with asking the rest to see if they have contributions.  Facilitation skills are critical at this stage.

These suggestions can then be used by the system owners to revamp the process.  Get the stakeholders in on the review.  The first rendition will not be perfect but I bet it’s better than what was there.

So what is the new Quality style?

Its where Quality is

• Value added
• A facilitator 95% of the time
• Encouraging of partnering
• where user-centric systems, processes, documents are the norm
• where team based approaches are encouraged
• consulted to solve problems.

As you begin the make the changes, it is essential to get to the point where old habits are delearned and new ones embedded.  It is aided when training becomes education and the HOW and the WHAT are alongside the WHY in the training.  People understand why the change has to happen and they buy off on it because they understand why doing it the old way is not as good as the new.  They understand it because they are part of the solution. It was their idea.  They understand the consequences of their actions.  They take ownership.

This is just the beginning.  Watch for more blogs on next steps.  The successes and the set backs.

By the way, the client’s ship has left the harbor.  The captain has charted a new course (and its in the right direction) and the crew are all pulling in the right direction.  Will it be plain sailing?  I doubt it!!  There will be storms and other testing events but the foundations are strong and they are determined.  Tune in to see chapter 2.

So do you see any of the warning signs in your company?  If so, you might want to drop me an email and let’s see what we can do!!!!!!

Posted in Commercial Manufacturing, GMP, News, Quality by Design, Risk Management| Tags: Services, SOPs|Leave a comment

In the first quarter of 2014, 3 Indian companies were issued warning letter (see my posting on the blog) whereas 7 pharmacies were hit.  Statistically significant?  Perhaps.

After the debacle of the New England Compounding Center about a year ago, the FDA has been on a rampage in the Pharmacy world.  I am no lawyer but the way I read it is the pharmacies are using a loophole in the law centered around the  issues of FDA jurisdiction.  FDA basically regulates interstate distribution of drugs, so make a drug in state X and “export” it to state Y – yep FDA has jurisdiction. So the manufacturers of drugs are under FDA rule.

Now, pharmacies are allowed to take these drugs and dispense prescriptions.  So when you go to your corner pharmacist, you can see them dispensing.  Counting out pills and putting them into bottles.  Hardly much risk here so long as they don’t muddle them up, get them cross contaminated  etc.  But they can also do further dispensing.  For instance, they can take a sterile vial or bottle of a drug and dispense it to another sterile container.  Now this is another matter.  What we are describing is aseptic processing.  As we all know that’s a risky business.  How many manufacturers fall foul of the regulations in industry?  The number of warning letters are numerous.

But it seems that FDA can not step in unless there is a demonstrated safety calamity.  But we don’t want to wait for that each and every time.  So what can the FDA do?  Their tack is to inspect these operations when they suspect that the Pharmacy has overstepped their authority.  It seems that in a majority of the 7 letter this quarter they have seen that the pharmacies have been dispensing these aseptically prepared drugs without prescriptions and compounding several drugs together.  Some of these drugs have different regimes of taking the drug.  Ergo, they are no longer dispensing, but manufacturing.

Now when they go in and inspect they cite for lack of GMP adherences and the story goes on.  Call me naive, but if I go to a pharmacy, I want an assurance that the drugs I am receiving are not adulterated.  I don’t care who regulates them but I want it done properly.  Clearly the Boards of Pharmacy have not been doing a good job (they are the ones who regulate at a state level rather than FDA).  What we have here is a standard clash between Federal and state control – we see it every day in other matters but in this case they are using our health as a pawn in the game.

Keep up the good work FDA.

He is the link to the 7 warning letters

Nora Apothecary Services ,  Lowlite Investments DBA Olympia Pharmacy, Pallimed Solutions, Wedgewood Village Pharmacy, Total Pharmacy Services ,Avella of Deer Valley, Village Fertility Pharmacy

Posted in audits, GMP, inspections, News, regulatory citations, Warning Letter| Tags: Services|Leave a comment