© Pharmaceutical Consultancy Services, All rights reserved. Quality System(s)

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Presentation transcript:

© Pharmaceutical Consultancy Services, All rights reserved. Quality System(s)

© Pharmaceutical Consultancy Services, All rights reserved. WHAT IS THAT; QUALITY ? There are multiple understandings, depending from which angle you are answering the question: Logisticallyright time, place and amounts Financiallyright price Technicallyright product! General definition : FITNESS FOR INTENDED USE The client returns (and not the product) 2

© Pharmaceutical Consultancy Services, All rights reserved. WHAT IS THAT; QUALITY ? In our (pharmaceutical) world: Product meets (assured), the requirements as described in the Regulatory Dossier 3

© Pharmaceutical Consultancy Services, All rights reserved. RIGHT…... BUT NOW: WHAT IS A QUALITYSYSTEM? 4

© Pharmaceutical Consultancy Services, All rights reserved. 1 st What does system mean ? (GOOGLED) A group of interacting, interrelated, or interdependent elements forming a complex whole. A condition of harmonious, orderly interaction complex. An organized and coordinated method; a procedure A naturally occurring group of objects or phenomena 5

© Pharmaceutical Consultancy Services, All rights reserved. Ok, so what is a Quality-System ? A Quality System (for us) is an holistic approach: There is no exception (it’s all) Systems People Equipment Buildings/Premises Utilities Products Processes Your companies system should assure that the above assets delivers a product consistent according specification, fit for purpose. 6

© Pharmaceutical Consultancy Services, All rights reserved. Finally, we can define system elements  Documentation  Training  Deviations  Change Management  Equipment Management  Vendor management  Sample management  Out of Specification  Stability  Etc. The above mentioned Quality System Elements should assure that the principle stated in former slide manages the assets properly. 7

© Pharmaceutical Consultancy Services, All rights reserved. QMS or QMS Elements Depending on how you like to call it: The individual items (deviation, training, etc) are called elements of the overall Quality Management System OR the individual item is called a Quality System and the overall is Quality Management Systems OR maybe other views Either way: it should do the job. For now: I use the term Quality System and the individual items elements of the QMS (completely arbitrary) 8

© Pharmaceutical Consultancy Services, All rights reserved. A table with QMS-elements (not limited) 9

© Pharmaceutical Consultancy Services, All rights reserved. US QUALITY SYSTEM APPROACH 10

© Pharmaceutical Consultancy Services, All rights reserved. Q10; QUALITY MANAGEMENT 11

© Pharmaceutical Consultancy Services, All rights reserved. QMS should be supported by the organizational systems Control Systems Organizational Systems Material Control System Production and Process Control System Records and Document Control System Facility and Equipment Control System Laboratory Control System Divergences Control System Validation ……… Responsibilities Management Review Continuous Compliance ………… 12

© Pharmaceutical Consultancy Services, All rights reserved. We are talking about the same system. Depending on where you stand, you might see something else, however it’s still one system. We are talking about the same system. Depending on where you stand, you might see something else, however it’s still one system. DEPENDING FROM WHICH ANGLE YOU WATCH 13

© Pharmaceutical Consultancy Services, All rights reserved. Performance or Quality ? 14 Quality is not a specific Pharmaceutical topic Basic principle: good performance on the QMS-elements delivers a well functioning QMS and as a result: Right Quality Well performing QMS supports short- and long term business objectives. One of the key/mandatory objectives for short- and long term business objective MUST be (in pharma/vaccine world): safety/efficacy/quality for the recipients. GMP requirements MUST be built in, in yours’ QMS. A QMS cannot create miracles (!)

© Pharmaceutical Consultancy Services, All rights reserved. CHANGE CONTROL & DEVIATIONS 15

© Pharmaceutical Consultancy Services, All rights reserved. CHANGES VS. DEVIATIONS "CHANGES" – Normally: planned – Starts: before execution "DEVIATIONS” – Normally: unexpected (unplanned) – Starts during regular work PLANNED DEVIATION vs. TEMPORARILY CHANGE – In English Planned Deviation might be a contradiction, however in other languages completely normal – My personal opinion: it doesn’t much matter how you call it, as long as you arrange it (decently) – Batch Records

© Pharmaceutical Consultancy Services, All rights reserved. CHANGE MANAGEMENT: WHY Preventing undesired changes Careful considerations Planning of associated actions (SOP’s/Validation) Communication of change Correct Documented Change. CONTROLLED PROCESS FOR CHANGE Many ways to manage, e.g. Documentation (wherein the document itself the changes are managed) 17

© Pharmaceutical Consultancy Services, All rights reserved. CHANGE CONTROL SOP RequestAuthorizationExecution Final authorization for Impelementation implementation 18

© Pharmaceutical Consultancy Services, All rights reserved. DEVIATIONS 19

© Pharmaceutical Consultancy Services, All rights reserved. DEVIATIONS 1. Details 2. Correc- tive Action (CA ) 3. Root Cause Analysis 4. Impact Assess- ment 5. Preven- tive Action (PA ) 20

© Pharmaceutical Consultancy Services, All rights reserved. SYSTEM FAILURE INVESTIGATION The process: 1. Documented Deviation – Timely: notification at least within 24 hours 2. Correction 3. Investigation into the root cause 4. Corrective Action(s) (CA), prevent recurrence 5. Scale and seriousness (Impact Assessment) 6. Preventive Action(s) (PA) – Root Root Cause Analysis – Risk Assessments CAPA systeem 21 Industry Practice: close deviations in 30 days

© Pharmaceutical Consultancy Services, All rights reserved. TRAINING 22

© Pharmaceutical Consultancy Services, All rights reserved. TRAINING REQUIREMENTS Or better: knowledge management (?) Per employee Plan (e.g. per year and during induction) CV (Resume) Each training Job Description Traceable Overview for management 23

© Pharmaceutical Consultancy Services, All rights reserved. CONCLUSION 24

© Pharmaceutical Consultancy Services, All rights reserved. Other QMS-Elements Per individual QMS Element Company Requirements Regulatory Requirements Interactions between Requirements and/or Departments and/or Sites 25

© Pharmaceutical Consultancy Services, All rights reserved. Checklist per QMS-Element An example assessment of a QMS, including progress per element 26

© Pharmaceutical Consultancy Services, All rights reserved. TESTING 27

© Pharmaceutical Consultancy Services, All rights reserved. BY HAND RAISING ICH-Q10 (PQS): QMS does function by managing its elements OPTIONS: 1.TRUE 2.NOT-TRUE 3.DON’T KNOW 28

© Pharmaceutical Consultancy Services, All rights reserved. BY HAND RAISING A QMS should be able to coop with ALL possible situations OPTIONS: 1.TRUE 2.NOT-TRUE 3.DON’T KNOW 29

© Pharmaceutical Consultancy Services, All rights reserved. 30 THANK YOU FOR YOUR ATTENTION