P2:
Quality Systems: What Works, What can Ghada Haddad, MBA
be Improved, What Should Change?
Quality Risk Management
Overview
Ghada Haddad
Executive Director, Global cGMP & Compliance Auditing
Organization
Merck & Co., Inc.
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Overview
• Building quality into drug product manufacturing
processes up front is better than testing products
for defects later.
– Risk management is most effective when used
prospectively during product development and
process design,
• Where design and control systems are easily
modified to reduce risks and improve product
quality.
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P2: Quality Systems: What Works, What can Ghada Haddad, MBA
be Improved, What Should Change?
Scope of Quality Risk Management (QRM)
Pharmaceutical companies must deal with general risks and product‐specific risks
General risks Product‐specific risks
What is QRM?
Quality Risk Management:
A systematic process for the assessment,
control, communication and review of risks to
the quality of the drug (medicinal) product
across the product lifecycle. (ICH Q9)
from ICH Q10 Glossary
ICH Q9 describes a wide range of applications of QRM including:
• Quality Management • Regulatory Review • Production Validation
• Change Control • Product Development • Laboratory Control/Stability
• Operations • Facilities/Equipment Studies
• Regulatory Inspection • Materials Management • Packaging 4
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P2: Quality Systems: What Works, What can Ghada Haddad, MBA
be Improved, What Should Change?
QRM Implementation requires Integration into the Pharmaceutical Quality
Systems
The principles and tools of QRM can be applied
throughout the product lifecycle
Benefits of QRM
Ensures limited resources are focused on areas that can have the greatest impact on product safety and performance.
Supports more qualified prioritization decision making
Helps reduce overall cost
Helps provide rationale for not spending time on low risk activities
Helps focusing on ensuring highest quality through Right First Time principles
Ensures decision making is consistent throughout:
Product lifecycle
Product family
Company
Promotes proactive quality, supporting right first time operations:
Is an iterative and continuous process where prior risks that became problems are either mitigated or recognized and reviewed in a
predictive manner for the future.
Provides a framework to better understand processes, what is critical and why?
Provides a mechanism for formal risk communication to management
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P2: Quality Systems: What Works, What can Ghada Haddad, MBA
be Improved, What Should Change?
Current Challenges with QRM
• Bias and high levels of subjectivity in Risk Assessment outputs
• Issues with Tools & Risk Scoring models– e.g. overly complex and
ambiguous
• Non‐robust risk reduction estimation methods
• Problems in arriving at reliable residual risk levels
• Inability to adequately link QRM work with a) GMP controls, b)
Qualification & Validation activities
• Poor understanding of formality in QRM work
• The need for better competencies in risk‐based decision making
“Appropriate use of quality risk management can facilitate but
does not obviate industry’s obligation to comply with regulatory
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requirements.” ICHQ9
Quality Risk Management DOES NOT EQUAL Risk Assessments
The outcomes of risk assessments are highly dependent on technical
knowledge, standard practices/tools & training
QRM Standards (guidelines for scoring definitions and
thresholds for Risk Control decisions)
Role of decision
makers/ management
Role based QRM Consistent QRM Application (competence &
training program authority)
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P2: Quality Systems: What Works, What can Ghada Haddad, MBA
be Improved, What Should Change?
Initiating and Planning QRM Activities
Clearly define the risk question or problem statement, scope and expected
decisions
Identify and gather facts and supporting data (process flows, design documents,
complaints data, SOPs etc.)
Identify facilitator and team of SMEs
Identify risk assessment methodology based on gathered data, scope, expected
outcome
Identify scoring criteria and risk control thresholds
Risk Assessment Tools
“It is important to note that no one tool or set of tools is applicable to every situation in
which a quality risk management procedure is used. ”
‐ ICHQ9 Briefing Pack
Tool(s) selected should be compatible Inappropriate tool selection
with the risk assessment strategy and Risk assessment tools have
ease of input, processing, and output of different strengths and limitations
data Proper understanding of these
strengths and limitations is crucial
Not all risk assessments require a
formal tool Potential risks may not be
Risk assessments may require the identified if the wrong tool is
combination of tools to properly assess selected to address the problem
the problem statement statement
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P2: Quality Systems: What Works, What can Ghada Haddad, MBA
be Improved, What Should Change?
Risk Assessment ‐Risk Identification
The systematic use of information to identify potential sources of harm (hazards) referring to the
risk question or problem description
‐ ICHQ9
Brainstorming
SME Interviews
Flow Charts
Process Mapping
Affinity Diagrams Analysis of Risks from
similar projects
Cause/Effect Diagrams
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Using appropriate rating
schemes & scales
Risk Assessment – Risk Analysis
Estimation of the risk associated with the identified hazards
‐ ICHQ9
What are the consequences?
Can we detect if things
What is the likelihood go wrong?
it will go wrong? 12
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P2: Quality Systems: What Works, What can Ghada Haddad, MBA
be Improved, What Should Change?
Risk Assessment ‐Risk Evaluation
(QRM allows) “Both industry and competent authorities to focus on areas of greatest
risk and understanding of residual risks”
‐ ICHQ9 Briefing Pack
Risk Evaluation compares analyzed risks against defined risk criteria to determine whether
further risk reduction should be explored
Is the risk
acceptable?
What is the level of
risk?
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Risk Control results in a
decision to reduce or accept
Risk Control the risk
Process through which decisions are reached and protective measures are implemented for
reducing risks to, or maintaining risks within acceptable levels
-ICH Q9
Risk reduction focuses on
reducing the probability of
occurrence of harm and/or the Risk Control
severity of harm Risk Reduction
Risk acceptance by the Risk Acceptance
appropriate decision makers and
associated justification must be
documented 14
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P2: Quality Systems: What Works, What can Ghada Haddad, MBA
be Improved, What Should Change?
Risk Communication
• Takes place throughout the risk management
process;
Clear and unambiguous
Structured and standardized.
Convey the appropriate amount of detail and
content to facilitate its purpose
Traceable and auditable for formal risk outputs
Permit recipients to execute their responsibilities
and duties
• Must be directed to the appropriate stakeholders
and management, including Quality;
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In a mature QRM process, QRM is
integrated into the Quality System and
Risk Review‐ Event based and Scheduled review includes event based and scheduled
reviews.nies are on a journey towards
this vision.
Risk management outputs must
be reviewed and updated
periodically to reflect the
current state. Risk review
should consider:
•New knowledge and
experience
•Utilized for planned and
unplanned events
•Reconsideration of risk
acceptance decisions, as
appropriate 16
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P2: Quality Systems: What Works, What can Ghada Haddad, MBA
be Improved, What Should Change?
QRM Application to Systems Across their Lifecycle
PDA Technical Report 54‐5:
Quality Risk Management for the Design, Qualification, and
Operation of Manufacturing Systems
• How QRM might be applied to systems
• Illustrate “how” application be accomplished, using specific
risk tools, control strategies, and mechanisms of utilizing
information from the QRM process.
• Controlling the system critical aspects is crucial to ensuring
product quality and patient safety.
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DRP3
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Slide 18
DRP3 this table is still hard for me to understand. What is this trying to convey?
patelda, 4/16/2018
P2: Quality Systems: What Works, What can Ghada Haddad, MBA
be Improved, What Should Change?
Using QRM to Characterize a System
• Characterizing the system with respect to potential effect on
product quality is an essential step within the system lifecycle.
• Two methods for characterizing a manufacturing system:
Process‐Based Approach‐
Leverages existing process risk assessments
Extracts information needed to design and qualify
systems
System‐Based Approach‐
Performed for each system
Uses a top‐down approach to classify the system,
identify critical aspects and assess design risks
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Characterizing a system – Using Process Based Approach
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P2: Quality Systems: What Works, What can Ghada Haddad, MBA
be Improved, What Should Change?
Characterizing a system – Using System Based Approach
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Developing Commissioning and Qualification Strategy
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P2: Quality Systems: What Works, What can Ghada Haddad, MBA
be Improved, What Should Change?
QRM Integrated into the PQS
Discrepancy Define discrepant events based on the level of risk and prioritize
resources to manage the most critical quality issues
Management
Corrective Manage risks identified within the process as a result of an event
or part of continuous improvement or preventive action
Action/Preventive
identification.
Action
Change Control Evaluate potential impact and effect of implementing a change
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within a system
Define the frequency and scope of audits based on several risk
Audits and Inspections factors
Questions
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