FMEA
FMEA
THE ULTIMATE
GUIDE FOR
SUCCESSFUL RISK
MITIGATION
         By Yan Kugel
                www.qualistery.com
  ABOUT
  QUALISTERY
                                           www.qualistery.com
                                                                 01
   TABLE OF
   CONTENT
1. What is FMEA?
2. Scoring Systems
3. What is ALARP?
5. Congratulation!
                            02
WHAT IS FMEA?
FMEA is a powerful and proactive tool to identify
potential failures in processes or designs. Most
importantly, it allows you to take any scenario and
evaluate how devastating it would be to your
process or the consumer. According to the result,
you can decide how to approach the potential
problem and how much resources you should
allocate to prevent it.
What is FMEA?
You work in the pharmaceutical industry and responsible for the health and safety of the
consumer. You cannot sit idly and wait for unwanted events to occur. Therefore, you must be
proactive and anticipate problems before they happen and minimize the incident’s risk. By
anticipating problems, you can prevent them and prepare for worst-case scenarios that can
severely impact the consumers or the whole business, no matter how unlikely the situations to
happen.
                                                                                      03
                                       WHEN SHOULD YOU USE
                                       FMEA?
  Those three factors (Severity, Occurrence, and detection) give you the power to
  determine which incidents would be the most devastating to your process or the
  consumer.
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                                                                                      04
WHAT TYPES OF FMEA
ARE THERE?
     Two types of FMEA may be relevant
     for you in pharmaceutical
     production.
     You would approach both of the types in the same way. However, the
     consequences and the way you approach the results would be different.
     Therefore, it is essential to understand the difference between them to apply
     them correctly.
 DFMEA
 You would use DFMEA during the design phase of the process. It would help you identify
 problems that could arise from faulty design or technological deficiencies.
 PFMEA
 You would use PFMEA to identify and rank failures in existing processes. In contrast to
 DFMEA, you cannot eliminate failures, as those are part of the designed system. However,
 you can improve the system by addressing the occurrence and detectability.
                                                                                     05
SCORING SYSTEMS
As mentioned above, FMEA evaluates the following parameters of an event:
    Severity (S)
    Occurrence (O)
    Detectability (D)
During the analysis, you would assign numbers to each of the parameters. The higher
the number, the worse is the scenario.
After scoring each of the categories, you will need to multiple the scores. The result
will be a number which is called Risk Priority Number (RPN).
S x O x D= RPN
The value of the RPN will tell you whether the risk is acceptable or not.
But what numbers do you need to assign?
There is no definite system that you must use. Instead, you need to choose a suitable
scoring system for your organization and the process. Therefore, a team of experts
should carefully assign the scoring based on the scientific background, product
knowledge, and experience.
                                                                                         06
Here are several examples of scoring methods that you can refer to:
SEVERITY
Table 1: Traditional ratings for Severity of failure (s)
                                                                                                                07
OCCURRANCE
                  Table 3: Traditional ratings for occurrence of failure (O)
                                    occurrence of failure (O)
                                                                                       Probability of failure (Occurrence)
          <1-1500,000
            1-150,000
                                                                                        Very High: Failure is almost
              1-15000
                                                                                        Inevitable
               1-2000
                1-400
                                                                                        High: repeated failure
>1-2
0 2 4 6 8 10
DETECTION
             Table 3: Traditional ratings for detection (D)
                                                                                     ratings for detection (D)
Criteria: Likelihood of detection
by design control                               Absolute Uncertainty
0 2 4 6 8 10
Now, keep in mind that FMEA was not developed with pharmaceutical
manufacturing in mind. Therefore, having a scoring system with 10 points may not
always be optimal for every case. Especially when there are not enough statistics
to back up the claims. In many instances, people argue for hours whether the
correct score should be seven rather than eight.
                                                                                                                     08
You can learn more about the original scoring system in the article- Failure effects and
resolution of modes: a novel FMEA treatise for finalizing mould designs in foundries.
Detection
              Table 4: Innovative rating for Detection (D) by WHO
                                    High
                                     2
                                                              Description
                                                              Control system in place has a high
   Non existent
                                                              probability of detecting the defect or
                                                 Modrate
        8                                          4          its effects
                                                              Control system in place could detect
                                                              the defect or its effects
                                                              Control system in place has a Low
                                                              probability of detecting the defect or
                                                              its effects
                                                              There is no control system to detect
                                    Low
                                     6                        the defect
 Occurrence
            Table 5: Innovative rating for Occurrence (O) by WHO
                                                                                  Extremely low
                                                                                        2
Description
Improbable to occur
Probable to occur
                                                                                   Moderate
                                                                                      6
                                                                                                        09
Severity
     Table 6: Innovative rating for Severity (S) by WHO                                     Low Moderate
                                                                                             2     4
    Description
This scoring system is excellent for investigating process deviations of aseptic products, as it doesn’t
leave room for error if there is suspicion of patient harm.
Description
As you can see, with this scoring system, it doesn’t matter how low the occurrence and good the
detectability are. If the risk is critical, the RPN will be critical as well. Such scoring is not very common.
                                                                                                            10
Detection
 Table 7: Simplified rating for Detection (D)             3.0
Description 2.5
                                                          0.0
                                                                   High     Moderate       Low
3.0
2.5
         2.0
                                                     Description
         1.5
                                                     LOW: Improbable to occur
         0.0
                 low       Moderate       High
                                                          3.0
 Description
                                                                                                   11
Here are examples of interpretations of the RPN:
Description
To evaluate the scores that fall under ‘Moderate’ and check whether an action is required, you need to
familiarize yourself with the term ALARP.
What is ALARP?
As Low as Reasonably Practicable (ALARP) is a tolerable risk region. It is an acceptable
risk level that you cannot reduce any further without spending resources that are not
proportional to the risk. In other words, the benefit doesn’t justify the invested money,
time, and effort.
The United Kingdom’s parliament introduced this concept in 1974 as part of the Health
and Safety at Work Act, and Its goal is to maintain safe working conditions, eliminating
any risk to the health of the employees. Although ALARP has a work safety connotation,
the concept has spread to different industries worldwide, including engineering, medical
device, and pharma.
  Intolerable risk:           If the risk is in this region, you cannot demonstrate and must take action to
                              reduce the risk whatever the cost is.
  Tolerable risk              If the risk falls in this region, then you must perform a case-specific ALARP
  (if ALARP):                 demonstration.
  Broadly acceptable          If the risk falls in this region, you can demonstrate that you achieved ALARP
  risk:                       by referring to standards and established best practice procedures.
                                                                                                              12
        Intolerable Risk                                                                           100%
                                                       ALARP
Broadly Acceptable Risk                                                                            40%
   Here is how you can use it in combination with an FMEA – You will need to look at the
   events where RPN falls between the acceptable and the not acceptable region (yellow).
   Then, you will want to weigh the consequences of the harmful events against the
   resources you need to invest in lowering the score.
   There are no specific rules that define what risks can stay within the ALARP limit and
   which you must reduce. However, there are some questions you can ask yourself to help
   you reach the right decision:
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 After you have mapped the possible changes that you can make to reduce the risk,
 you and your team must consider:
 If you can prove that the sacrifice in resources is too high compared to the
 reduced risk, you have reached ALARP. Therefore, the risk is tolerable. Otherwise,
 you need to invest the resources and reduce the risk to the broadly acceptable
 area.
  1. At first, You will map your processes and list everything in the column Process
    Step.
 2. Afterward, you will brainstorm everything that could go wrong.
However, for the best results, you should modify the FMEA for your purposes. That way,
it will be easier to stay focused on the goal.
                                                                                       14
Modified FMEA Template (Example Nr. 1- Out-of-Specification Investigation)
You got an out-of-specification result in a final product. Therefore, you would assess
whether it has an impact on the safety and efficacy of the drug. In this case, your
FMEA template would look like that:
EXAMPLE: OOS pH
EXAMPLE: pH 6-8
 In this example, you want to change the supplier of critical raw material. In such
 a case, you would have to assess whether the change may influence the drug
 product. E.g., a different manufacturing method of raw material, packaging,
 transport, etc.                                EXAMPLE: pH 6-9.5
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 Stage 2: Identify the Variables
Here how it would look like in the FMEA table (For simplicity, only steps 1 and 2):
Process Step/input
TIP: Always work as a team and never do an FMEA by yourself. Otherwise, the result will be biassed and inaccurate.
                Therefore, choose five people from different areas of expertise for the best output.
                                                                                                               16
 Stage 3: Brainstorm potential failures
 At this stage, you would sit down with your team and brainstorm anything that can
 go wrong. You can use mind-maps or idea boards before writing the FMEA table’s
 failures to improve the process.
 To keep it simple, let us look at the third step only (Microwave at 1000 mW). In this
 phase, the operator must set the power correctly to the required setting. There are
 at least two possible failures here: The operator sets the capacity too low or too
 high. If he puts it too high, the popcorn will burn. If he sets it too low, the corn kernel
 won’t pop.
   What is the Process               In what ways could the step or              What is the impact on the
  step or feature under                    feature go wrong                      customer if this failure is
      investigation                                                             not prevented or corrected
      TIP: Always work as a team and never do an FMEA by yourself. Otherwise, the result will be biassed and
           inaccurate. Therefore, choose five people from different areas of expertise for the best output.
                                                                                                               17
    Tip: Add additional columns to the FMEA, where you can justify each of your decisions and document them.
    Remember that everyone must understand the results even if he weren’t part of the team. Additionally, even
                           people on the team can forget the reasons for the decisions.
 For this, let’s take a scenario that relates better to the pharma industry, than the
 preparation of popcorn.
 We will look at some of the stages of biotechnological production processes:
          Process
                                                      Values                             Potential Failure mode
         Step/Input
What is the process step or              What are the required                         In what ways could the
      feature under                      Specification                                step or feature go wrong
      investigation?
                                                                                             1.1 Contaminated
                                                                                                culture media
   Purity of the Inoculum                                N/A
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   Now comes the critical part, of assigning the right severity scores to each of the parameters S, O and D.
    Q: What impact would contamination of the inoculum have on the final product and the
    process if you don’t detect the failure in time?
    A: The impact would be severe, and it doesn’t matter what causes it- Material failure or
    medium contamination. Such an event poses a high risk to consumers, as it can harm their
    health. The impact on the process is also severe because even if you detect the issue at a
    later stage, you would need to stop everything and start over. It means that the score
    would be – 3.
                                                                                                                SEVERITY (1-3)
     Step/Input                                             Failure mode                Failure mode
                                                                                    What is the impact on
 What is the process step or    What are the required    In what ways could the    the customer or process
feature under investigation?       Specification            step or feature go        if this failure is not
                                                                  wrong            prevented or corrected?
                                                             1.1 Contaminated
                                                                culture media        Adverse effect on
                                       N/A                                                                           3
   Purity of the Inoculum                                                           health and safety /
                                                                                      interruption of
                                                            1.2 Material Failure
                                                                                         inoculums
                                                                                                               19
      Process                                                        Potential                       Potential
                                                                                                                          Occurrence (1-3)
     Step/Input                         Values
                                                                   Failure mode                       Causes
                                                                                             What Causes the step or
 What is the process step or       What are the required       In what ways could the         feature to go wrong ?
feature under investigation?          Specification               step or feature go          (How could it occur?)
                                                                       wrong?
                                                                                                 1.1 Contamination
                                                                    1.1 Contaminated            during preparation-
                                                                       culture media          Operator doesn’t follow      2
   Purity of the Inoculum                                                                      best practice aseptic
                                          N/A                                                         technique
                    FMEA example: Two possible occurrence rates, depending on the cause of the event.
                Pay attention to the fact, that one failure may have multiple causes. Therefore, it is vital to
                                                 explore all possible options.
 What is the process step           What are the required        In what ways could the        What controls exist that
    or feature under                   Specification                step or feature go         either prevent or detect
     investigation?                                                      wrong?                       the failure?
                                                                     1.1 Contaminated
                                                                        culture media             Macroscopic/
                                            N/A                                                    microscopic                       2
    Purity of the Inoculum
                                                                                                detention methods
                                                                    1.2 Material Failure
                                                                                                                        20
   Now, we have finished investigating one feature in the process. Afterward, you would need
   the same assessment for each step or feature in the process. It may be two more
   assessments, or 1000, depends on your process. Therefore, you need to take each step
   seriously and input the same good amount of energy into it.
   In our example, I have presented two additional steps, which I would leave to you as an
   Exercice:
                                                                                                                                                       Contamination/
                                                                                                 Contamination of final                               Adverse effect on
             Sterility of final bulk                              N/A
                                                                                                         bulk                                         health and safety/
                                                                                                                                                         lot rejection
    Step/Input                                                                                                                                                Controls
                                                                                SEVERITY (1-3)
DETECTION (1-3)
                                                                                                                                                                                  21
   As a reminder, here is the scoring system we have chosen for this example:
                                                                 Description
                                                                  Critical if RPN value >12: Take
                                                                  Immediate action!
  According to this system, one failure has two causes. One is a high-risk cause, while the
  second one is moderate. It means, that we must address both of the issues, although with
  different priorities, or more correctly, with a different endgame in mind.
  What I mean by that, is that we must address the high-risk event (contaminated culture
  media) and find a solution, no matter the cost. On the other hand, we have the Moderate
  Event (Material failure) which we can address through ALARP evaluation. If we can prove
  that we have achieved ALARP, we won’t have to introduce any changes regarding it to
  the system.
  However, it is wise first to address the high risk event, in any case, as the solution may
  reduce the risk for both of the events. And, that’s exactly what we will be doing in the
  next stage.
                                                                                                         22
                      Stage 6: Assigning Corrective and Preventive Actions (CAPAs)
                      In this stage, you need to start thinking about solutions to the problems. Remember, that you
                      cannot influence the severity, therefore you need to concentrate on improving detection
                      and/or reducing the occurrence rate of the event.
                      How can we reduce the RPN score in our case? As I mentioned, microscopic tests are not
                      perfect, so we could introduce better detection methods, such as PCR. Thus, improving the
                      Detection score to 1.
                      Now, let’s take a look at the wonders that one improvement can do:
                                                                           Current                                                                                          Action
                           Potential                                                                                         Action
                                                                                                                                                                                                                OCCURRENCE (1-3)
                                                 OCCURRENCE (1-3)
                                                                                                                                                                                               SEVERITY (1-3)
                            Causes                                                                DETECTION (1-3)         Recommanded
                                                                                                                                                                                                                                   DETECTION (1-3)
                                                                                                                                What are the      Who is responsible    What actions were
                   What Causes the step
                                                                                                                    RPN
                                                                                                                                                                                                                                                     RPN
                                                                    What controls exist that                               recommended actions for making sure the       completed ( and
                   or feature to go wrong                                                                                     for reducing the       actions are       when) with respect to
                                                                    either prevent or detect
                              ?                                                                                           occurrence of the cause   completed?               the RPN
                                                                           the failure?
                    (How could it occur?)                                                                                 or improving detection?
                   And look at that! With one action we managed to reduced the risk of both events!
                   Material failure is now in the green area, and with the purity of inoculum we managed to
                   reduce the risk to an area, where we can explore ALARP.
                                           Tip: When you assign CAPAs, make sure to assign responsible people and think
                                                       about all the required procedures, such as validation.
                                                                                                                                                                                                                23
Stage 7: FMEA Life Cycle
After coming up with CAPAs, you need to ensure that the assigned people perform them on
time.
Make sure you distribute the FMEA as widely as you can to get good feedback about the
results.
However, the FMEA doesn’t rest even when all the CAPAs are closed. You must review each
process regularly and make performance checks to make sure your CAPAs were effective.
Remember, problems don’t go away as soon as you sign a paper. You must actively track
the trends and update the FMEA accordingly.
Congratulation!
You did it! After reading this manual, you should clearly understand what FMEA is and how to
apply it correctly.
However, your journey towards mastery of risk management mastery doesn’t end here. There
are still many tools and approaches you must learn to become a real risk mitigation champion
in your environment! So keep learning and make sure to visit our free GMP webinars.
  1. At first, You will map your processes and list everything in the column Process Step.
 2. Afterward, you will brainstorm everything that could go wrong.
 3. Then, you will assess the impact of the event if it takes place. This will determine the
     event’s Severity (S).
 4. Consequently, you will contemplate the reason for the event’s occurrence and its
     probability. This will determine the Occurrence (O) score.
 5. After that, you will have to review the controls you have to detect the event before it
     happens. This will determine the Detection (D) score.
 6. Finally, you will see multiple scores SxOxD and get your RPN.
 7. You will then determine how to act following your scoring system.
 8. You will then create CAPAs and a follow-up timeline.
 9. Review the FMEA again after a suitable amount of time to make sure no new risks arise.
                                                                                       24
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