This is a slide deck that starts to help those in the pharmaceutical research industry begin to understand the key differences between QC and QA. The presentation also delineates the different levels of QC and the types of QA audits. The presentation also touches on the do's and don't's of conduct during a FDA audit,
2. Twenty years of
industry experience
Clinical RN to Chief
Operating Officer
Patrick R. Ayd MBA, BSN, RN
President/CEO/Lead Auditor
of ClinPharm Network, Inc.
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GCP audits & manage
Site QA programs
3. Workshop Goal
Identify the foundational “Building
Blocks” essential to the development of
a Quality Clinical Trial Site
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4. 4
Gain an increased perspective on FDA
expectations during and after an audit
Clarify the differences between Quality
Control (QC) and Quality Assurance (QA)
Comprehend the importance of Standard
Operating Procedures(SOP) in QC and QA
Conduct quality control review on actual
source documents
Workshop Objectives
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Receive a valid quality control (QC) SOP
template
5. Why is a “Quality”
Organization Critical?
Business Development
PI is Solely Responsible
Data Acceptability
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6. Quality Control Definition
Verifying and maintaining a desired
level of quality in an existing product
or service by careful planning, use of
proper tools, continued inspection,
and corrective action as required
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7. Quality Assurance Definition
A system for ensuring a desired level
of quality in the development,
production, or delivery of products and
services with continued inspection, and
corrective action as required
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9. Key to Good Quality Control
Formal, Well
Documented
Process
Documentation
of QC Performed
Ink Stamp
Procedure
Involve Staff
In Process
Quality Control
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10. Varying Degrees of Quality Control
(W)Hole
Checking
Consistent
Data
Believable
Data
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12. Quality Control
Standard Operating Procedure
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Define WHO will conduct the QC process
Define WHEN the QC process will be completed
What documents will be QC’d 100% of the time
The % of other documents that will be QC’d
Do not alter/modify sponsor provided or sites’ source
documents
Precisely describe the documentation process
Use the lower right reverse side method
Use “unusual” ink color for stamp
Flag documents that have problems
Do not stamp documents until complete problem resolution
15. Quality Assurance Definition
A system for ensuring a desired level
of quality in the development,
production, or delivery of products and
services with continued inspection, and
corrective action as required
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24. Documentation of a Quality
Assurance Program
Binder that keeps all information
in one place
Protected QA Documents
Audit Reports
CAPA Plans
Audit Certificates
Reviewer of all SOPs
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25. Perspective on an FDA Audit
During an Audit
Organized
regulatory binders
Organized patient
charts
Organizational chart
Training records
After an Audit
No more “Further
Avoidance of Same”
Don’t throw anyone under
the bus
Vague terms of changes
made or improvements
Quality Assurance/
Improvement program in
place
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Industry experience spanning 20 years
Have held positions from clinical RN to COO
President/CEO/Lead Auditor of ClinPharm Network, Inc.
Conduct site audits and manage independent Quality Assurance programs
“Take Away”-Solid Quality Control SOP
NO need to click for text to appear
“Take Away”-Solid Quality Control SOP template
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For the obvious reasons
Any Site Owners or PIs in the room??
The PI has to have the confidence that all delegated tasks are being performed as s/he wants them performed
Verifying And Maintaining A Desired Level Of Quality In An Existing Product Or Service by Careful Planning, Use Of Proper Tools, Continued Inspection, and Corrective Action as Required
System For Ensuring A Desired Level Of Quality In The Development, Production, Or Delivery Of Products & Services With Continued Inspection,& Corrective Action as Required
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Formal, Well Documented Process (SOP)
Documentation of QC Performed
Involve Entire Staff in Process
Description of Ink Stamp Procedure-Lower right reverse side method
We’ll discuss further in a bit when we discuss the Quality Control SOP
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This is where team work becomes critical
Whole checking: Is the document whole? Are there any holes that need to be completed i.e. signatures, initials, data, etc.
Believable Data: Does the data make sense i.e. BP 80/120, HR 312, LMP data in a male chart
Consistent Data: Is the data consistent, BP at last visit 102/60, now 140/88, HR changes, no middle initial used prior, now present, etc.
In order to check if certain processes were done correctly you need to have a solid base of SOPs, which includes of course an SOP on the Quality Control process.
Your SOP needs to define
WHO will conduct the QC process
WHEN the QC process will be done (can be different by document, i.e. ICF)
WHAT documents will be QC’d 100% i.e. ICFs
WHAT % of standard documents will be QC’d
HOW the QC process will be documented
Quality Assurance looks at larger processes versus individual completed documents. Is there a system or tools in place to ensure quality?
Report Directly to CEO or Medical Director-based on organizations size and structure
The Quality Assurance person can’t be constantly worried about job stability because of reporting problems or performance issues
For most organizations the answer is to outsource the Quality Assurance function, it’s cheaper and much more effective
Though only 3 blocks, there are 6 basic tenants of a quality organization separate pieces—add Quality Control and Quality Assurance programs
These are must haves in order to run an efficient Quality Assurance program internally or externally
Job Description: Lets the employee know what procedures/tasks they are responsible for
SOPs: Shows employees how the procedures/tasks are performed at our trial site
Training: Train the employees on a regular basis how to perform the procedures/tasks they are responsible for
Performance Evaluation: Lets the employee know how they are performing to the standards that have been set (yes this is a pain)
WITHOUT ALL 4 IT IS DIFFICULT TO CREATE AND IMPLEMENT A CAPA WHEN ISSUES IDENTIFIED BE IT INTERNALLY OR EXTERNALLY IDENTIFIED.
Don’t explain specifics, slides to follow
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Just to list a few, there are many more
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This is just a list of examples. Can you think of any others??
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Click to add Critical Link text after change and training
I have been through 11 FDA audits and have helped “clean up” after another 5.
Spend the money necessary to purchase good binders and section dividers
Don’t rush to recycle binders and section dividers
If a 483 is issued and you respond,
Nothing worse than “your response was unacceptable, no further response required”.