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Saturday, October the 10, 2015
Quality Metrics & Science
Habib University, Karachi
Obaid Ali & Roohi B. Obaid
Civil Service Officers at Drugs Regulatory Authority of Pakistan
1 Math, Statistics and Computer in Quality Science
2Cultural Scores and Site Performance for key Quality Metrics
5 Quality is everyone's responsibility
6Closing words - Simple, clear and loud
3 Essential Attributes for Culture of Quality
4Roots and Principle of Quality Culture
Where everyone willingly takes
responsibility for patient protection and
quality of product
Where patient is centre of everything
Econometrics
Pharmacometrics
Chemometrics
Science
Rational
Data Integrity – Deviant Behaviors
Not
recording
activities
contempor
aneously
Backdating
Fabricating
data
Copying
existing
data as
new data
Re-running
samples
Discarding
data
Alicia M. Mozzachio, July 2014, FDLI, Washington DC
Trends help indeed to understand and predict
Lets have a visit to some slides of US-FDA
Time 
ProcessParameter
Lower Specification Limit (LSL)
Upper Specification Limit (USL)
today
Uncertainty
RISK: For a given severity of risk event, what are the chances (probability) of exceeding the USL in the next period of time?
G. Claycamp, FDA, Sept. 2005
Tomorrow ?
ProcessParameter
Lower Specification Limit (LSL)
Upper Specification Limit (USL)
Uncertainty
Tomorrow ?
G. Claycamp, FDA, Sept. 2005
RISK: Control options are scenarios for risk management. Note that this scenario shows the best estimate is below the USL.
Time  today
Time 
ProcessParameter
Lower Specification Limit (LSL)
Upper Specification Limit (USL)
today
Uncertainty
Take a cut at a moment in time:
Risk has a distribution.
Tomorrow ?
G. Claycamp, FDA, Sept. 2005
Quality
Metrics
Indicator of
operational reliability Quality Culture
Quality
Metrics
Lot
Acceptanc
e Rate
Product
Quality
Complaint
Rate
Right first
time Rate
Invalidate
d OOS
Rate
APR or
PQR on
time Rate
CAPA
Rate
Ability to
initiate
voluntary
CAPA
Lots rejected/total lots in a year
Lot Acceptance Rate
Lot Acceptance Rate
4/355=
Deviated lots/ total lots
in a year
Right First Time Rate
38/355=
Right First Time Rate
APR triggered CAPA/ total
number of APRs
Corrective & Preventive Action (CAPA) Rate
Corrective & Preventive Action (CAPA) Rate
3/30=
Process capability or
performance index for each
critical quality attribute that
triggers a CAPA
Ability to initiate voluntary CAPA
Ability to initiate voluntary CAPA
Cp value
The number of batches for which
complaint received/ total number of
batches (very specific to the product)
Product Quality Complaint Rate
Product Quality Complaint Rate
6/30=
Invalidated initial OOS tests /
total number of tests in a year
Invalidated OOS Rate
Invalidated OOS Rate
200/9900=
The number of APRS within
30 days of annual due date /
the total number of products
produced during the year
APR or PQR on time Rate
APR or PQR on time Rate
05/40=
Cultural Scores & Site Performance Key Quality Metrics
Pharmaceutical OnlineKen Congdon, 26 May 2015
Stronger culture is correlated with
fewer action limit excursions in steriles
1/4 ISPE
Cultural Scores & Site Performance Key Quality Metrics
Pharmaceutical OnlineKen Congdon, 26 May 2015
Stronger culture scores are associated
with higher lot acceptance
2/4 ISPE
Cultural Scores & Site Performance Key Quality Metrics
Pharmaceutical OnlineKen Congdon, 26 May 2015
Sites with higher quality culture scores
have lower deviations recurrence
3/4 ISPE
Cultural Scores & Site Performance Key Quality Metrics
Pharmaceutical OnlineKen Congdon, 26 May 2015
Sites with higher quality culture scores
have higher CAPA effectiveness
4/4 ISPE
Identified Essential Attributes for Culture of Quality
Harvard Business ReviewSurvey April 2014
Leadership Emphasis
Message Credibility
Peer Involvement
Employee Ownership
Identified Essential Attributes for Culture of Quality
Harvard Business ReviewSurvey April 2014
Maintaining a leadership emphasis on quality
What they say & What they do
1/4
Even when executives have the best intentions, there are
often gaps b/w
What they say & What they do
As a result, employees get mixed messages about
whether quality is truly important. Company leaders must
first buy into quality improvement initiatives and clearly
demonstrate their own personal commitment to this effort
to employees
Identified Essential Attributes for Culture of Quality
Harvard Business ReviewSurvey April 2014
Ensuring Message Credibility
One Message
2/4
Quality messaging should be tailored in such a
way that it resonates with every employee.
Different messages may need to be developed to
resonate appropriately with employees at
different sites.
The key is to regularly test these messages with
employees, solicit their feedback, and refresh
these messages over time if necessary
Identified Essential Attributes for Culture of Quality
Harvard Business ReviewSurvey April 2014
Encouraging Peer Involvement
Participation
3/4
A variety of different tactics can be used to
create positive social pressure that encourages
employees to participate in (& even generate)
quality initiatives. These can include friendly
“quality competitions”.
The key is to test these tactics and solicit
feedback to see which are most effective with
employees.
Identified Essential Attributes for Culture of Quality
Harvard Business ReviewSurvey April 2014
Increasing Ownership & Empowerment
Engage in Decisions
4/4
Employees should be free to apply their own
judgment to situations that fall outside the
common directive. Providing the right level of
guidance is crucial to this effort
but they must know how to act when they
encounter specific quality issues.
Visible Signals of Quality Culture
Right tone at the top
Focus on the right
value
Constant display of
putting patient
above everything
Constant display of
concern for quality
Consistently
walks the talk
With great
people skill
& strong
value
More than
financial
rewards
Roots of Strong Quality Culture
Introduction of Improvement & Innovation for quality driven
productivity
Adaptation & Investment in Technology to ensure state of control
over system
Promotion of change & continuous improvement in Quality
System
Roots of Strong Quality Culture
Prompt adaptation of best practice, low staff rotation
Proactive & transparent behavior
Strong relationship based on dialogue, science & mutual respect
Principle of Quality Culture
Product & Process Understanding Sensible Business Management
Sufficient depth of science to
explain why deviations have
not impacted on quality of
product
Too fast growth & operating at
limit of capacity triggers often
issues & non-compliance
How mature is your quality system
1 2 3 4
Level
Richard L. Friedman, FDLI Workshop Washington DC, July 2014US-FDA
Small problems ultimately snowball into larger ones, and
management becomes aware only when there is a crisis
How mature is your quality system
1 2 3 4
Level
Richard L. Friedman, FDLI Workshop Washington DC, July 2014US-FDA
Nearly always reactive, but there is willingness to change.
Patchwork corrections are the norm
How mature is your quality system
1 2 3 4
Level
Richard L. Friedman, FDLI Workshop Washington DC, July 2014US-FDA
More proactive. Increasingly detects emerging adverse trends,
surfaces major issues, and makes lasting manufacturing and
system improvements
How mature is your quality system
1 2 3 4
Level
Richard L. Friedman, FDLI Workshop Washington DC, July 2014US-FDA
Routinely acts preventively as described in level 3. Fully
institutionalizes and reinforces (rewards) a vigilant culture that
makes meaningful manufacturing and systemic improvements
Systems Thinking
System is the product of interacting parts
Improving the parts taken separately will
not improve the system
Quality is everyone’s responsibility
Selected Quotes, W. Edwards Deming
Lack of
knowledge …
that is the
problem
If you do not
know how to ask
the right
question, you
discover nothing
If you can’t describe
what you are doing as
a process, you don’t
know what you are
doing
Rational behavior
requires theory.
Reactive behavior
requires only reflex
action
Whenever there
is fear, you will
get wrong
figures
Learning is not compulsory … neither is survival
Strong Quality Culture Efficient Quality System Consistent manufacturing
It’s the culture that decides the path
Poor Quality Culture Unreliable Quality System Defects and Recall
Soft gelatin capsule Paracetamol tablet
Pyrimethamine tragedy Metronidazole label
Disintegration
failure
Dissolution
failure
Materialmix
up
LabelMixup
One of the important
Hormonal Product
Contract
manufacturing
Changed in
color
Stability was
not done
Quality Agreement
Batch of 1
million tablets
22 batches Underweight
Caught after 2
weeks
System ???
or culture ???
Antibiotic &
steroid
cream
Analytical
method
unable to
quantify
Manipulated
method used
for years
Ended up
with
withdrawal
of product
from market
Lets Look Around …
09 Oct, 2015, Tab Paracetamol - USA
Tablet Paracetamol
Wrongly labeled
325 mg instead of 500 mg
175 mg additional than claimed
What do you think what
should be the action?
End up with recall
Aug 2015
Puerto Rico &
Taiwan
Wood
fragments
found in
toothpaste
3.9 M tubes
recalled
Attix Canada April 2015
Attix Canada April 2015
Health Canada ….
FDA closed an API
repackager in Toronto
recall hundreds of
bulk APIs … cross-
contaminated by
penicillin
failed to use separate
facilities, or
equipment like hoods
and air handlers
cross-contamination
… employees move
freely b/w the
different areas
Attix stance: We have
carefully cleaned
everything before use
Regulatory Stance:
Cleaning is not a
substitute for
segregating products
Cross-contamination
with sensitizing agents
can initiate life-
threatening allergic
reactions
No safe level of
penicillin
contamination has
been determined to be
a tolerable risk
Attix Canada April 2015
Philippines-
Aug 2014
GMP non-
compliance in
Italy
Tetrahydrozoli
ne HCl RM
Used in
manufacturing
of ophthalmic
solution in
China
Phillippines
instructed
discontinuatio
n of
distribution,
sale & use
Many lots
recalled
Do you calculate a
cost of poor quality
at your site?
ISPE/PDA Survey Sep 2011
Have you evaluated the
cost of improving quality
vs. the cost of failure
(recalls, rejections, low
yield, downtime etc)?
ISPE/PDA Survey Sep 2011
Lets make it simple, clear & loud
Me, my kids &
parents use same
drug which I
manufacture
No batch has ever
failed
Drug manufactured in non-cGMP
environment
It does not mean that there is necessarily
something wrong with the drug
But “intention in question”
Please remember
Lack of adverse event reports, or
“something is wrong” is NOT the same
as evidence of no harm….
Closing words
Innocence
• Quality
mainly
outsourced
to regulators
Awareness
• Quality unit
will identify
the issue
Understanding
• Quality
system &
Metrics
reveals
reality &
drives action
Competence
• Quality
mind set in
all functions.
Design
quality in &
anticipate
issues
Excellence
• Competitive
advantage
through
prevention
of quality
issues
Journey of uncertainty to certainty matters
Linkage
Science &
compliance
Challenge
Traditional
validation &
continuous
verification
Maintain
Process
robustness &
drives
reliability
Product & Process
Criticality
Culture of Quality
beyond complianceNew technology
Even a great quality system will fail, if the
Quality Culture
is not equal standard
The question isn’t whether we will have standards …
The question is how useful can we make standards

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5 of 5 Quality Metrics & Science by Obaid Ali

  • 1. Saturday, October the 10, 2015 Quality Metrics & Science Habib University, Karachi Obaid Ali & Roohi B. Obaid Civil Service Officers at Drugs Regulatory Authority of Pakistan
  • 2. 1 Math, Statistics and Computer in Quality Science 2Cultural Scores and Site Performance for key Quality Metrics 5 Quality is everyone's responsibility 6Closing words - Simple, clear and loud 3 Essential Attributes for Culture of Quality 4Roots and Principle of Quality Culture
  • 3. Where everyone willingly takes responsibility for patient protection and quality of product Where patient is centre of everything
  • 5.
  • 6.
  • 7.
  • 8. Data Integrity – Deviant Behaviors Not recording activities contempor aneously Backdating Fabricating data Copying existing data as new data Re-running samples Discarding data Alicia M. Mozzachio, July 2014, FDLI, Washington DC
  • 9.
  • 10. Trends help indeed to understand and predict Lets have a visit to some slides of US-FDA
  • 11. Time  ProcessParameter Lower Specification Limit (LSL) Upper Specification Limit (USL) today Uncertainty RISK: For a given severity of risk event, what are the chances (probability) of exceeding the USL in the next period of time? G. Claycamp, FDA, Sept. 2005 Tomorrow ?
  • 12. ProcessParameter Lower Specification Limit (LSL) Upper Specification Limit (USL) Uncertainty Tomorrow ? G. Claycamp, FDA, Sept. 2005 RISK: Control options are scenarios for risk management. Note that this scenario shows the best estimate is below the USL. Time  today
  • 13. Time  ProcessParameter Lower Specification Limit (LSL) Upper Specification Limit (USL) today Uncertainty Take a cut at a moment in time: Risk has a distribution. Tomorrow ? G. Claycamp, FDA, Sept. 2005
  • 15. Quality Metrics Lot Acceptanc e Rate Product Quality Complaint Rate Right first time Rate Invalidate d OOS Rate APR or PQR on time Rate CAPA Rate Ability to initiate voluntary CAPA
  • 16. Lots rejected/total lots in a year Lot Acceptance Rate
  • 18. Deviated lots/ total lots in a year Right First Time Rate
  • 20. APR triggered CAPA/ total number of APRs Corrective & Preventive Action (CAPA) Rate
  • 21. Corrective & Preventive Action (CAPA) Rate 3/30=
  • 22. Process capability or performance index for each critical quality attribute that triggers a CAPA Ability to initiate voluntary CAPA
  • 23. Ability to initiate voluntary CAPA Cp value
  • 24. The number of batches for which complaint received/ total number of batches (very specific to the product) Product Quality Complaint Rate
  • 26. Invalidated initial OOS tests / total number of tests in a year Invalidated OOS Rate
  • 28. The number of APRS within 30 days of annual due date / the total number of products produced during the year APR or PQR on time Rate
  • 29. APR or PQR on time Rate 05/40=
  • 30. Cultural Scores & Site Performance Key Quality Metrics Pharmaceutical OnlineKen Congdon, 26 May 2015 Stronger culture is correlated with fewer action limit excursions in steriles 1/4 ISPE
  • 31. Cultural Scores & Site Performance Key Quality Metrics Pharmaceutical OnlineKen Congdon, 26 May 2015 Stronger culture scores are associated with higher lot acceptance 2/4 ISPE
  • 32. Cultural Scores & Site Performance Key Quality Metrics Pharmaceutical OnlineKen Congdon, 26 May 2015 Sites with higher quality culture scores have lower deviations recurrence 3/4 ISPE
  • 33. Cultural Scores & Site Performance Key Quality Metrics Pharmaceutical OnlineKen Congdon, 26 May 2015 Sites with higher quality culture scores have higher CAPA effectiveness 4/4 ISPE
  • 34. Identified Essential Attributes for Culture of Quality Harvard Business ReviewSurvey April 2014 Leadership Emphasis Message Credibility Peer Involvement Employee Ownership
  • 35. Identified Essential Attributes for Culture of Quality Harvard Business ReviewSurvey April 2014 Maintaining a leadership emphasis on quality What they say & What they do 1/4
  • 36. Even when executives have the best intentions, there are often gaps b/w What they say & What they do As a result, employees get mixed messages about whether quality is truly important. Company leaders must first buy into quality improvement initiatives and clearly demonstrate their own personal commitment to this effort to employees
  • 37. Identified Essential Attributes for Culture of Quality Harvard Business ReviewSurvey April 2014 Ensuring Message Credibility One Message 2/4
  • 38. Quality messaging should be tailored in such a way that it resonates with every employee. Different messages may need to be developed to resonate appropriately with employees at different sites. The key is to regularly test these messages with employees, solicit their feedback, and refresh these messages over time if necessary
  • 39. Identified Essential Attributes for Culture of Quality Harvard Business ReviewSurvey April 2014 Encouraging Peer Involvement Participation 3/4
  • 40. A variety of different tactics can be used to create positive social pressure that encourages employees to participate in (& even generate) quality initiatives. These can include friendly “quality competitions”. The key is to test these tactics and solicit feedback to see which are most effective with employees.
  • 41. Identified Essential Attributes for Culture of Quality Harvard Business ReviewSurvey April 2014 Increasing Ownership & Empowerment Engage in Decisions 4/4
  • 42. Employees should be free to apply their own judgment to situations that fall outside the common directive. Providing the right level of guidance is crucial to this effort but they must know how to act when they encounter specific quality issues.
  • 43. Visible Signals of Quality Culture Right tone at the top Focus on the right value Constant display of putting patient above everything Constant display of concern for quality Consistently walks the talk With great people skill & strong value More than financial rewards
  • 44. Roots of Strong Quality Culture Introduction of Improvement & Innovation for quality driven productivity Adaptation & Investment in Technology to ensure state of control over system Promotion of change & continuous improvement in Quality System
  • 45. Roots of Strong Quality Culture Prompt adaptation of best practice, low staff rotation Proactive & transparent behavior Strong relationship based on dialogue, science & mutual respect
  • 46. Principle of Quality Culture Product & Process Understanding Sensible Business Management Sufficient depth of science to explain why deviations have not impacted on quality of product Too fast growth & operating at limit of capacity triggers often issues & non-compliance
  • 47. How mature is your quality system 1 2 3 4 Level Richard L. Friedman, FDLI Workshop Washington DC, July 2014US-FDA Small problems ultimately snowball into larger ones, and management becomes aware only when there is a crisis
  • 48. How mature is your quality system 1 2 3 4 Level Richard L. Friedman, FDLI Workshop Washington DC, July 2014US-FDA Nearly always reactive, but there is willingness to change. Patchwork corrections are the norm
  • 49. How mature is your quality system 1 2 3 4 Level Richard L. Friedman, FDLI Workshop Washington DC, July 2014US-FDA More proactive. Increasingly detects emerging adverse trends, surfaces major issues, and makes lasting manufacturing and system improvements
  • 50. How mature is your quality system 1 2 3 4 Level Richard L. Friedman, FDLI Workshop Washington DC, July 2014US-FDA Routinely acts preventively as described in level 3. Fully institutionalizes and reinforces (rewards) a vigilant culture that makes meaningful manufacturing and systemic improvements
  • 51. Systems Thinking System is the product of interacting parts Improving the parts taken separately will not improve the system
  • 52. Quality is everyone’s responsibility Selected Quotes, W. Edwards Deming Lack of knowledge … that is the problem If you do not know how to ask the right question, you discover nothing If you can’t describe what you are doing as a process, you don’t know what you are doing Rational behavior requires theory. Reactive behavior requires only reflex action Whenever there is fear, you will get wrong figures Learning is not compulsory … neither is survival
  • 53. Strong Quality Culture Efficient Quality System Consistent manufacturing It’s the culture that decides the path Poor Quality Culture Unreliable Quality System Defects and Recall
  • 54.
  • 55. Soft gelatin capsule Paracetamol tablet Pyrimethamine tragedy Metronidazole label
  • 57. One of the important Hormonal Product
  • 60. Batch of 1 million tablets 22 batches Underweight Caught after 2 weeks System ??? or culture ???
  • 61. Antibiotic & steroid cream Analytical method unable to quantify Manipulated method used for years Ended up with withdrawal of product from market
  • 63. 09 Oct, 2015, Tab Paracetamol - USA
  • 64. Tablet Paracetamol Wrongly labeled 325 mg instead of 500 mg 175 mg additional than claimed
  • 65. What do you think what should be the action? End up with recall
  • 66. Aug 2015 Puerto Rico & Taiwan Wood fragments found in toothpaste 3.9 M tubes recalled
  • 69. Health Canada …. FDA closed an API repackager in Toronto recall hundreds of bulk APIs … cross- contaminated by penicillin failed to use separate facilities, or equipment like hoods and air handlers cross-contamination … employees move freely b/w the different areas Attix stance: We have carefully cleaned everything before use Regulatory Stance: Cleaning is not a substitute for segregating products Cross-contamination with sensitizing agents can initiate life- threatening allergic reactions No safe level of penicillin contamination has been determined to be a tolerable risk Attix Canada April 2015
  • 70. Philippines- Aug 2014 GMP non- compliance in Italy Tetrahydrozoli ne HCl RM Used in manufacturing of ophthalmic solution in China Phillippines instructed discontinuatio n of distribution, sale & use Many lots recalled
  • 71. Do you calculate a cost of poor quality at your site? ISPE/PDA Survey Sep 2011
  • 72. Have you evaluated the cost of improving quality vs. the cost of failure (recalls, rejections, low yield, downtime etc)? ISPE/PDA Survey Sep 2011
  • 73. Lets make it simple, clear & loud
  • 74. Me, my kids & parents use same drug which I manufacture No batch has ever failed
  • 75. Drug manufactured in non-cGMP environment It does not mean that there is necessarily something wrong with the drug But “intention in question”
  • 76. Please remember Lack of adverse event reports, or “something is wrong” is NOT the same as evidence of no harm….
  • 78. Innocence • Quality mainly outsourced to regulators Awareness • Quality unit will identify the issue Understanding • Quality system & Metrics reveals reality & drives action Competence • Quality mind set in all functions. Design quality in & anticipate issues Excellence • Competitive advantage through prevention of quality issues Journey of uncertainty to certainty matters
  • 79. Linkage Science & compliance Challenge Traditional validation & continuous verification Maintain Process robustness & drives reliability Product & Process Criticality Culture of Quality beyond complianceNew technology
  • 80. Even a great quality system will fail, if the Quality Culture is not equal standard
  • 81. The question isn’t whether we will have standards … The question is how useful can we make standards