“Mind the Gap” – 5 Top Tips for Improved Self-Inspection

Article By Michelle Yeomans Operations Manager for EPiC Auditors

During our time as MHRA Inspectors and now as pharmaceutical consultants, at EPiC we routinely see non-compliant sites i.e., those referred to MHRA’s Inspection Action Group (IAG) with a series of self-inspection reports indicating a high level of compliance. This begs the question why do some self-inspection programmes fail to adequately appraise the effectiveness and applicability of pharmaceutical quality systems (PQS)? 

Here are our top tips on how to avoid gaps between self-inspection and regulators findings: 

1. Remember why you are performing self-inspections Self-inspections are often not taken as seriously as regulatory inspections, but ultimately have the same objective to protect patients and product quality. Self-inspections can help identify and address deficiencies to support maintaining an “inspection ready” status by providing confidence that you as a licence holder are meeting your legal obligations to comply with EU GMP and GDP requirements.   

2. Self-inspection perception – Unless sufficient time and resources are allocated to self-inspection, programmes can become too informal and rushed. Taking the time to objectively evaluate a process, facility, or document should be seen as value adding by providing an opportunity to gather information about compliance and is a way for Senior management including QPs/RPs to have oversight of the performance of all areas of the business.​ 

3. Self-inspection focus – Consider whether audits should be horizontal audits i.e., follow the process flow from goods receipt to product release for example or be focussed on just one area of the process.​ Use a risk-based approach by researching the most common deficiencies found during inspections and audits e.g., consider examples which are published by MHRA, or featured in EPiC Seminar presentations, to ensure “hot topics” are include as an area of focus during the audit. Identify the high-risk areas of the process which will require more of your attention. This can be done by looking at the past performance of the area – deviations, change controls, previous audit findings etc​. 

4. Invest in Auditor training – Audits drive big decisions such as capex, awarding contracts, supplier approval, compliance level assessment, etc. so it is important auditors are trained. This includes having an understanding and ability to apply a broad range of softer behavioural and questioning skills, follow good practice guidance on the principles of auditing, and can demonstrate an understanding of the applicable GXP rules and regulations. 

5. Post audit activity – It’s not all about performing the audit, it is equally important to maintain a focus on CAPA completion and ongoing effectiveness checks. Successful completion of CAPA is integral to achieving the objective to protect patient and product quality and drives sustainable compliance. 

By following these 5 tips, you can improve the effectiveness of self-inspections, ensure that the PQS is continuously improving and “mind the gap” between self-inspection and regulatory findings! 

Get in touch if you want to know more about our bespoke inhouse training course on effective and value adding self-inspection and how we train auditors.  

Call to speak to one of our pharmaceutical consultants: +44 (0)1244 980544 or email us at enquiries@epic-auditors.com

Serious about Making Pharmaceuticals?

Our Directors Richard Andrews and Darren Jones will be joining GMP Healthcare Ltd on stand 220 at this year’s Making Pharmaceuticals Conference in Coventry on the 25th – 26th April 2023.

As the largest Pharmaceutical Event in the UK, it covers everything from Processing, Medical Devices, Regulatory, Clinical Testing, Research & Development, Operational Excellence, Pharmaceutical Quality, Serialisation, Clinical Trial Testing, Ingredients / Excipients, Microbiology, Pharmaceutical Engineering, Packaging & Labelling, New Technologies & Data Management.

We will be on hand to discuss any challenges you are facing and offering our expertise to help pharmaceutical and biotechnology companies, as well as other associated healthcare clients, to achieve and maintain regulatory compliance and excellent pharmaceutical quality systems, to best industry standards.

Registrations are open for your complimentary Exhibition & Conference passes. It will be great to catch up with clients and colleagues old and new. If you are attending, please come along and say hello at the Making Pharmaceuticals Conference!

WE SPECIALISE in helping pharmaceutical and biotechnology companies, as well as other associated healthcare clients, to achieve and maintain regulatory compliance and excellent pharmaceutical quality systems, to best industry standards. As ex MHRA inspectors, we know how the Regulators work and think. No consultants know how the MHRA operates better than we do.  We specialise in mock inspections; GXP audits, supply chain and system audits. We work with large organisations but also have a particular interest in supporting new and expanding small companies including wholesalers; contract laboratories and clinical development laboratories.

Top Tips for Implementing Effective Knowledge Management Practices

Article By Michelle Yeomans Operations Manager for EPiC Auditors

At the EPiC Autumn Compliance Seminar, I delivered a presentation outlining the direction of travel in demonstrating compliance  (Session 1. GMP Seminar 10th November 2022 9am to 10am) which highlighted how global regulators are looking at new ways to be agile and make best use of resources and reduce regulatory complexity.  

The aim is to benefit patients by supporting access to quality medicines by adopting the same requirements for the formats and data expectations in regulatory submissions and applying the same standards in regulatory review, assessment, and inspection to support reliance. Such approaches will require companies to demonstrate effective use of data, knowledge management and to implement a culture of continuous improvement throughout the product lifecycle.

How organisations create, manage, and use knowledge is a key component of an effective Pharmaceutical Quality System (PQS) as defined by ICH Q10. The need to minimise knowledge loss is a primary concern, as loss of knowledge can lead to poor risk-based decision making and inefficiencies in trying to retrieve past knowledge or having to  “reinvent the wheel” to replace lost knowledge.

Hardly a week goes by without seeing a post on LinkedIn from a network connection who is “happy to share” that they are starting a new position. Whilst this is exciting for the individual to be embarking on a new chapter in their career, what can organisations do to minimise the risk of specialist knowledge walking out of the door with them?

Tips for implementing effective knowledge management practices:

1. It’s important to recognise that it is the people and not the data that underpin an organisations’ knowledge base. Compile and maintain a list or matrix of subject matter experts (SMEs) to increase awareness of “go to” people and encourage communication, networking and sharing of past and current knowledge.
2. Don’t wait until someone is working their notice to try to capture all that they know, as there won’t be enough time to transfer valuable knowledge to colleagues. Think about how you can capture and manage knowledge as a continuous improvement activity e.g., capturing and implementing lessons learned and after-action reviews.
3. Advances in technology to support remote collaborative working accelerated during the Covid-19 pandemic and has increased the availability and accessibility of creative tools to capture and share information. Explore what options are available with IT and Data Management colleagues to make use of available tools to help build and improve your knowledge management systems.
4. Asking someone to write down everything they know about a particular product, process, system, operation is a daunting task. People may not be aware of the knowledge they possess or how valuable it is to others. Indecision on what to include could result in a lot of the implicit knowledge remaining in people’s heads and at risk of being lost. As implicit knowledge is often difficult to articulate, transfer of knowledge can be achieved more effectively by encouraging regular interaction with colleagues e.g., networking forums, and sharing practical experiences through coaching and mentoring opportunities.  
5. For knowledge to be usable, it needs to be captured in an effective manner. Consider using a variety of formats to encourage information sharing and capturing knowledge e.g., video recordings, voice notes, whiteboards, story boards etc. Look at how the resulting output could be adopted into workflows, SOPs, Work Instructions, etc. as continuous improvement helping to retain current knowledge and support the development of new knowledge.

The above practical tips are intended to help minimise the risk of knowledge loss and support compliance with the EU GMP requirement to implement quality improvements appropriate to the current level of process and products knowledge (EU GMP Chapter 1, 1.4 (xi)) and ICH Q10 principles.

If you need our help and support, then please don’t hesitate to contact us.

Telephone: +44 (0)1244 980544 or email us at enquiries@epic-auditors.com

Lewis Corbett joins EPiC as Business Manager & Senior Consultant

EPIC Auditors are delighted to announce that Ex MHRA Inspector Lewis Corbett has joined EPiC Auditors as Business Manager and Senior Consultant.

Lewis has over 25 years experience of pharmaceutical manufacture and distribution gained from working within the industry and for the GMP Inspectorate of the UK medicines regulator (MHRA) as a Senior GMP Inspector and Head of GMP Team 1. During his 5 years at the MHRA Lewis had responsibility for the licensing and inspection of pharmaceutical manufacturers and distributors both in the UK and overseas, managing and leading a team of GMP Inspectors, implementing changes to regulations and ways of working as a result of EU Exit, and supporting elements of the agency’s Covid-19 pandemic response. 

Prior to joining the MHRA Inspectorate Lewis spent 22 years working in the pharmaceutical industry in various QC, QA and management roles, and as a Qualified Person for a range of active pharmaceutical ingredients and non-sterile product dosage forms.

Lewis was trained and accredited by the MHRA to inspect:

• API manufacturers, importers and distributors  
• Importation of medicinal products 
• Non-Sterile manufacturing sites   
• Contract laboratories   
• Excipient manufacturers  
• Storage and distribution sites

He has expertise in MHRA and EU Inspection preparation and remediation, Pharmaceutical Quality Management Systems, and training in EU GMP Regulatory requirements and is eligible to act as an EU Qualified Person.

With his wide portfolio of experience, Lewis is a great addition to the core EPiC team and with his help we are confident we can extend our GXP support across the medicinal product lifecycle and help all our clients to improve their GXP quality systems and regulatory compliance.

If you need our help and support from an Ex MHRA Inspector then please contact us on +44 (0)1244 980544 or e mail us at enquiries@epic-auditors.com

EPiC Auditors Autumn Compliance Seminar: Thursday 10th November 2022

Here’s what our seminar speakers have to say about the event;

“A condition of holding an MIA and WDA(H) is that the guidelines on GMP and GDP are complied with. Sustaining the required level of compliance is a must to ensure medicinal products of the right quality are manufactured and distributed and avoid regulatory action. My presentation on Future-proofing compliance will explore what licence holders can and should do to continually improve and not only fulfil but exceed this requirement.” 

Richard Andrews, EPiC Auditors Managing Director & Senior Consultant   

With the deadline for the implementation of Annex1 fast approaching, now is a great time to consider the implications for your sterile processes.  At the EPiC Autumn Compliance Seminar, I will roadmap those areas of the new Annex 1 that may result in many future sterility assurance deficiencies – a roadmap of the hotspots. This session will complement the session from Rick Parker of the MHRA, who will provide the latest MHRA thinking on Annex 1. A great opportunity to get ahead of the Annex 1 changes!

Darren Jones, EPiC Auditors Director & Senior Consultant

To find out more about the seminar and to book your tickets click on the link below:

What was it?

This online seminar was a full day delivered remotely comprising a variety of ex MHRA Inspector speakers with invited guest speaker Richard Parker, Senior GMDP Inspector at the MHRA who will be delivering an MHRA update on Annex 1 with a regulators view of the changes. 

Altogether was a thought-provoking and informative day which aimed to:

• Share recent changes and updates to the GMP and GDP Guidelines and Regulations with particular focus on Annex 1.
• Highlight changes to inspection practices and MHRA oversight.
• Discuss tools and practices to maintain compliance.
• Present current and future Annex 1 deficiencies, along with the pitfalls to avoid.
• Provide insight into the changes arising from the implementation of the Clinical Trials Regulations and points to consider around the IMP / GCP Interface.
• Explore the challenges and considerations when moving from an R & D to a GMP Environment.

This event provided updates and information on recent changes to guidelines and regulations as well insights into current deficiency trends and inspection practices.