Measuring Success – Top Tips for Assessing the Effectiveness of Training

Article By Michelle Yeomans Operations Manager for EPiC Auditors

The Covid-19 pandemic led to changes in the amount and delivery method used by Pharmaceutical companies to conduct training. Some companies cut back on training to conserve resources for core functions, whilst others invested in virtual training and e-learning to provide continued development opportunities for their employees. The situation was no different for regulators.

During the pandemic, I was the Unit Manager of the GMP and GDP Inspectorate at the MHRA, and as well as developing remote inspection approaches to ensure a continued level of regulatory oversight, MHRA used the opportunity to dedicate Inspectorate resource to enhance the range of training materials available within the ‘Inspector Academy’ knowledge hub and developed virtual training modules and competency frameworks. At the time, it was a case of adapting to the situation and being innovative in exploring available tools and techniques to identify the “least worst” available option.

Post pandemic, several conferences and training events have now returned to being run as face-to-face events, while others are continuing to offer virtual or hybrid options to maximise accessibility and minimise costs. EU GMP Chapter 2, 2.11 refers to the need for “continuing training” to be given and for its “practical effectiveness” to be periodically assessed. Continuing training is an ongoing process of learning and acquiring new skills and knowledge to help individuals stay updated with the latest developments and changes relevant to their role and industry sector. Continuing training can include self-learning so is not just limited to attending workshops, seminars, conferences, or specialist courses. The key point is finding a way to stay current with industry trends, which will help increase expertise and proficiency and support compliance with GMP requirements. Another key consideration is the need to keep a record to document the training, as training records are routinely reviewed during a regulatory inspection and provide evidence of continuing professional development.

With different training opportunities and formats on offer, it is important to have clearly defined learning objectives and ways of collecting information to determine whether the training provided has produced the desired effect and contributed to the development of the trainee.

Here are our top tips for assessing the practical effectiveness of training:

1. Pre and post-assessments: Conducting assessments, questionnaires, or quizzes before and after the training can help measure the knowledge, skills, or behaviour changes that have occurred as a result of the training. Comparing the scores or performance levels before and after the training provides an indication of the impact of the training.
2. Observations and simulations: Observing participants during or after the training session can help assess their application of the newly acquired knowledge and skills. This can be done through simulations or real-world scenarios to evaluate their ability to transfer the learning into practical situations.
3. Follow-up assessments: Conducting assessments weeks or months after the training has taken place can help evaluate the long-term impact and effectiveness of the training. This can provide insights into whether the learning has been retained, and if it has influenced the individual’s work performance over time.
4. Feedback: Soliciting feedback from trainees and supervisors or managers who work closely with the individuals can provide an additional perspective on the effectiveness of the training. They can assess whether the training has positively impacted the individuals’ job performance, productivity, or overall contribution to the organisation.
5. Performance metrics: Comparing PQS performance, KPIs or Quality metrics before and after the training can yield insights into any improvements or changes in the workplace performance of individuals or teams who participated in the training. An overview of GMP related training completed, and a review of PQS performance to identify compliance improvement topics for inclusion in further GMP refresher training should be included as agenda items at periodic Management Review meetings.

By using a combination of these assessment methods, organisations can gain a comprehensive understanding of the effectiveness of their training efforts and identify areas for improvement.

Please get in touch if you want to know more about our virtual symposia and bespoke in-house training courses.

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

 “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

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

EPIC Auditors are delighted to welcome ex MHRA Inspector Tony Orme to the team as an independent consultant.

Tony has over 32 years’ experience at the MHRA working in various areas of regulation of medicinal product supply chains. As a former MHRA GDP Inspector, with 22 years within the MHRA GDP Inspectorate team where he reached Expert Inspector level, he undertook the most high profile and complex inspections across the UK.

Tony was the GDP EU Exit Lead and formulated the post Brexit guidance for import from listed countries, the RPi role and supply to Northern Ireland. He led on the implementation of the Falsified Medicines Directive for distributors in the UK and the continued use of the Medicines Verification system in Northern Ireland.

During his career at the MHRA Tony was involved in the development of most UK GDP policies, including the GDP risk based inspection strategy and supply chain security. He was GDP lead for IAG cases for many years and is ideally placed to help distributors ensure their operations are compliant or help respond to failures and to develop and implement effective remedial actions.

With his comprehensive portfolio of experience, Tony is an excellent addition to the EPIC team.

I have known and worked with Tony for over 20 years and am delighted that he has joined the EPiC team of Experts as an independent consultant. His knowledge and experience of GDP and supply chain security is second to none.

As announced last week at the MHRA Symposium 2023 the GDP Inspectorate are moving to a licence based inspection model, whereby the overall compliance of all sites named on a WDA(H) will be determined from the inspection outcomes of a selected sample of the sites. In implementing this approach, the GDP Inspectorate will be making greater use of unannounced and short notice inspections. Ensuring all sites are in a constant state of inspection readiness is therefore now even more important.

Through EPiC, Tony and the other former MHRA GDP Inspectors, who also work as independent consultants for us, can conduct regular and routine mock inspections and audits to help you maintain the required level of compliance and ultimately be inspection ready.

Richard Andrew, EPiC Director & Senior Consultant

Pharmaceutical Industry Experts

Auditors used by EPIC are former Regulatory Inspectors, typically ex MHRA Inspectors. All auditors have extensive industry experience and many years of experience auditing and inspecting within the pharmaceutical industry.

To read the bio and full CV for Tony Orme and our other experts’ visit Meet Our Experts

If you need our help and support 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.