“Transform Your Training”-5 Top Tips for Implementing an Effective Training Program

Article By Vicki Pike, Operations Manager for EPiC Auditors

Training is essential in the pharmaceutical industry for several key reasons. Proper training helps maintain high standards of product quality and safety. Well-trained employees are better equipped to identify and prevent errors, ensuring that the products meet the required quality standards and are safe for patient use. Well-trained staff can perform their tasks more effectively, reducing waste and improving overall operational efficiency. Training also ensures that employees understand and adhere to GMP/GDP requirements, which is crucial for maintaining compliance.

The Eudralex GMP guide requires training for all personnel involved in production, storage, control labs, and other roles affecting product quality. This must include basic and role-specific training for new recruits, with ongoing training and periodic effectiveness assessments. Similarly, GDP mandates training for all personnel involved in wholesale distribution activities to ensure they are competent and experienced before starting their tasks. Training records must be kept, and effectiveness periodically assessed and documented.

Unfortunately, training deficiencies, such as overdue or incomplete training and failure to follow SOPs, have led to significant regulatory actions, including referrals to the MHRA Compliance Management Team (CMT) and Inspection Action Group (IAG). These issues are often part of broader systemic failures, which, although not cited directly as a training deficiency, inadequate training is a root cause or contributory factor.

During the EPiC Virtual Symposium on 28 November 2024, we held a round table discussion on GMDP training, including refresher training. Here are our top tips for implementing an Effective Training Program:

1. Tailor Training to Roles: Develop training plans specific to each job role, considering responsibilities and required experience. Use job descriptions and SOPs to identify relevant tasks and ensure everyone receives appropriate GMP/GDP training during induction and on an ongoing basis.
2. Effective Training Delivery: Choose the most effective training methods based on the role’s responsibilities. Options include:
   • reading SOPs, when awareness of the activity is only required
   • e-learning, can be used to pull out the key aspects of a procedure
   • instructor-led training (classroom or virtual), to be used when a role has direct responsibility for an activity
   • on-the-job training is best for practical demonstrations and coaching.
3. Understand the ‘Why’: Ensure training materials explain not just what to do, but why it is done that way. Understanding the reasons behind tasks helps employees remember and comply with procedures and understand the implications of errors.
4. Refresher training: Regular management reviews of the Quality System can identify adverse trends to plan topics for GMDP refresher training. Consider using real life examples of issues that have occurred at your own site for the basis of discussions and exercises, to make refresher training as relevant as possible to your teams.  Also consider changes to regulations and new legislation. Stay informed about industry trends and inspection findings from MHRA, EMA, and FDA, and use resources like blogs, newsletters, free webinars, symposia, and forums.
5. Interactive and Engaging Training: Make training interactive to promote engagement. For GMP/GDP refresher training, use a mix of shorter sessions throughout the year rather than one long annual session. Tailor training to the audience and include opportunities for questions and clarifications.

By following these top tips, companies can ensure their GMDP training is effective, relevant, and engaging, leading to better compliance and performance. 

To assess the effectiveness of training, please see our previous post EPiC Top Tips – Assessing the Effectiveness of Training

Get in touch if you want to know more about how EPiC can deliver targeted, engaging training on a variety of topics.

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

EPiC Auditors Virtual Symposium 2024: From Complaint to Compliant: A Practical Guide to Overcoming Current GMDP Challenges

Join us for EPiC’s fourth annual virtual symposium on Thursday, 28th November 2024, titled “From Complaint to Compliant: A Practical Guide to Overcoming Current GMDP Challenges.”

Building on the success of our past symposia, this event promises a day packed with enlightening presentations by a distinguished panel of former MHRA Inspectors. We’ll explore the latest updates and guidance and provide practical guidance to conquer compliance challenges facing the pharmaceutical sector.  Further details can be found here; https://academy.epic-auditors.com/

Subscribe to our newsletter to receive exclusive updates and all the latest news on EPiC’s Symposium 2024.

Pharma Discovery to Distribution

The EPiC team were pleased to be able to attend the UK’s Making Pharmaceuticals Conference 2024 in Coventry from 23rd to 24th April 2024.

The two-day conference covered topics spanning the entire product lifecycle, from discovery to distribution, and it was a fantastic opportunity to explain and promote our services to the conference attendees as well as meet with many of our current and past clients

“Keep Calm and Be Prepared” – 5 Top Tips for Inspection Readiness

Article By Michelle Yeomans, Operations Manager for EPiC Auditors

Judging by the number of enquiries we are receiving to provide ex MHRA Inspectors to assist with inspection readiness preparations or remediation activities; it certainly looks like the number of regulatory inspections and supplier due diligence audits are returning to pre-pandemic levels.

Inspections are an opportunity to demonstrate compliance, so when you receive notification of a regulatory inspection (or external audit), keep calm, and use our top tips to help be prepared:

1. Inspection Scope  – Make sure that the purpose and scope of the inspection are clearly understood to help identify the relevant people, products, premises, systems, processes, and procedures that are likely to be involved so that these can all be factored into an inspection readiness plan. As part of the plan, consider the need for inspection awareness training for staff likely to be directly involved, especially if they have not previously experienced a regulatory inspection. Do not forget to check any contractual agreements, as contract acceptors may be required to notify the contract giver of any regulatory inspections.  

2. Compliance Status – Leverage output from the pharmaceutical quality system by referring to performance and trend data from self-inspections, deviations and CAPA, risk assessments, management review, etc. to understand how the quality system and operational processes are performing. This will either give you assurance that you are inspection ready or help identify specific compliance concerns or weakness to enable you to focus on implementing mitigating actions.  

3. Front and Back Room Organisation – Based on the scope and purpose of the inspection, identify and assign appropriate numbers of personnel (including deputies) to act as hosts, tour guides, scribes, runners, back-room staff handling document requests, and subject matter expects (SMEs). Provide some basic inspection preparation awareness training to give an overview of the inspection process and ensure everyone involved has a clearly defined role and purpose. 

4. Turning Negatives into Positives – In completing your inspection readiness plan you may have identified potential deficiencies or there may be questions you would not want an inspector to ask. Encourage the SME’s who know the areas of weakness to practice explaining in a clear and succinct way what the issues are and what is being done to improve the situation. Being able to clearly explain the issues, mitigating actions and CAPA already in place can help to reassure the inspector that a situation is under control and may avoid or reduce the severity of a deficiency.    

5. First Impressions Count – Get the inspection off to a positive start by anticipating likely questions and areas of interest and have documentation and premises ready for inspection.  Prepare a brief presentation covering site activities and confirm any significant changes since the previous inspection (if it is not the first inspection). Check that previous inspection actions have been closed and have evidence of closure to hand. Identify and walk the physical inspection routes and tidy the areas focusing on housekeeping and first impressions. Plan to walk the expected route each day to check on housekeeping, as new deliveries may have arrived, new production batches set up, new teams on shift, etc.   

By following these tips, you can prepare for an inspection by using practice runs and role-play scenarios to practice hosting, tracking, and responding to questions (including the difficult ones!) and help build confidence in being able to demonstrate compliance. 

Get in touch if you want to know more about our mock inspections or bespoke inspection readiness training.  

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

 You may also like to read our Case Study 1: Inspection Readiness: https://epic-auditors.com/case-study-inspection-readiness/

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