Enterprise management systems as the basis for GxP compliance - QFINITY
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Enterprise management systems as the basis for GxP compliance.

In Pharm. Ind. 79 (2017), Dr. Stefan Schaaf (Q-FINITY Qualitätsmanagement) describes why GxP compliance does not rest on the management manual but on the processes: an enterprise management system integrates quality, governance, risk and strategy into a control loop, instead of producing documentation for the auditor.

The article

GxP compliance begins with the process, not the manual.

The article argues that many still equate quality with documentation, whereas compliance is in reality becoming a system, a tool used in day-to-day work. The backdrop is a shift among regulators: European authorities and the FDA are bringing pharma and medtech regulation closer together, and ISO 9001:2015 makes process orientation and risk-based thinking mandatory. The once-obligatory management manual gives way to the "documented information" that arises directly from the process.

What the article establishes

The key points at a glance.

  • Enterprise management system

    An integrated approach covering every topic that management defines at strategic and operational level, from process management, organization and quality to governance, risk & compliance and corporate strategy. Its control loop follows the Deming cycle (PDCA) and covers more than quality alone.

  • Process as the common denominator

    Laws and standards impose requirements on processes, not organizational units. Every process needs clearly assigned accountability, held by the process owner. That is the basis on which the various parties work together.

  • Consolidation of standards

    European regulators and the FDA are bringing pharma and medtech regulation closer together. ISO 9001:2015 makes process orientation mandatory, anchors risk-based thinking and drops the obligatory management manual.

  • Risk sits with the process

    Risk always sits with the process. Even when a failing IT system is the trigger, the business process must compensate for the failure through its rules. Risk-based thinking determines the level of detail and formality of the management system.

  • Data and metrics

    A sound system brings the relevant data into focus and clarifies data ownership. Master data stays stable while operational data flows. Success depends on capturing financial and non-financial metrics. Non-financial metrics in particular can only be captured easily with integrated systems.

  • Software supports, it does not solve

    A high degree of integration is only achievable with intelligent software support. Yet software can only ever support; it never solves the organizational problems. Quality comes from Quality by Design, not from buying tools after the fact.

The key theses

From the management manual to a system in everyday use.

The article takes a sober look at the status quo: many companies operate in silos, with audits, CAPA and complaints in separate systems, and finance-oriented control functions such as the internal control system or internal audit running alongside quality management. What is missing is integration. This is exactly where the enterprise management system comes in: the purpose comes from the process and its intended use, not from the IT system. The system merely supplies the data foundation, while organizational responsibility rests with the process. That holds beyond GxP-relevant systems too, for instance for business-critical systems under SOX or GDPdU.

PDCA cycle Intended Use ISO 9001:2015 SOX GDPdU
A management manual is written for the auditor. A management system grows out of the processes and lives in daily practice.
The author

Written from quality management practice.

Dr. Stefan Schaaf (Q-FINITY Qualitätsmanagement, Dillingen) wrote the article. He combines the management-system and GxP perspectives, an approach that still shapes QFINITY's work today. The article was published in Pharm. Ind. 79, No. 12, pp. 1644-1650 (2017) at ECV Editio Cantor Verlag, Aulendorf, as an updated version of the text in "IT-Trends im GxP-Umfeld" (ed. by Concept Heidelberg, 2015); copyright and full text rest with the publisher.

Q-FINITY Qualitätsmanagement Pharm. Ind. 79 (2017) ECV Editio Cantor Verlag Enterprise management system GxP compliance
Enterprise-Managementsysteme als Basis für GxP-Compliance in der Life-Science-Industrie - ECV (Pharm. Ind.)↗
Related topics

From thesis to practice.

Quality as a working system.

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