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 documenting, whereas compliance is really becoming a system, an operational instrument. The backdrop is a shift among regulators: European authorities and the FDA are aligning pharma and medtech topics, 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 covers

The key points at a glance.

  • Enterprise management system

    An integrated approach covering everything management sets strategically and operationally, from process management, organization and quality to governance, risk & compliance and corporate strategy. Its control loop follows the Deming cycle (PDCA) and reaches well beyond quality alone.

  • Process as the common denominator

    Laws and standards impose requirements on processes, not organizational units. Every process needs clear accountability, a process owner, as the basis on which the various parties work together.

  • Consolidation of standards

    European regulators and the FDA are aligning pharma and medtech topics. 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 absorb it 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. Only integrated systems make the latter easy to capture.

  • Software supports, it does not solve

    Deep integration takes 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 living system.

The article takes a sober look at the status quo: many companies run parallel worlds, 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, combining the management-system and GxP perspectives, an outlook that shapes QFINITY's work to this day. The article appeared in Pharm. Ind. 79, No. 12, pp. 1644-1650 (2017) at ECV Editio Cantor Verlag, Aulendorf, as an updated version from "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.

We work with you to determine whether your processes, metrics and risk assessments can sustain an integrated management system that is GxP-compliant and effective in operation rather than merely documented. Free initial consultation, about 30 minutes.

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