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 - when compliance is really 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 - process management, organization, quality, 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 stable, operational data flowing. 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 - audits, CAPA and complaints in separate systems, finance-oriented control functions such as the internal control system or internal audit 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 - GxP-compliant and effective in operation, not merely documented. Free initial consultation, about 30 minutes.

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