The path to perfection: A deep dive into continuous improvement in quality management

insights from industryBettina KaplanHead of Quality Assurance ServicesDS InPharmatics (DSI)

This interview examines the principles of continuous improvement and how they can be applied to enhance QMS.

What principle does DSI prioritize for continuous improvement for quality management? How do these principles contribute to the advancement of quality management systems?

Continuous improvement is an industry expectation. If you are using quality management systems on a daily basis, it is important to keep up with changes and trends you are seeing in the industry and within your own organization and ask whether there are things that you could be doing better. ICH guidelines advise continuous improvement.

Our organization is slightly different.  We stay current with industry improvements and we work with and offer these improvements to our clients. My team ensures that best practices and trends are provided to our clients and in so doing, they can improve as well. Basaically, my team will bring back best practices and trends that we have seen and put them into practice. 

How does DSI's GMP consulting team provide hands-on support and strategic guidance to enhance clients' quality systems?

Each of the DSI Quality Team members is a seasoned quality professional. We have all worked in the industry for many years and have held many roles. Because we monitor  continuous improvements within our organization and update each other, we can then offer those improvements to our clients as well.

Consultants use gap assessments to determine where support is needed and provide a strategic plan for improving systems with known best practices, remediating the identified gaps.  We can also be found pulling up our sleeves to help our clients in any aspect of quality from performing daily quality activities to performing assessments to providing guidance as needed.

How does DSI navigate the challenge of maintaining compliance with industry standards while meeting the unique needs of companies at different operational stages?

One of the things that DSI supports as an organization is  phase-appropriate quality systems.  Requirements in Phase 1 differ from the requirements in Phase 3. We help our clients understand what is expected at each phase and we apply them as such.

We work with our counterparts,  within the client and/or within DSI, to determine what phase-appropriate standard operating procedures (SOPs) need to be in place.

If you start with the appropriate SOPS and policies for each phase, compliance is maintained because the right systems are built in place.

If you try to implement a Phase 3 set of SOPS in Phase 1, It will be a difficult task. You would have a lot of policies, procedures, and standards you may not be able to comply with.  We can maintain compliance by applying phase-appropriate procedures and policies.

Can you offer an example illustrating how DSI's proactive evaluation of vendor cGMP compliance minimizes risks, ensuring quality and preventing disruption in the supply chain?

When performing audits where vendors are being evaluated/qualified for cGMP (current good manufacturing practice) compliance, on-site visits are extremely pivotal in identifying real-time operations, gaps and deficiencies, and identifying possible areas for improvement.

Allowing for more valuable risk assessments will minimize causes for disruptions in the supply chain, and will make processes more efficient in the long run. We are there to ensure quality and product compliance and to prevent a problem from disrupting distribution.

It is relevant to consider whether distribution is per clinic or commercial. Most of our clients are small-scale clinical product suppliers and some of our clients have commercial distribution. Our whole goal is to ensure that the systems in place are adequate and be able to reduce risk or. If there are risks, risk assessments are carried out to ensure that the client is not put at risk.

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Image Credit: DS InPharmatics (DSI)

Can you describe DSI's approach to managing compliance situations?

If there is a deviation or some type of non-conformance, we will evaluate it. A risk assessment will be performed, if needed.  If corrective and preventative actions (CAPAs) are needed to correct or prevent non-conformance in the future, they will be put in place. That is how we ensure compliance: everything is reviewed fully and adequately, and we make sure that the right people review the documents.

Most of the time, we will have a technical reviewer and a quality reviewer assessing the deviation.  Subject matter experts are also part of the review: if it is analytical, we will have an analytical expert; if it is manufacturing, a manufacturing expert will review. Throughout the process, there is always the quality review.

We try to match our quality consultants to the appropriate client needs to ensure they have the appropriate knowledge and expertise, and can better offer appropriate advice, guidance, and compliance

How does DSI strike a balance between adaptability and adherence to industry standards?

DSI consultants continuously monitor the industry for best practices and work with clients to create unique programs that meet their clients' needs. An experienced DSI consultant also works with their client to determine and recommend the best approach.

We also look our client's quality documents and determine whether the appropriate persons have the correct responsibilities assigned to them in the documents. Many times, we find companies do not always have the correct position assigned to a task or action item. You have to ensure you effectively designate work to the right person.

Can you share an instance where DSI's involvement in batch record review and release upheld the highest quality standards, ensuring compliance with industry regulations?

DSI's consultants perform routine batch record reviews and releases to ensure compliance with industry regulations, filing requirements, and regulatory guidance. 

One of the many best practices DSI recommends for their clients' batch record review process is to include a systematic approach, including both technical and quality assessment (QA) reviewers, to ensure the knowledge and compliance requirements are addressed and a robust documentation system is used as part of the review and release process.

I work on various projects. Right now, I am on one project with four additional reviewers, and we spend hours going through the batch records.

I have teams of Technical and QA reviewers. They review every piece of the batch record. If the companies have not written up deviations where necessary, they will request them. They will make sure that compliance is there such that if someone else reviews or looks at this batch record, all the questions will be answered. Nothing would be left unanswered as part of our review.

Does DSI provide strategic initiatives and training programs to help clients improve quality systems and mitigate future risks?

Depending on the client’s requirements and the stage of the company, the DSI consultant will recommend, advise, or implement initiatives as requested by the client, perform training as needed, and be involved in risk management to help mitigate risks. For example, consultants can provide guidance and remediation activities on data integrity and other risk-identified quality issues.

How does DSI assist clients in preparing for pre-approval inspections? What measures does the company take to minimize surprises during approval and launch processes?

In many cases, there are two different ways to go about this. If we have been working on the project from day one, we have probably signed off on all the documents and know exactly what to expect.

Once we are approaching filing, we will do a mock pre-approval inspection (PAI) to make sure that all the documents we are expecting are done and approved, that no corrections are needed, and that all the systems needed to support the processes are in place.

If we were not initially involved in the project, we will still use the same scope to ensure that all the documents are approved and sound. If there are any observations, we will note them so that they can be corrected. We will work with the client to help them prepare for the PAI. If they need help training individuals to speak to a health or regulatory body, we will also help train them for that.

Can you share a case study in which DSI's approach to addressing clients' needs successfully resolved challenges in quality and regulatory operations?

This approach has been followed for many years and is currently active with several clients pending regulatory approvals. Recently, a team of auditors went to Europe for a client to perform Mock PAI inspections of their CDMOs. Identifying deficiencies during the Mock PAI audits and allowing the CDMOs to correct the dificiencies.  The benefit of these audits resulted in an FDA PAI with no FD-483 observations noted. This was the ultimate successful outcome.

About Bettina Kaplan 

Bettina Kaplan is a seasoned Pharmaceutical Quality Assurance and Compliance professional with a BS in Chemistry from Steven's Institute of Technology and various industry certifications in Quality Assurance and Compliance Practices. Bettina has over 30 years of experience in Quality Control, Quality Assurance (R & D, Manufacturing, Quality Systems, Supplier Management, Quality Management and Corporate Quality) and Compliance with expertise in remediating and building robust and effective Quality Systems that are fit for the organization's size and scope.

About DSI, a PLG Company

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