Comparing Multi-National Plant Sites
Scenario: Company X wants to compare
SOPs in its pharmaceutical manufacturing facilities in five different countries and ensure that the
SOPs at each site are in compliance with corporate policies and consistent with each other.
Solution: Using Dynamic DRUMBEAT® for Pharmaceutical
Clinical Trial Supplies Form A, each facility links its
GMP-related SOPs to
DRUMBEAT® Concepts. The
SOPs listed on Form A are then sorted by
DRUMBEAT® Concepts. A Multi-Unit Gap Analysis,
Form
F, is produced with each of the five facilities listed. Form F indicates which
SOPs are available and which are missing at each plant site enabling a standardized comparison of the five facilities.
SOPs required by the corporate policies are then screened for quality with a quality attribute of “Consistent with Corporate Policies” added to
Dynamic DRUMBEAT® for Pharmaceutical Clinical Trial Supplies
Form H.
Results: Plant sites are compared using an established standardized method that is based upon worldwide regulations.
SOPs missing from one plant site are obtained from another site and then modified, as appropriate. All
SOPs are brought into compliance with corporate policies. Company X is thus better prepared for a regulatory inspection.
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Compliance Assessment
Scenario: Company X plans to manufacture
clinical trial supplies in the US and ship to the EU and therefore Company X wants to compare the US requirements for
clinical trial supplies against those from the EU.
Solution: Using Dynamic DRUMBEAT® for Pharmaceutical
Clinical Trial Supplies, Company X scans through the
DRUMBEAT® Concepts
to determine which have regulatory requirements in the EU but not in the US. The EU citations are linked to the
DRUMBEAT® Concepts and therefore simple to click and read. A table is prepared documenting the differences.
Results: Dynamic DRUMBEAT® for Pharmaceutical Clinical
Trial Supplies enables a quick determination of requirements unique to EU that are not required in the US.
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Writing a New
SOP
Scenario: As a result of a recent FDA inspection, you need to write an
SOP on the Accounting for
Clinical Trial Supplies Product, but you want to research the regulatory requirements before you write the
SOP, and your time is limited.
Solution: Do a search of the
DRUMBEAT® Concepts
List in Dynamic DRUMBEAT® for Pharmaceutical Clinical Trial
Supplies for accountability. When the search displays
DBC 20.07, click on the regulatory citations and read the regulatory requirements for Investigation Drug Product Accountability, and include the required elements in the
SOP.
Results: You write the
SOP in less time, with confidence that it is based on worldwide regulatory requirements.
Dynamic DRUMBEAT® for Pharmaceutical Clinical Trial Supplies
reduced the research time.
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Preparing for a Pre-Approval Inspection
Scenario: You expect a Pre-Approval Inspection in the next month that could involve plant sites X, Y, and Z. Your
GMP-related SOPs have been linked at Plants X and Y, but not Z.
Solution: Using
Form A, link Plant Z
SOPs to DRUMBEAT® Concepts. While linking Plant Z
SOPs, compare Plants X and Y
SOPs by using a Multi-Unit Gap Analysis,
Form
F. When Plant Z SOPs are linked, add Plant Z to the
Multi-Unit Gap
Analysis. If any plant site is missing an
SOP that is available at another Plant Site, a copy should be obtained and modified, as appropriate. Perform a Rapid Quality Screening,
Form
H, on 100 SOPs from each plant site and DrumKEY™
Analyses on 10 SOPs from each site.
Results: All three plant sites are ready for Pre-Approval Inspection with
SOPs of known quality.
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Selecting a
Contract Manufacturer
Scenario: You are looking for a new contract manufacturer to produce
Clinical Trial Supplies for you. You have narrowed the list of potential manufacturers to three and plan to conduct only one audit.
Solution: Request each potential contract manufacturer to send you their
SOP index; listing the SOP Number, Title, and Effective Date. Request that the index be provided in electronic format (preferably MS
Excel®), if possible. Using Dynamic DRUMBEAT® for Pharmaceutical Clinical Trial Supplies
Form A, link each potential manufacturer’s SOPs to
DRUMBEAT® Concepts and then prepare
Single Unit Gap Analyses for each manufacturer and a
Multi-Unit Gap Analysis for all of the manufacturers. Compare the results of the Gap Analyses and determine which manufacturer appears to have the required
SOPs. Audit the selected manufacturer.
Results: Time and money are saved by only auditing one manufacturer.
DRUMBEAT® Concepts
linked manufacturer SOPs can also be used to plan the audit.
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GMP Training
Scenario: GMPs require employees to be trained in
GMPs and the
SOPs related to their job function.
Solution: Link
SOPs to
DRUMBEAT® Concepts
and use DRUMBEAT® Concepts to define required training for each job function.
Results: Linking
SOPs to
DRUMBEAT® Concepts links the
SOPs to
GMPs as well. Training an individual is simplified because the
SOPs are now directly related to the regulations that require them.
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Audit Planning
Scenario: It currently takes several hours to plan an audit and locate the
SOPs that will be addressed during the audit.
Solution: Link
SOPs to
DRUMBEAT® Concepts
and define the concepts that will be covered during the audit. Locate the
SOPs that are linked to the
DRUMBEAT® Concepts to be addressed during the audit. Perform a
DRUMBEAT® Quality Screening on the
SOPs prior to the audit to find any quality issues.
DRUMBEAT® Concepts links can also be used during follow-up on Audit Action Items, if the Action Items are linked to
DRUMBEAT® Concepts.
Results: Audit planning and follow-up time is reduced.
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Linking to FDA and Audit Activities
Scenario: Over the past year, you have collected copies of FDA Inspections at several of your competitors’ facilities, and you want to avoid having the FDA finding the same problems in your plant.
Solution: Create a list of the FDA Observations and link them to
DRUMBEAT® Concepts. Link your
SOPs to
DRUMBEAT® Concepts and then compare your
SOPs against the
DRUMBEAT® Concepts that were assigned to FDA observations in order to identify vulnerabilities. Correct any deficiencies. Similar practices can be used for audit findings.
Results: You are ready for the FDA.
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