Quality Risk Management For Pharmaceutical Industry |
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Quality Risk Management For Pharmaceutical Industry
Wed, 02/28/2007 - 02:00 Anonymous
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Kirupakar.B.R
The importance of quality systems has been recognized in pharmaceutical industry and the
protection of the patient by managing the risk to quality is being given prime importance.
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The manufacturing and use of a drug product has some degree of risk. It is important to understand that product quality
should be maintained through out the product lifecycle.
Traditionally risk to quality have been assessed and managed in a variety of informal ways for example compilation of
observations, trends and other information. These provide information that support topics like handling of complaints,
quality defects, deviations etc. Now risk management can be performed with recognized management tools along with
support of statistical tools in combination, which make easy for application of quality risk management principles. Risk
Management is a process for identifying hazards associated with a product, estimating and evaluating the associated
risks, controlling these risks, and monitoring the effectiveness of the control. An effective quality risk management
ensures the high quality of drug product to the patient. Inaddition quality risk management improves decision making if a
quality problem arises. It should include systemic processes designated to co-ordinate, facilitate and improve sciencebased decision-making with respect to risk.
Effective quality risk management facilitates better and more informed decisions and provide FDA regulators with
greater assurance of a companys ability to deal with potential risk.
Risk management principles are effectively utilized in many areas of business and development including finance,
insurance, occupational safety, public health, pharmacovigilance and agencies regulating these industries.
It can be
applied to different aspect of pharmaceutical quality including development, Manufacturing, Distribution, Inspection,
submission and review processes through the life cycle of drug substances, drug product, biological and biotechnological
product (including use of raw material,solvent,exciepient,packaging and labeling.)
Model for quality risk management is outlined in diagram below.
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Decision-making nodes are not present in diagram because decision can occur at any point in process. Decision might be
to return to previous step and seek further information, to adjust risk model or end the risk management process
Risk Assessment:
Risk assessment is identification of hazards and the analysis and evaluation of risk related to with exposure to those
hazards. As an aid to clearly defining the risk for risk assessment few fundamental are often useful, such as what might
go wrong? What is the probability and consequence of wrong occurrence? While doing effective risk assessment, the
robustness of the data is important as it determines the quality of outcome. The risk assessment can be either
quantitative or qualitative parameter.
Risk Management Methods and Tools:
Basic risk management facilitation methods:
The simple technique used to structure risk management by organizing data and facilitating decision-making are flow
charts, check sheet, process mapping, cause and effect diagrams.
Failure Mode Effects Analysis (FMEA):
FMEA depends on product and process understanding. It methodically breaks down the analysis of complex processes
into manageablesteps. It provides evaluation of potential failure modes for processes and their likely effect on product
performance.
It can be applied to equipment and facilities and might be used to analyze a manufacturing operation and
its effect on product or process. This tool is further advanced with studying criticality of the consequences and providing
clear indication of situation. The purpose, terminology and other details can vary according to type ( e.g. Process FMEA,
Design FMEA, Health FEMA etc.), the basic methodology is similar for all.
Benefits of FMEA
Some benefits of performing FMEA analysis include higher reliability, better quality, increased safety and its contribution
towards cost saving includes decreased development time and reduced waste and non value added operations.
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Cost benefits associated with FMEA are usually expected to come from the ability to identify failure modes earlier in the
process, when they are less expensive to address. Financial benefits are also derived from the design improvements that
FMEA is expected to facilitate, including reduced warranty costs, increased sales through enhanced customer satisfaction,
etc.
4, 5
This Provides a learning tool for new engineers and meets customer requirement and/or to comply with Safety and
Quality requirements, such as ISO 9001, QS 9000, ISO/TS 16949, Six Sigma, FDA Good Manufacturing Practices
(GMPs), Process Safety Management Act (PSM)
Ideally, FMEA is best done in conjunction with or soon after PHA efforts. Results can be used to identify high-vulnerability
elements and to guide resource deployment for best benefit. An FMEA can be done anytime in the system lifetime, from
initial design onward.
The below given chart 1 describes the pattern of this tool in the maintenance applications and chart II serves as a typical
example for problem cause during export of the finished products and its likely effect on the business.
Chart I
Failure Mode And Effects Analysis (Fmea)
Subsystem/Name: DC motor
Final Design:
Model Year/Vehicle(s):
FMEA Date (Org.):
Prepared by:
P = Probabilities of Occurrences S = Seriousness of Failure
Reviewed by:
D = Likelihood that the Defect will Reach the customer R =
Risk Priority Measure (P x S x D)
1 = very low or none
2 = low or minor
3 = moderate or significant
4 = high
5=
very high or catastrophic
No.
Part
Function
Failure
Name
Mechanism
Effect(s)
Current
Causes(s)
Of
Control
of Failure
Failure
Wear and
Extensive
P.R.A.
Recommended
Action
(s) &
Mode
Part
(s)
Corrective
P
80
Action(s)
Taken
No.
Drive
Measures
Incorrect
actual
speed
speed
reading
tear
Voltmeter
damage
Improve check
procedures
CHART II
Mode of
Cause of
Effect of
Frequency
Degree
Chance f
Risk
Design
Design
failure
failure
failure
of
of
detection
priority
action
validation
occurrence
Severity
(1-10)
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(1-10)
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(1-10)
(11000)
(4) x
(5)x(6)
Drug
Shipping
Customer
Agent
Agent
product
delay from
loses
reviews
initials
not
manufacturer
time/$
timeline with
order form
delivered
on time
96
supplier
Missing
Customer
Verify
Initiate
excipients
loses
components
preliminary
time/$
175
needed for
checklist for
job
job
Assigned values for column 4-6
Column Value
10
[Link]
10
12
14
16
18
20
(errors/100 customers
[Link] for customer
Trivial
[Link] of detection
Certain
Complaint
Major time/$
Loss of customer
Possible
None
Failure Mode, Effects and Criticality Analysis (FMECA):
It is the extension of earlier said FMEA tool. Extending FEMA to incorporate an investigation of the degree of severity of
consequences, their probabilities of occurrence and their detectability is Failure mode, effects and criticality analysis.
In
FMECA, each failure mode of the product is identified and then evaluated for criticality. This criticality is then translated
into a risk, and if this level of risk is not acceptable, corrective action must be taken. This can be utilized for failure and
risk associated with manufacturing processes. The tool can also be used to establish and optimize maintenance plans for
repairable systems and/or contribute to control plans and other quality assurance procedures. In addition, an FMEA or
FMECA is often required to comply with safety and quality requirements, such as ISO 9001, QS 9000, ISO/TS 16949, Six
Sigma, FDA Good Manufacturing Practices (GMPs), Process Safety Management Act (PSM), etc.
When we perform a FMECA, we are identifying all potential failure modes and their associated effects. To make this task
more manageable, we must first decide what type of FMECA we want to perform - Design, Process, User, Software, Test,
to name a few.
Severity classification
This classification is assigned to provide a qualitative measure of the worst potential consequences resulting from design
error or item failure. Classifications should be assigned to each identified failure mode and each item analyzed in
accordance with the loss statements below. It may not be possible to identify an item or a failure mode according to the
loss statements in the four categories below, but similar loss statements based on various inputs and outputs can be
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developed and included in the ground rules for the FMECA activity. Severity classification categories that are consistent
with are defined as follows:
Category ICatastrophicA failure that may cause injury or death.
Category IICriticalA failure which may cause severe injury, major property damage, or major system damage that
will result in major downtime or production loss.
Category IIIMarginalA failure which may cause minor injury, minor property damage, or minor system damage
which will result in delay or loss of system availability or degradation.
Category IVMinorA failure not serious enough to cause injury, property damage or system damage, but will result
in unscheduled maintenance or repair.
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FMECA's are similar to FTA's. The big difference is an FTA starts with one specific failure effec t and then identifies only
those failure modes that can cause the particular effect, whereas a FMECA is trying to identifying all possible failure
modes of a product and the effects of these failure modes.
Fault tree analysis (FTA):
This tool assumes failure of the functionality of a product or process.
The results are represented pictorially in the form
of a tree of fault modes. This can be used to investigate complaints or deviation in order to fully understand their root
cause and ensure that intended improvement will resolve the issues and not cause any other different problem.
example of this tool is provided in the picture below.
Fault Tree Analysis
A good
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Hazard Analysis and critical control points (HACCP):
HACCP is a systematic, proactive and preventive tool for assuring quality, reliability and safety.
It involves hazard
analysis, determining critical control point, establishing critical limit, establishing a system to monitor critical control point
and establishing a record keeping system.
chemical and biological hazards.
This might be used to identify and manage risk associated with physical,
Hazard operability Analysis (HAZOP):
HAZOP is a highly structured hazards identification tool.
This is based on assumption that events are caused by deviations from the design or operating intentions.
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Guide words
like for example no, more, other than are applied to relevant parameter ([Link], temperature) to identify
potential deviation from the design intentions.
For example, when the guide word "No" is combined with the parameter
"flow" the deviation "no flow " results.
It concentrates on identifying both hazards as well as operability problems. While the HAZOP study is designed to identify
hazards through a systematic approach, more than 80% of study recommendations are operability problems and are not,
of themselves, hazards. Although hazard identification is the main focus, operability problems should be identified to the
extent that they have the potential to lead to process hazards, result in an environmental violation or have a negative
impact on profitability.
The purpose and scope of the study should be determined before a HAZOP Study objectives may be to check the safety
of the design, decide whether and where to build, check operating and safety procedures, improve the safety of an
existing and or modified facility, and verify that safety instrumentation is working optimally
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HAZOP Methodology includes collection of document and drawing, breaking facility into manageable section, listing out
parameters, create deviations, record cause and consequence for each cause, record controls to prevent the cause and
list any future action that should be implemented.
It is imperative that accurate information associated with the project is sourced and included in the study. Such
information may include provisional layouts,material safety data sheets (MSDS),process flow diagrams, plant model,
equipment arrangement drawings, provisional operating instructions,
heat and material balances layouts, logic
diagrams, equipment datasheets, hazardous area layouts, and start-up and emergency shutdown procedures.
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The operation of this tool is depicted in the above diagram.
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Preliminary hazard Analysis (PHA):
This tool analysis is based on applying prior experience or knowledge of hazard to identify future hazards, hazardous
situation. This can be used for product, process and facility design. This can be used in early development of a project
where there is little information on detail is available.
Preliminary hazard analysis (PHA) is a semi-quantitative analysis that is performed to
Identify all potential hazards and accidental events that may
lead to an accident, Rank the identified accidental events according to their
Severity and Identify required hazard controls and follow-up actions.
A typical PHA worksheet is shown below.
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Risk ranking and filtering:
This can be used to prioritize manufacturing sites for inspection. It is helpful in situation in which portfolio of risks and the
underlying consequences to be managed are diverse and difficult to compare using a tool.
Statistical tool like histograms, control charts or Pareto charts can aid and facilitate in decision-making along with abovementioned tools.
References:
[Link] for industry Q9 Quality risk management by US department of Health and Human Services, Food and drug
Administration, Center for drug and evaluation research June 2006.
2. IEC 60812 Analysis techniques for system reliabilityProcedure for failure mode and effects analysis (FMEA).
3. FMEA and FMECA An Overview of Basic Concepts and Directory of Other Resources by [Link]
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[Link] corporations xfmea applications and benefits
[Link] mode effect analysis Quality training and management by Geoff vorely 26 may 1999
[Link] 61025 Fault tree analysis (FTA).
[Link] Assessment: Use and Application in pharma and biotech manufacturing operations by Geoff pilmoor sims moelich
associates
8. WHO Technical Report Series No. 908, 2003, Annex 7Application of Hazard Analysis and Critical Control Point (HACCP)
methodology to pharmaceuticals
[Link] protecting people and profitability
TM
simplified risk analysis solutions
10. IEC 61882 - Hazard Operability Analysis (HAZOP).
11. CSIRO minerals OHS&E Intranet
12. Preliminary Hazard Analysis by Marvin Rausand System Reliability Theory (2nd ed), Wiley, 2004
13. The Complete Guide to the CREby Bryan Dodsonand Dennis Nolan, 1996 by Quality Publishing
About Author
[Link] .B.R earned his master degree on Pharmaceutics in 2000 at the [Link] medical University ( India ) . He
is working as senior research officer at Exela Pharmsci [Link]., Bangalorewith more focus on Novel Drug Delivery
Systems and have great interest in Nanotechnology.
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