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Quality Risk Management Process Overview

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0% found this document useful (0 votes)
15 views8 pages

Quality Risk Management Process Overview

Uploaded by

zombie12388888
Copyright
© All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd

Quality risk management (QRM) is a systematic approach to assessing, controlling,

communicating, and reviewing risks that could affect product quality, patient safety, or
business operations.

The QRM process generally consists of several key steps:

 Risk assessment: Identifying potential hazards, analyzing their likelihood and severity,
and evaluating their significance with tools like risk matrices or Failure Mode and
Effects Analysis (FMEA).6sigma+3

 Risk control: Determining and implementing actions to mitigate, reduce, or accept


risks based on predefined [Link]+2

 Risk communication: Sharing information about risks and their management clearly
among all stakeholders, including regulatory agencies if [Link]+2

 Risk review: Continuously monitoring and reassessing risks and controls to adapt to
new information, process changes, or regulatory requirements

Risks can be managed by achieving

1. Elimination by design
2. Reduction to an Accepted Level
3. Verification to demonstrate that risks are managed to an acceptable level

“Harm: Damage to health, including the damage that can occur from loss of product quality
or availability.”

“Hazard: The potential source of harm.”

“Risk: The combination of the probability of occurrence of harm and the severity of that
harm.”

“Severity: A measure of the possible consequences of a hazard.


A process risk assessment means you're looking at risks at a big-picture level. You’re not focusing on specific systems or software yet.
Instead, you're looking at how the overall business process or the flow of data might be exposed to risks. It’s often done early on, before
diving deep into technical security controls for specific systems. It helps identify potential weak points in the overall business process.

The following are the steps for a QRM Process

 Perform initial risk assessment and determine system impact.

Any initial risk assessment should be performed based on the understanding of the business
process. The user requirement, regulatory requirement

A result of this assessment should include a decision on whether the system is GXP
regulated.
 Identify functions with the impact on patient safety, product quality and data
integrity.

Functions that have an impact on patients safety, product quality and data integrity should
be identified by building information gathered in step 1.

 Perform functional risk assessments and identify controls

Functions identified during step two should be assessed by considering possible hazards and
how potential harm arising from this may be controlled.

 Implement and verify appropriate controls

The controls identified in step three should be implemented and verified to ensure that they
are successfully implemented.

 Review risk and monitor controls

During periodic review of the system, an organisation should review the risk.

The review should verify that the controls are still effective with corrective action taken
under change management.

The organisation should also consider whether

 Previously unrecognised Hazards are present


 Previously identified hazards are no longer applicable.
 Estimated risk associated with hazard is no longer acceptable
 Original assessment is otherwise invalidated following changes to
applicable regulation or changes to the system use.

ROLE AND RESPONSIBILITY.


Quality risk management is the overall responsibility of the business process owner.

SCALABILITY

The five step management process may be scaled according to the risk, complexity and
novelty of individual system.

APPLICATION TO A BUSINESS PROCESS

To apply a quality risk management process to a computerized system, the thorough


understanding of the business process supported by the computerized system is needed.

The following. Aspects needs to be considered. During the application.

 What are the hazards? It is the identification of where the system could go wrong.
Consideration should include both user failure and system failure.
 What is the harm? Example production of adult trader product.
 What is the impact?
 What is the probability of the failure? The probability of failure to some extent aligns
with the GAMP categories. As the complexity increases, failure likelihood increases.
 What is the detectability of the failure?
 How will the risk be managed?

It is worth noting that zero risk is usually an unattendable goal.. Instead, companies need to
think in terms of acceptable risk, sometimes known as risk tolerance.
Risk tolerance is the clear limit on how much risk you’re willing and able to accept before
you must take action.

It’s the measurable boundaries for what’s acceptable (e.g., defect rates, audit findings,
delays). If a risk crosses those limits, you fix it or escalate.

LIFE CYCLE APPROACH

Appropriate risk management processes should be followed throughout the life cycle to
manage the identified risks.

R1 Initial risk assessment: An initial assessment should be performed. At or before the


beginning of the project phase.

The earlier this can be done, the better, as this is the step in which the system is defined as
in or out of the scope of GXP.

This assessment should precede or at worst be parallel with the development of


requirement specification.

The GXP determination and the impact of the computerized system on patient safety,
product quality, and data integrity are the important aspects of initial risk assessment.

The amount of information available while performing the initial risk assessment depends on
both the business process and the camp category. For category three products, the amount
of information available at the time of initial risk assessment may be sufficient for all
relevant risks to be identified, assessed and controlled without the need of further risk
assessment. This won’t be true for a custom application of category 5.
R2 Risk based decisions during planning.

R3 Functional risk assessment.

Functional risk assessment should be used to identify and manage risk to patient safety,
product quality, and data integrity that arise from the failure of a function under
consideration.

Functions with impact on patient safety, product quality in data integrity are identified by
referring to the requirement specification.

When a computer system replaces a manual operation, there should not be resultant
decrease in product quality, process control or quality assurance and there should not be an
increase in the overall risk of the process.

R4 Risk based decision during test planning.


Majors identified to manage risk should be implemented and verified.

R5 Risk based decision during planning of operational activities.

RISK ASSESMENT METHODS

SELECTION AND USE OF CONTROLS


Reducing risk by establishing downstream checks or error traps means you put safety
measures in place further along in a process to catch any errors or failures that happen
earlier on.

Think of a fire alarm system in a building. The alarm is an early warning system to detect
smoke or fire. But if that fails or doesn’t go off, you still have sprinklers installed that will
automatically start spraying water if heat is detected. The sprinklers act as a downstream
check. So even if the first system fails, the sprinklers help reduce the risk of a bigger disaster.

Residual risk is the risk that remains after you’ve put all your safety measures and controls in
place. No system is 100% risk-free. So even after you’ve done everything you can to reduce
or manage risks, there’s still a small amount of risk left over. That leftover risk is called
residual risk. It’s basically what you’re still responsible for keeping an eye on even after all
precautions are in place.

RISK MANAGEMENT FOR OUTSOURCED ACTIVITIES

The use of cloud-computing services means that direct control of risk-management


processes must be delegated to a supplier in some cases. This does not absolve the
regulated company of accountability for the actions of a supplier on the regulated
company’s behalf. Supplier assessment and management processes become a critical part of
the regulated company’s QRM approach. If a supplier’s practices cannot be reconciled with
the regulated company’s QRM needs, this should be determined during the assessment and
they must be prepared to not engage the supplier if the objectionable issues cannot be
satisfactorily resolved.
Continuous monitoring of engaged suppliers of IT services to ensure that quality gaps do not
arise should be an integral, contractually obligated aspect of the supplier relationship.

Common questions

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The initial risk assessment is a critical component of Quality Risk Management (QRM) because it establishes the foundation for managing risks throughout the process lifecycle . Crucial factors to determine during this phase include whether the system falls under Good X Practice (GXP) regulations, and how the system may impact patient safety, product quality, and data integrity . Conducting this assessment at or before project initiation allows for early identification of high-risk areas and informs the development of requirement specifications . A comprehensive initial risk assessment helps ensure all relevant risks are identified and managed appropriately from the onset.

Within computerized systems, functions impacting patient safety, product quality, and data integrity are identified during the initial risk assessment phase by referring to the requirement specification . This assessment involves determining which functions have affects these critical areas and assessing potential hazards they pose. Managing these functions requires a functional risk assessment to identify and mitigate risks arising from functional failures . This process ensures the computerized system does not decrease product quality or process control compared to the manual operation it replaces and does not introduce new risks . Continuous monitoring and verification of risk-based decisions throughout the lifecycle of the system are pivotal to manage these risks effectively .

Scalability in the Quality Risk Management (QRM) process allows it to be adjusted according to the specific risk, complexity, and novelty of a given system . This means that the extent and depth of risk management activities can be tailored to align with the criticality of the system in question, ensuring that resources are effectively utilized where they are most needed. For highly complex and novel systems, more intensive risk control measures and more frequent risk reviews may be necessary . Conversely, for systems with lower risk levels or those that are well understood, QRM activities might be less comprehensive, focusing on maintaining vigilance against any identified risks.

Quality Risk Management (QRM) is crucial in pharmaceutical processes as it systematically addresses risks that could affect product quality, patient safety, or business operations. The critical steps in QRM include risk assessment, where potential hazards are identified and their likelihood and severity analyzed using tools like risk matrices or FMEA . Following this, risk control involves determining and implementing actions to mitigate or accept risks based on criteria . Furthermore, risk communication ensures clear sharing of risk-related information among stakeholders, including regulatory agencies when relevant . Lastly, risk review requires continuous monitoring and reassessment of risks and controls to adapt to new information and regulatory changes . These steps help in eliminating risks by design, reducing them to an acceptable level, and verifying the effectiveness of these controls, thus ensuring high product quality and patient safety .

Implementing QRM for custom-developed software poses challenges due to the unique nature and often increased complexity of such applications . Unlike off-the-shelf solutions, custom software requires a more detailed understanding of potential hazards and risks specific to its environment and use . Risk management must include a thorough initial risk assessment, often needing continuous reassessment as new functionality or integrations are developed. Furthermore, this requires a flexible and scalable QRM process adaptable to the evolving requirements and features of the software . In contrast, off-the-shelf solutions often have more predictable risk profiles due to their widespread use, allowing for more standardized risk management approaches.

A business should approach risk tolerance in QRM by defining clear limits on the amount of risk it is willing to accept before corrective actions must be implemented . This involves setting measurable boundaries for what constitutes acceptable risk, such as defect rates, audit findings, or process delays, and aligning these with corporate strategies and regulatory requirements . Factors determining the acceptable level of risk include the potential impact on patient safety, product quality, financial loss, and regulatory compliance . Analyzing historical data, industry benchmarks, and stakeholder expectations further inform these boundaries to ensure managed risks remain within an acceptable spectrum.

'Residual risk' in Quality Risk Management (QRM) refers to the risk that remains after all safety measures and controls have been implemented. It is an acknowledgment that no system is entirely risk-free, and some risk will always persist . The implications for ongoing risk management include the necessity for continuous monitoring and assessment of these residual risks. In a pharmaceutical setting, this means that businesses must remain vigilant in observing these risks and adjusting processes or controls as necessary to ensure they continue to fall within acceptable limits . This ongoing management helps to maintain product quality and patient safety despite the presence of residual risk.

The use of cloud-computing services impacts Quality Risk Management (QRM) by requiring the delegation of some control of risk-management processes to the supplier, which presents new challenges . To manage these risks effectively, the regulated company must conduct thorough supplier assessments and manage processes to ensure supplier practices align with the company's QRM needs . Continuous monitoring of suppliers is critical to ensure quality gaps are addressed promptly. Contractual obligations related to risk management must be clear, requiring suppliers to adhere to agreed risk control and mitigation standards. If a supplier's risk management practices do not meet requirements, the company should be prepared to disengage to protect the integrity of their QRM process .

When applying a QRM process to a new business process, key considerations include identifying potential hazards, which involve understanding where the process might fail, either due to system or user failure . It's crucial to evaluate the harm these hazards could cause, their impact, and the probability and detectability of failures occurring. Management of these risks revolves around establishing a baseline of acceptable risk, known as risk tolerance, and determining how those risks will be monitored and controlled . This involves setting measurable boundaries for accepted risk levels and ensuring rapid response should these limits be exceeded during the operations phase of the business process.

To ensure QRM controls continue to be effective over time, periodic reviews and continuous monitoring should be conducted . This involves verifying that the established controls are still aligned with the original risk assessment and effectively mitigating identified risks. Organizations must also respond to changes in process or regulatory requirements, reassess previously identified hazards, and determine the presence of previously unrecognized hazards . Control measures should be validated and adjustments made as necessary to maintain an appropriate level of risk management, incorporating feedback from these reviews into continuous improvement efforts.

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