Montrium Connect Compliance Concerns

Hello good people of the world! Today we’re talking about a specific Software-as-a-Service (SaaS) product: Montrium’s Connect. Montrium offers a number of modules in their Connect software (Document Management, Training, CAPA, Incidents, etc.) Today I’ll focus on the Document Management module.

What makes Montrium’s offering unique is that is it built on top of Microsoft Sharepoint. I previously talked about Sharepoint Online with respect to compliance concerns here (a little out-of-date, but still relevant).

The first point I’ll make is having the application built on Sharepoint brings some significant advantages and disadvantages. The primary advantage I see, in comparison with other electronic Document Management Systems (eDMS), is that Sharepoint uses Microsoft’s Office Online suite, and arguably the world’s best online word processor: Word. I am not aware of any online word processor as fully featured as this one. I have used other eDMSs that have their own word processor and having less features can be really frustrating.

That said, Sharepoint also brings it’s clunky user interface and outdated Active Server Page (.aspx) architecture. The application won’t feel as snappy as modern websites, and you’ll see page reloads for things that would be handled by a component re-render in more modern applications. Overall the application feels very slow. I found myself having to wait minutes sometimes for items moving through a workflow to pop up in my task list.

An example of Montrium / Sharepoint UI

The first thing that struck me with the compliance aspect of Montrium’s offering is that they have categorized their Connect SOP (which is the brand name for the Document Management Module) as GAMP category 3 software. GAMP category 3 is commerical-off-the-shelf (COTS) non-configurable software. I don’t know how they consider this software non-configurable, because there is a lot of configuration options that change how it functions, including workflows. This results in end-users not creating a configuration specification and not testing the configuration to their specific intended use. This could be a compliance risk.

Another thing I noticed is the audit trail functionality. There is no interface for audit trail, instead it is automatically exported a protected Excel file every 28 days. I find it strange that the audit trail would not be available in real-time, and think this could introduce some compliance risk. It also falls into the trap of including at least some non-human readable data. See the example below:

Audit Trail Example

So just a couple points of concern with Montrium’s Connect software in a regulated use case.

What has your experience with Montrium Connect been? What is your favorite eDMS? Comment below.

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Oral Solid Dose – Supporting Equipment and Systems

Hello good people of the world! Continuing the series on oral solid dosage forms, today we’re going to talk about supporting equipment and systems. The main equipment in unit operations get the spotlight when it comes to manufacturing Oral Solid Dosage forms, but they cannot work without supporting equipment and systems.

Supporting Equipment:
Typical supporting equipment in a OSD manufacturing process includes:

1. Air Systems: all modern manufacturing processes use air systems for process, instruments, and environment. HVAC helps control environmental conditions, including particulate (viable and nonviable) counts, temperature, and humidity. Compressed air systems may be used in the process to cool or cover product, such as with nitrogen, or operate unit operation steps, such as in fluid bed drying. Automated systems will use compressed air to pneumatically control valves and other components.
2. Dust Collection: compared to biotech and other pharmacuetical processes, OSD processes have the added complication of dust collection. OSD material movement and processes can create a lot of dust, which can be a risk from a product quality point-of-view, but also a safety point-of-view, since dust can lead to fires and even explosions. Dust collection equipment must be employed to minimize and control dust.
3. Vacuum Systems: vacuum systems may be used for cleaning, dust collection, and also in process steps such as vacuum drying.

Supporting Systems:
Typical supporting systems include:

1. Change Control: it is expected that engineering changes are controlled with quality oversight through a formal process.
2. Preventive Maintenance: it is expected that regular preventive maintenance be performed and documented formally.
3. Calibration: it is expected that “critical” instruments are calibrated at regular intervals traceable to an international standard. Calibration procedures and results must be formally documented. The method to determine and results of the determination of critical instruments must be documented.

What supporting equipment and/or systems do you use in your OSD manufacturing process? Comment below!

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Oral Solid Dose – Quality Risk Management Considerations

Hello good people of the world! Today’s post is the second in the series covering the commissioning, qualification, and validation of facilities, systems, and equipment involved in the manufacture of oral solid dose (OSD) products. This post covers quality risk management.

Quality Risk Management is performed per the principles outlined in ICH Q9. The management process may then be divided up into six (6) steps:

1. Determine risk areas. These are typically safety, product quality, schedule, cost, etc.
2. Identify the risks for each area defined in step 1. For example, microbiological contamination may be a risk to product quality, APIs may be a risk to personnel safety.
3. Identify the failure modes which contribute to the risks identified in step 2. For example, pests contribute to microbiological contamination risk, and HVAC failure could be a vector by which personnel are exposed to an API.
4. Analyze failure modes and identify mitigations. In our examples procedures around pest control and qualification of HVAC systems could be mitigation to the failure modes identified.
5. Implement monitoring and CAPA (corrective and preventative action) processes.
6. Apply a continuous improvement plan to periodically review risks, risk assessments, and mitigation.

There are many tools which may be used to document the process, such as: FMEA, HAZOP, PHA, etc.

How do you execute your quality risk management process?

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Corrective Action / Preventive Action (CAPA)

Hello good people of the world! Today’s post is about Corrective Action / Preventive Action, typically referred to as CAPA. CAPA is an integral part of any Quality System, and certainly one of the first things an agency will look at in any audit.

There is a ton of good information out there already on CAPA, including FDA’s own guidance from 2014.

I’ve personally used a few software packages for CAPA management, including MasterControl and Oracle’s Agile, among others, but have not seen any standouts.

The key points of the CAPA program are:

1. Issue identification, i.e. ensuring the issue is truly understood and well documented
2. Root cause analysis, i.e. identifying the root cause of the issue
3. effectiveness check, i.e. verifying actions have actually resolved the issue

What tips have you learned from your CAPA program? Comment below.

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WHO’s Draft Guidelines on Validation May 2016

Hello good people of the world! On May 15, 2016, the World Health Organization released its draft Guidelines on Validation. It is available on the WHO website for download here.

This post covers my review of the guidance.

Quality During Construction

Hello good people of the world! This blog post covers Construction Quality Assurance, based on an article that appeared in the Nov/Dec 2012 edition of Pharmaceutical Engineering titled “Assured Construction Quality Saves Time and Money.” All credit goes to the authors: Jay Lad of Skanska Pharmaceutical Group and Bruce Beck of Eli Lilly.

Revision to EudraLex Volume 4 August 2014

Hello good people of the world! Another short post today, this one on the revision to EudraLex Volume 4 (GMPs) dated 13 August 2014. The revision is here. A short revision, the changes include updates to Chapter 3 (Premises and Equipment) and Chapter 5 (Production) around prevention of cross-contamination and qualification of suppliers.

Of note is the increased guidance around the use of quality risk management principles.

The revision will come into affect in March 2015.

What do you think of these changes? How will you adjust your quality program, if at all?

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Quality Metrics

Metrics

Hello, good people of the world! If you know me, then you know I’m into “metrics” – ways to evaluate the health of a system or process quantitatively. We know finding and correctly interpreting the “right” metrics is not trivial, and looking at the “wrong” metrics can do more harm then good.

ISPE has recently released a whitepaper suggesting quality metrics for the FDA to use in their inspection process. I’ve uploaded a copy