Development & Deployment of Development & Deployment of a a Risk Based Compliance Risk Based Compliance Turnaround Strategy Turnaround Strategy John R. Pinion II John R. Pinion II Genentech, Inc. Genentech, Inc. The FDA Regulatory and The FDA Regulatory and Compliance Symposium Compliance Symposium August 24 – 26, 2005 August 24 – 26, 2005
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Development & Deployment of a Risk Based Compliance Turnaround Strategy John R. Pinion II Genentech, Inc. The FDA Regulatory and Compliance Symposium August.
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Development & Deployment of a Development & Deployment of a Risk Based Compliance Risk Based Compliance
Turnaround StrategyTurnaround Strategy
John R. Pinion IIJohn R. Pinion IIGenentech, Inc.Genentech, Inc.
Development & Deployment of a Development & Deployment of a Risk Based Compliance Risk Based Compliance
Turnaround StrategyTurnaround Strategy
John R. Pinion IIJohn R. Pinion IIGenentech, Inc.Genentech, Inc.
The FDA Regulatory and Compliance The FDA Regulatory and Compliance SymposiumSymposium
August 24 – 26, 2005August 24 – 26, 2005
The FDA Regulatory & Compliance Symposium Page 2
Development & Deployment of a Risk Based Compliance Turnaround Strategy
AgendaAgenda1. Objectives2. Keys to Success3. Risk Triggers4. Getting Started / Expectations5. Business Assessment6. Risk Assessment7. Risk Control / Mitigation8. Communication and Timing9. Execution10. Measurement / Effectiveness Review11. Questions
The FDA Regulatory & Compliance Symposium Page 3
Development & Deployment of a Risk Based Compliance Turnaround Strategy
Development & Deployment of a Risk Based Compliance Turnaround Strategy
Keys to SuccessKeys to Success1. Senior Management Recognition/Understanding of Issues2. Comprehensive Evaluation / Assessment of Business3. Effective Analysis of the Results of the Business Evaluation
(risk / gaps)4. Review of Organization and Talent5. Development of a Risk Analysis / Risk Management6. Creation of a Progress Measurement Approach7. Senior Management Acceptance of Approach8. Broad Communication of Need for Change and Action Plan9. Adequate Resources to Execute Strategy10. Implementation of Routine Senior Management Review Process11. Effectiveness Review of Mitigation Actions
The FDA Regulatory & Compliance Symposium Page 5
Development & Deployment of a Risk Based Compliance Turnaround Strategy
Risk TriggersRisk Triggers• Change in CEO & Other Senior Management
Changes• Restructuring / Mergers• Products
– New Area– New Molecular Entity
• RIF – Process Support Staff
• Regulatory Agency Quality Indicators– FCAs– Complaint Trends or Product Field Performance– Lack of Procedure Maintenance to Current cGMP's
The FDA Regulatory & Compliance Symposium Page 6
Development & Deployment of a Risk Based Compliance Turnaround Strategy
Getting Started / ExpectationsGetting Started / Expectations• Define
– Inputs to Be Included in the Business Assessment– Risk Analysis / Management Model (ISO 14971)– Cross Functional Risk Management Team– Outputs of Process
• Develop and Deploy Measurement System• Identify
– Risks– Mitigation Actions
• Verify Effectiveness of Mitigations• Establish / Initiate Communication with Appropriate Agencies
The FDA Regulatory & Compliance Symposium Page 7
Development & Deployment of a Risk Based Compliance Turnaround Strategy
Getting Started / ExpectationsGetting Started / Expectations
• Product Performance– FCAs– CAPAs– Complaints– Process Performance
Define Rating / Scoring Criteria to Help Prioritize Mitigation Actions
Define Rating / Scoring Criteria to Help Prioritize Mitigation Actions
The FDA Regulatory & Compliance Symposium Page 12
Development & Deployment of a Risk Based Compliance Turnaround Strategy
Risk Control / MitigationsDecisions / Actions to be ConsideredRisk Control / MitigationsDecisions / Actions to be Considered
• System Redesign• Management Changes• Organization Changes• FCAs• Process Improvements• Facility Capital Improvements• Retirement of Product• Facility Closure /
• Well Developed Plan• Communication / Alignment of Organization• Objective / Fact Based Measurement• Employee Training & Development• Prioritization• Visible Management Commitment• Dedicated Resources• Third Party Review of Approach / Progress• Forecast of Activity• Commitment to Make the Difficult Decisions• Verification of Effectiveness
The FDA Regulatory & Compliance Symposium Page 16
Development & Deployment of a Risk Based Compliance Turnaround Strategy
MeasurementMeasurement
Measurement Approach Objective
Risk Reduction Tracking Risk Analysis Document Verify Reduction of Risk
Mitigation Action Progress Tracking
Score CardEnsure Timely Implementation of Mitigation Actions
Product / Process Trend Data Management ReviewConfirm Effectiveness of Mitigation Actions
Internal Assessment Trends Management ReviewConfirm Effectiveness of Mitigation Actions
Third Party Assessment Results
AD Hoc ReviewConfirm Effectiveness of Mitigation Actions
The FDA Regulatory & Compliance Symposium Page 17
Development & Deployment of a Risk Based Compliance Turnaround Strategy