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Page 1: Risk Management Training

Company

LOGO

Quality Improvement Consulting LLC

Risk Management

What Is Risk

bull Risk may be defined as the possibility of suffering damage or loss

Possibility

The possibility is characterized by three factors

bull probability or likelihood that loss or damage will occur

bull The expected time of occurrence

bull The magnitude of the negative impact that can result from its occurrence

What Is Risk Management

bull A Determination of the probability of

occurrence of a process failure amp the

negative effect or impact if it does

bull Putting in place preventive actions to

mitigate those risks that are determined to

be most likely to happen and will have a

server impact to the process

What Is Acceptable Risk

A decision process thatbull Specifies the objectives to measure

the desirability or lack thereofbull Defines possible options including

no actionbull Identifies the consequences of each

option and likelihood of occurrencebull Specifying the desirability of

consequencesbull Analyzing the options and selecting

the ldquomost acceptablerdquo option

The Seriousness of a Risk

This can be determined by multiplying the probability of the event actually occurring by the potential negative impact to cost schedule or performance

Risk Severity = Probability of Occurrence x Potential Negative Impact

Potential Risk Scenarios

bull Scenario 1 Probability of occurrence is high and the potential impact is very low

bull Scenario 2 Probability of occurrence is low and the potential impact is very high

bull Scenario 3 Probability of occurrence is low and the potential impact is very low

bull Scenario 4 Probability of occurrence is high and the potential impact is very high

Ways to Deal With Risk

bull Proactive approach Risk Managementndash Analyzes future project events and past

projectsndash Identify potential risksndash Taking measures to reduce their probability

and or impactbull Reactive approach Crisis Management

ndash Resource-intensivendash Available options constrained or restricted by

events

Systems of Feedback

bull Design feedbackbull Management Reviewbull Risk Management

bull Customer Complaintsbull CAPA Escalationbull Acceptable Risk

Proactive

Reactive

Balance

Risk

Benefit

Why Risk as Part of CAPA System

bull What is the impact of risk to the CAPA

system

bull What hurdles will you encounter

CAPA Connecting RiskManagement and Trending

Critical questions that drive into the CAPA process and determine the depth of investigationpriority of CAPAndash Is this a new or unknown problemndash Has the severity increased Decreasedndash Has the frequency of occurrence

increasedndash Have the causes of the problem been

confirmedndash Are there new causes of the problem

that have inadequate or no mitigation

Key Definitions

Nonconformance (NC)bull Any noncompliance with the requirements of the Quality

System (product and non-product)Correctionbull Repair rework or adjustment related to the disposition of an

existingnonconformity Corrections are typically one-time fixesCorrective Action (CA)bull Action taken to eliminate the causes of an existing

nonconformity defect or other undesirable situation in order to prevent recurrence

Preventive Action (PA)bull Action taken to eliminate the cause of a potential

nonconformity defect or other undesirable situation in order to prevent occurrence and improve quality trends

CAPA Process

Failure Investigation(Root Cause Analysis)

CAPA Plan

Approval andDissemination

Implementation(Change Control)

Follow-up for Effectiveness

Problem Identification (Risk Assessment)

Closure

Not EffectiveEffective

Inputs and Triggers -Internal

bull Acceptance activitiesbull Calibration and Maintenance recordsbull Design Control systembull Management ReviewsAnnual Product Reviewsbull Nonconformances (product and non-product)bull Packaging and Labeling materialsbull Quality Auditsbull Returned productsbull Risk Management documentsbull Service and Installation recordsbull Six SigmaProcess Excellence programsbull SPC monitoringbull And morehellip

Inputs and Triggers-External

bull Customer complaintsbull Customer feedbackbull External Quality Audit reportsbull ISOAS 9100 feedbackbull Product warrantybull Recallsfield actionsbull Identification of any other conditionissue that

does not comply withbull Your own Quality System andorbull ISOAS standards (eg ISO 9001 AS 9100 etc)bull And morehellip

Inputs and Triggers- Issues

bull Inputs not clearly defined or established

bull Trigger thresholds not establishedbull Focus on reactive metrics

(Nonconformances Complaints Audit

Observations)bull Data not easily retrievablebull Data not easy to analyze for trends

Root Cause Analysis-Issues

bull Poorlack of technical skills to conduct root cause analysis

bull Poorlack of writing skills in documenting root cause analysis

bull Poorlittle business knowledge in conducting root cause analysis across processes systems product lines and Quality Systems

Preventive Actions- Issues

bull When everything is corrective how can the organization assign resources to address Preventive Action

bull Risk assessment may not be designed to address elevation to CAPA for a potential issue or improvement (Preventive Action)

bull CAPA metrics tend to focus on closure rates cycle time number of open CAPAs etc Preventive Actions are in most cases longer-term solutions across processes systems product lines and Quality Systems and will take more time to close

From Corrective to Preventive

bull Clearly define inputs and establish thresholds

bull Implement predictive metricsindicators

bull Routinely review and act on sources of product and quality data

bull Make data reporting available and easy to users and management

From Corrective to Preventive

Risk Managementbull Establish elevation mechanisms to CAPAbull Use a risk assessment process to allow

prioritization of CAPAs and elevation to Management

bull Use a risk assessment process that allows CAPAs for Preventive Action

bull Link CAPA to Risk Management documentation (eg Design Control documents)

bull Make data reporting available and easy to users and management

From Corrective to Preventive

Root Cause Analysisbull Establish clear roles and responsibilities

for conducting investigationbull Increase technical skills on root cause

analysis toolsbull Improve writing skillsbull Use team approach to conduct

investigation to increase business and technical knowledge

From Corrective to Preventive

Preventive Actionbull Implement predictive metricsindicatorsbull Routinely review and act on sources of product

and quality databull Use a risk assessment process that allows CAPAs

for Preventive Actionbull Improve linkage between CAPA into Design

Controlsbull Take a holistic view of issuesbull Can it link to other Quality Systems product lines

systems andor processes

From Corrective to Preventive

Management Support and Oversightbull Ensure Management oversight and

commitmentbull Align CAPA with company departmental

and individual goals and objectivesbull Create rewards and recognition programsbull Establish joint partnership between

businesssystem owner and Information Technology for continuous improvement efforts

bull Align metrics from departmental to corporate level

Annual Product Review - Requirements

Written records subject to this review include but are not limited to the following

1048713 Manufacturing and quality records from lots or batches of products manufactured within the previous year including

bull ndash receiving inspectionbull ndash in-processbull ndash final release testing resultsbull ndash deviationsbull ndash investigationsbull ndash change control recordsbull ndash quality system trends

Annual Product Review - Requirements

Post market quality records such as

ndash Customer complaintsndash Adverse eventsndash Field actionsndash Product correctionsndash Regulatory submissionsndash Returned or salvaged products

Conclusions - Annual Product Review

bull Covers the product cradle to grave Presents management a view of product and process behavior over time

bull Is influenced by all aspects of the Quality System - including in process and release testing

bull Supports decisions related to design control process validation and control as well as user drift

bull Identifies trendsopportunities across mfg lines or sites

  • Slide 1
  • What Is Risk
  • Possibility
  • What Is Risk Management
  • What Is Acceptable Risk
  • The Seriousness of a Risk
  • Potential Risk Scenarios
  • Ways to Deal With Risk
  • Systems of Feedback
  • Balance
  • Why Risk as Part of CAPA System
  • CAPA Connecting Risk Management and Trending
  • Key Definitions
  • CAPA Process
  • Inputs and Triggers -Internal
  • Inputs and Triggers-External
  • Inputs and Triggers- Issues
  • Root Cause Analysis-Issues
  • Preventive Actions- Issues
  • From Corrective to Preventive
  • From Corrective to Preventive (2)
  • From Corrective to Preventive (3)
  • From Corrective to Preventive (4)
  • From Corrective to Preventive (5)
  • Annual Product Review - Requirements
  • Annual Product Review - Requirements (2)
  • Conclusions - Annual Product Review
Page 2: Risk Management Training

What Is Risk

bull Risk may be defined as the possibility of suffering damage or loss

Possibility

The possibility is characterized by three factors

bull probability or likelihood that loss or damage will occur

bull The expected time of occurrence

bull The magnitude of the negative impact that can result from its occurrence

What Is Risk Management

bull A Determination of the probability of

occurrence of a process failure amp the

negative effect or impact if it does

bull Putting in place preventive actions to

mitigate those risks that are determined to

be most likely to happen and will have a

server impact to the process

What Is Acceptable Risk

A decision process thatbull Specifies the objectives to measure

the desirability or lack thereofbull Defines possible options including

no actionbull Identifies the consequences of each

option and likelihood of occurrencebull Specifying the desirability of

consequencesbull Analyzing the options and selecting

the ldquomost acceptablerdquo option

The Seriousness of a Risk

This can be determined by multiplying the probability of the event actually occurring by the potential negative impact to cost schedule or performance

Risk Severity = Probability of Occurrence x Potential Negative Impact

Potential Risk Scenarios

bull Scenario 1 Probability of occurrence is high and the potential impact is very low

bull Scenario 2 Probability of occurrence is low and the potential impact is very high

bull Scenario 3 Probability of occurrence is low and the potential impact is very low

bull Scenario 4 Probability of occurrence is high and the potential impact is very high

Ways to Deal With Risk

bull Proactive approach Risk Managementndash Analyzes future project events and past

projectsndash Identify potential risksndash Taking measures to reduce their probability

and or impactbull Reactive approach Crisis Management

ndash Resource-intensivendash Available options constrained or restricted by

events

Systems of Feedback

bull Design feedbackbull Management Reviewbull Risk Management

bull Customer Complaintsbull CAPA Escalationbull Acceptable Risk

Proactive

Reactive

Balance

Risk

Benefit

Why Risk as Part of CAPA System

bull What is the impact of risk to the CAPA

system

bull What hurdles will you encounter

CAPA Connecting RiskManagement and Trending

Critical questions that drive into the CAPA process and determine the depth of investigationpriority of CAPAndash Is this a new or unknown problemndash Has the severity increased Decreasedndash Has the frequency of occurrence

increasedndash Have the causes of the problem been

confirmedndash Are there new causes of the problem

that have inadequate or no mitigation

Key Definitions

Nonconformance (NC)bull Any noncompliance with the requirements of the Quality

System (product and non-product)Correctionbull Repair rework or adjustment related to the disposition of an

existingnonconformity Corrections are typically one-time fixesCorrective Action (CA)bull Action taken to eliminate the causes of an existing

nonconformity defect or other undesirable situation in order to prevent recurrence

Preventive Action (PA)bull Action taken to eliminate the cause of a potential

nonconformity defect or other undesirable situation in order to prevent occurrence and improve quality trends

CAPA Process

Failure Investigation(Root Cause Analysis)

CAPA Plan

Approval andDissemination

Implementation(Change Control)

Follow-up for Effectiveness

Problem Identification (Risk Assessment)

Closure

Not EffectiveEffective

Inputs and Triggers -Internal

bull Acceptance activitiesbull Calibration and Maintenance recordsbull Design Control systembull Management ReviewsAnnual Product Reviewsbull Nonconformances (product and non-product)bull Packaging and Labeling materialsbull Quality Auditsbull Returned productsbull Risk Management documentsbull Service and Installation recordsbull Six SigmaProcess Excellence programsbull SPC monitoringbull And morehellip

Inputs and Triggers-External

bull Customer complaintsbull Customer feedbackbull External Quality Audit reportsbull ISOAS 9100 feedbackbull Product warrantybull Recallsfield actionsbull Identification of any other conditionissue that

does not comply withbull Your own Quality System andorbull ISOAS standards (eg ISO 9001 AS 9100 etc)bull And morehellip

Inputs and Triggers- Issues

bull Inputs not clearly defined or established

bull Trigger thresholds not establishedbull Focus on reactive metrics

(Nonconformances Complaints Audit

Observations)bull Data not easily retrievablebull Data not easy to analyze for trends

Root Cause Analysis-Issues

bull Poorlack of technical skills to conduct root cause analysis

bull Poorlack of writing skills in documenting root cause analysis

bull Poorlittle business knowledge in conducting root cause analysis across processes systems product lines and Quality Systems

Preventive Actions- Issues

bull When everything is corrective how can the organization assign resources to address Preventive Action

bull Risk assessment may not be designed to address elevation to CAPA for a potential issue or improvement (Preventive Action)

bull CAPA metrics tend to focus on closure rates cycle time number of open CAPAs etc Preventive Actions are in most cases longer-term solutions across processes systems product lines and Quality Systems and will take more time to close

From Corrective to Preventive

bull Clearly define inputs and establish thresholds

bull Implement predictive metricsindicators

bull Routinely review and act on sources of product and quality data

bull Make data reporting available and easy to users and management

From Corrective to Preventive

Risk Managementbull Establish elevation mechanisms to CAPAbull Use a risk assessment process to allow

prioritization of CAPAs and elevation to Management

bull Use a risk assessment process that allows CAPAs for Preventive Action

bull Link CAPA to Risk Management documentation (eg Design Control documents)

bull Make data reporting available and easy to users and management

From Corrective to Preventive

Root Cause Analysisbull Establish clear roles and responsibilities

for conducting investigationbull Increase technical skills on root cause

analysis toolsbull Improve writing skillsbull Use team approach to conduct

investigation to increase business and technical knowledge

From Corrective to Preventive

Preventive Actionbull Implement predictive metricsindicatorsbull Routinely review and act on sources of product

and quality databull Use a risk assessment process that allows CAPAs

for Preventive Actionbull Improve linkage between CAPA into Design

Controlsbull Take a holistic view of issuesbull Can it link to other Quality Systems product lines

systems andor processes

From Corrective to Preventive

Management Support and Oversightbull Ensure Management oversight and

commitmentbull Align CAPA with company departmental

and individual goals and objectivesbull Create rewards and recognition programsbull Establish joint partnership between

businesssystem owner and Information Technology for continuous improvement efforts

bull Align metrics from departmental to corporate level

Annual Product Review - Requirements

Written records subject to this review include but are not limited to the following

1048713 Manufacturing and quality records from lots or batches of products manufactured within the previous year including

bull ndash receiving inspectionbull ndash in-processbull ndash final release testing resultsbull ndash deviationsbull ndash investigationsbull ndash change control recordsbull ndash quality system trends

Annual Product Review - Requirements

Post market quality records such as

ndash Customer complaintsndash Adverse eventsndash Field actionsndash Product correctionsndash Regulatory submissionsndash Returned or salvaged products

Conclusions - Annual Product Review

bull Covers the product cradle to grave Presents management a view of product and process behavior over time

bull Is influenced by all aspects of the Quality System - including in process and release testing

bull Supports decisions related to design control process validation and control as well as user drift

bull Identifies trendsopportunities across mfg lines or sites

  • Slide 1
  • What Is Risk
  • Possibility
  • What Is Risk Management
  • What Is Acceptable Risk
  • The Seriousness of a Risk
  • Potential Risk Scenarios
  • Ways to Deal With Risk
  • Systems of Feedback
  • Balance
  • Why Risk as Part of CAPA System
  • CAPA Connecting Risk Management and Trending
  • Key Definitions
  • CAPA Process
  • Inputs and Triggers -Internal
  • Inputs and Triggers-External
  • Inputs and Triggers- Issues
  • Root Cause Analysis-Issues
  • Preventive Actions- Issues
  • From Corrective to Preventive
  • From Corrective to Preventive (2)
  • From Corrective to Preventive (3)
  • From Corrective to Preventive (4)
  • From Corrective to Preventive (5)
  • Annual Product Review - Requirements
  • Annual Product Review - Requirements (2)
  • Conclusions - Annual Product Review
Page 3: Risk Management Training

Possibility

The possibility is characterized by three factors

bull probability or likelihood that loss or damage will occur

bull The expected time of occurrence

bull The magnitude of the negative impact that can result from its occurrence

What Is Risk Management

bull A Determination of the probability of

occurrence of a process failure amp the

negative effect or impact if it does

bull Putting in place preventive actions to

mitigate those risks that are determined to

be most likely to happen and will have a

server impact to the process

What Is Acceptable Risk

A decision process thatbull Specifies the objectives to measure

the desirability or lack thereofbull Defines possible options including

no actionbull Identifies the consequences of each

option and likelihood of occurrencebull Specifying the desirability of

consequencesbull Analyzing the options and selecting

the ldquomost acceptablerdquo option

The Seriousness of a Risk

This can be determined by multiplying the probability of the event actually occurring by the potential negative impact to cost schedule or performance

Risk Severity = Probability of Occurrence x Potential Negative Impact

Potential Risk Scenarios

bull Scenario 1 Probability of occurrence is high and the potential impact is very low

bull Scenario 2 Probability of occurrence is low and the potential impact is very high

bull Scenario 3 Probability of occurrence is low and the potential impact is very low

bull Scenario 4 Probability of occurrence is high and the potential impact is very high

Ways to Deal With Risk

bull Proactive approach Risk Managementndash Analyzes future project events and past

projectsndash Identify potential risksndash Taking measures to reduce their probability

and or impactbull Reactive approach Crisis Management

ndash Resource-intensivendash Available options constrained or restricted by

events

Systems of Feedback

bull Design feedbackbull Management Reviewbull Risk Management

bull Customer Complaintsbull CAPA Escalationbull Acceptable Risk

Proactive

Reactive

Balance

Risk

Benefit

Why Risk as Part of CAPA System

bull What is the impact of risk to the CAPA

system

bull What hurdles will you encounter

CAPA Connecting RiskManagement and Trending

Critical questions that drive into the CAPA process and determine the depth of investigationpriority of CAPAndash Is this a new or unknown problemndash Has the severity increased Decreasedndash Has the frequency of occurrence

increasedndash Have the causes of the problem been

confirmedndash Are there new causes of the problem

that have inadequate or no mitigation

Key Definitions

Nonconformance (NC)bull Any noncompliance with the requirements of the Quality

System (product and non-product)Correctionbull Repair rework or adjustment related to the disposition of an

existingnonconformity Corrections are typically one-time fixesCorrective Action (CA)bull Action taken to eliminate the causes of an existing

nonconformity defect or other undesirable situation in order to prevent recurrence

Preventive Action (PA)bull Action taken to eliminate the cause of a potential

nonconformity defect or other undesirable situation in order to prevent occurrence and improve quality trends

CAPA Process

Failure Investigation(Root Cause Analysis)

CAPA Plan

Approval andDissemination

Implementation(Change Control)

Follow-up for Effectiveness

Problem Identification (Risk Assessment)

Closure

Not EffectiveEffective

Inputs and Triggers -Internal

bull Acceptance activitiesbull Calibration and Maintenance recordsbull Design Control systembull Management ReviewsAnnual Product Reviewsbull Nonconformances (product and non-product)bull Packaging and Labeling materialsbull Quality Auditsbull Returned productsbull Risk Management documentsbull Service and Installation recordsbull Six SigmaProcess Excellence programsbull SPC monitoringbull And morehellip

Inputs and Triggers-External

bull Customer complaintsbull Customer feedbackbull External Quality Audit reportsbull ISOAS 9100 feedbackbull Product warrantybull Recallsfield actionsbull Identification of any other conditionissue that

does not comply withbull Your own Quality System andorbull ISOAS standards (eg ISO 9001 AS 9100 etc)bull And morehellip

Inputs and Triggers- Issues

bull Inputs not clearly defined or established

bull Trigger thresholds not establishedbull Focus on reactive metrics

(Nonconformances Complaints Audit

Observations)bull Data not easily retrievablebull Data not easy to analyze for trends

Root Cause Analysis-Issues

bull Poorlack of technical skills to conduct root cause analysis

bull Poorlack of writing skills in documenting root cause analysis

bull Poorlittle business knowledge in conducting root cause analysis across processes systems product lines and Quality Systems

Preventive Actions- Issues

bull When everything is corrective how can the organization assign resources to address Preventive Action

bull Risk assessment may not be designed to address elevation to CAPA for a potential issue or improvement (Preventive Action)

bull CAPA metrics tend to focus on closure rates cycle time number of open CAPAs etc Preventive Actions are in most cases longer-term solutions across processes systems product lines and Quality Systems and will take more time to close

From Corrective to Preventive

bull Clearly define inputs and establish thresholds

bull Implement predictive metricsindicators

bull Routinely review and act on sources of product and quality data

bull Make data reporting available and easy to users and management

From Corrective to Preventive

Risk Managementbull Establish elevation mechanisms to CAPAbull Use a risk assessment process to allow

prioritization of CAPAs and elevation to Management

bull Use a risk assessment process that allows CAPAs for Preventive Action

bull Link CAPA to Risk Management documentation (eg Design Control documents)

bull Make data reporting available and easy to users and management

From Corrective to Preventive

Root Cause Analysisbull Establish clear roles and responsibilities

for conducting investigationbull Increase technical skills on root cause

analysis toolsbull Improve writing skillsbull Use team approach to conduct

investigation to increase business and technical knowledge

From Corrective to Preventive

Preventive Actionbull Implement predictive metricsindicatorsbull Routinely review and act on sources of product

and quality databull Use a risk assessment process that allows CAPAs

for Preventive Actionbull Improve linkage between CAPA into Design

Controlsbull Take a holistic view of issuesbull Can it link to other Quality Systems product lines

systems andor processes

From Corrective to Preventive

Management Support and Oversightbull Ensure Management oversight and

commitmentbull Align CAPA with company departmental

and individual goals and objectivesbull Create rewards and recognition programsbull Establish joint partnership between

businesssystem owner and Information Technology for continuous improvement efforts

bull Align metrics from departmental to corporate level

Annual Product Review - Requirements

Written records subject to this review include but are not limited to the following

1048713 Manufacturing and quality records from lots or batches of products manufactured within the previous year including

bull ndash receiving inspectionbull ndash in-processbull ndash final release testing resultsbull ndash deviationsbull ndash investigationsbull ndash change control recordsbull ndash quality system trends

Annual Product Review - Requirements

Post market quality records such as

ndash Customer complaintsndash Adverse eventsndash Field actionsndash Product correctionsndash Regulatory submissionsndash Returned or salvaged products

Conclusions - Annual Product Review

bull Covers the product cradle to grave Presents management a view of product and process behavior over time

bull Is influenced by all aspects of the Quality System - including in process and release testing

bull Supports decisions related to design control process validation and control as well as user drift

bull Identifies trendsopportunities across mfg lines or sites

  • Slide 1
  • What Is Risk
  • Possibility
  • What Is Risk Management
  • What Is Acceptable Risk
  • The Seriousness of a Risk
  • Potential Risk Scenarios
  • Ways to Deal With Risk
  • Systems of Feedback
  • Balance
  • Why Risk as Part of CAPA System
  • CAPA Connecting Risk Management and Trending
  • Key Definitions
  • CAPA Process
  • Inputs and Triggers -Internal
  • Inputs and Triggers-External
  • Inputs and Triggers- Issues
  • Root Cause Analysis-Issues
  • Preventive Actions- Issues
  • From Corrective to Preventive
  • From Corrective to Preventive (2)
  • From Corrective to Preventive (3)
  • From Corrective to Preventive (4)
  • From Corrective to Preventive (5)
  • Annual Product Review - Requirements
  • Annual Product Review - Requirements (2)
  • Conclusions - Annual Product Review
Page 4: Risk Management Training

What Is Risk Management

bull A Determination of the probability of

occurrence of a process failure amp the

negative effect or impact if it does

bull Putting in place preventive actions to

mitigate those risks that are determined to

be most likely to happen and will have a

server impact to the process

What Is Acceptable Risk

A decision process thatbull Specifies the objectives to measure

the desirability or lack thereofbull Defines possible options including

no actionbull Identifies the consequences of each

option and likelihood of occurrencebull Specifying the desirability of

consequencesbull Analyzing the options and selecting

the ldquomost acceptablerdquo option

The Seriousness of a Risk

This can be determined by multiplying the probability of the event actually occurring by the potential negative impact to cost schedule or performance

Risk Severity = Probability of Occurrence x Potential Negative Impact

Potential Risk Scenarios

bull Scenario 1 Probability of occurrence is high and the potential impact is very low

bull Scenario 2 Probability of occurrence is low and the potential impact is very high

bull Scenario 3 Probability of occurrence is low and the potential impact is very low

bull Scenario 4 Probability of occurrence is high and the potential impact is very high

Ways to Deal With Risk

bull Proactive approach Risk Managementndash Analyzes future project events and past

projectsndash Identify potential risksndash Taking measures to reduce their probability

and or impactbull Reactive approach Crisis Management

ndash Resource-intensivendash Available options constrained or restricted by

events

Systems of Feedback

bull Design feedbackbull Management Reviewbull Risk Management

bull Customer Complaintsbull CAPA Escalationbull Acceptable Risk

Proactive

Reactive

Balance

Risk

Benefit

Why Risk as Part of CAPA System

bull What is the impact of risk to the CAPA

system

bull What hurdles will you encounter

CAPA Connecting RiskManagement and Trending

Critical questions that drive into the CAPA process and determine the depth of investigationpriority of CAPAndash Is this a new or unknown problemndash Has the severity increased Decreasedndash Has the frequency of occurrence

increasedndash Have the causes of the problem been

confirmedndash Are there new causes of the problem

that have inadequate or no mitigation

Key Definitions

Nonconformance (NC)bull Any noncompliance with the requirements of the Quality

System (product and non-product)Correctionbull Repair rework or adjustment related to the disposition of an

existingnonconformity Corrections are typically one-time fixesCorrective Action (CA)bull Action taken to eliminate the causes of an existing

nonconformity defect or other undesirable situation in order to prevent recurrence

Preventive Action (PA)bull Action taken to eliminate the cause of a potential

nonconformity defect or other undesirable situation in order to prevent occurrence and improve quality trends

CAPA Process

Failure Investigation(Root Cause Analysis)

CAPA Plan

Approval andDissemination

Implementation(Change Control)

Follow-up for Effectiveness

Problem Identification (Risk Assessment)

Closure

Not EffectiveEffective

Inputs and Triggers -Internal

bull Acceptance activitiesbull Calibration and Maintenance recordsbull Design Control systembull Management ReviewsAnnual Product Reviewsbull Nonconformances (product and non-product)bull Packaging and Labeling materialsbull Quality Auditsbull Returned productsbull Risk Management documentsbull Service and Installation recordsbull Six SigmaProcess Excellence programsbull SPC monitoringbull And morehellip

Inputs and Triggers-External

bull Customer complaintsbull Customer feedbackbull External Quality Audit reportsbull ISOAS 9100 feedbackbull Product warrantybull Recallsfield actionsbull Identification of any other conditionissue that

does not comply withbull Your own Quality System andorbull ISOAS standards (eg ISO 9001 AS 9100 etc)bull And morehellip

Inputs and Triggers- Issues

bull Inputs not clearly defined or established

bull Trigger thresholds not establishedbull Focus on reactive metrics

(Nonconformances Complaints Audit

Observations)bull Data not easily retrievablebull Data not easy to analyze for trends

Root Cause Analysis-Issues

bull Poorlack of technical skills to conduct root cause analysis

bull Poorlack of writing skills in documenting root cause analysis

bull Poorlittle business knowledge in conducting root cause analysis across processes systems product lines and Quality Systems

Preventive Actions- Issues

bull When everything is corrective how can the organization assign resources to address Preventive Action

bull Risk assessment may not be designed to address elevation to CAPA for a potential issue or improvement (Preventive Action)

bull CAPA metrics tend to focus on closure rates cycle time number of open CAPAs etc Preventive Actions are in most cases longer-term solutions across processes systems product lines and Quality Systems and will take more time to close

From Corrective to Preventive

bull Clearly define inputs and establish thresholds

bull Implement predictive metricsindicators

bull Routinely review and act on sources of product and quality data

bull Make data reporting available and easy to users and management

From Corrective to Preventive

Risk Managementbull Establish elevation mechanisms to CAPAbull Use a risk assessment process to allow

prioritization of CAPAs and elevation to Management

bull Use a risk assessment process that allows CAPAs for Preventive Action

bull Link CAPA to Risk Management documentation (eg Design Control documents)

bull Make data reporting available and easy to users and management

From Corrective to Preventive

Root Cause Analysisbull Establish clear roles and responsibilities

for conducting investigationbull Increase technical skills on root cause

analysis toolsbull Improve writing skillsbull Use team approach to conduct

investigation to increase business and technical knowledge

From Corrective to Preventive

Preventive Actionbull Implement predictive metricsindicatorsbull Routinely review and act on sources of product

and quality databull Use a risk assessment process that allows CAPAs

for Preventive Actionbull Improve linkage between CAPA into Design

Controlsbull Take a holistic view of issuesbull Can it link to other Quality Systems product lines

systems andor processes

From Corrective to Preventive

Management Support and Oversightbull Ensure Management oversight and

commitmentbull Align CAPA with company departmental

and individual goals and objectivesbull Create rewards and recognition programsbull Establish joint partnership between

businesssystem owner and Information Technology for continuous improvement efforts

bull Align metrics from departmental to corporate level

Annual Product Review - Requirements

Written records subject to this review include but are not limited to the following

1048713 Manufacturing and quality records from lots or batches of products manufactured within the previous year including

bull ndash receiving inspectionbull ndash in-processbull ndash final release testing resultsbull ndash deviationsbull ndash investigationsbull ndash change control recordsbull ndash quality system trends

Annual Product Review - Requirements

Post market quality records such as

ndash Customer complaintsndash Adverse eventsndash Field actionsndash Product correctionsndash Regulatory submissionsndash Returned or salvaged products

Conclusions - Annual Product Review

bull Covers the product cradle to grave Presents management a view of product and process behavior over time

bull Is influenced by all aspects of the Quality System - including in process and release testing

bull Supports decisions related to design control process validation and control as well as user drift

bull Identifies trendsopportunities across mfg lines or sites

  • Slide 1
  • What Is Risk
  • Possibility
  • What Is Risk Management
  • What Is Acceptable Risk
  • The Seriousness of a Risk
  • Potential Risk Scenarios
  • Ways to Deal With Risk
  • Systems of Feedback
  • Balance
  • Why Risk as Part of CAPA System
  • CAPA Connecting Risk Management and Trending
  • Key Definitions
  • CAPA Process
  • Inputs and Triggers -Internal
  • Inputs and Triggers-External
  • Inputs and Triggers- Issues
  • Root Cause Analysis-Issues
  • Preventive Actions- Issues
  • From Corrective to Preventive
  • From Corrective to Preventive (2)
  • From Corrective to Preventive (3)
  • From Corrective to Preventive (4)
  • From Corrective to Preventive (5)
  • Annual Product Review - Requirements
  • Annual Product Review - Requirements (2)
  • Conclusions - Annual Product Review
Page 5: Risk Management Training

What Is Acceptable Risk

A decision process thatbull Specifies the objectives to measure

the desirability or lack thereofbull Defines possible options including

no actionbull Identifies the consequences of each

option and likelihood of occurrencebull Specifying the desirability of

consequencesbull Analyzing the options and selecting

the ldquomost acceptablerdquo option

The Seriousness of a Risk

This can be determined by multiplying the probability of the event actually occurring by the potential negative impact to cost schedule or performance

Risk Severity = Probability of Occurrence x Potential Negative Impact

Potential Risk Scenarios

bull Scenario 1 Probability of occurrence is high and the potential impact is very low

bull Scenario 2 Probability of occurrence is low and the potential impact is very high

bull Scenario 3 Probability of occurrence is low and the potential impact is very low

bull Scenario 4 Probability of occurrence is high and the potential impact is very high

Ways to Deal With Risk

bull Proactive approach Risk Managementndash Analyzes future project events and past

projectsndash Identify potential risksndash Taking measures to reduce their probability

and or impactbull Reactive approach Crisis Management

ndash Resource-intensivendash Available options constrained or restricted by

events

Systems of Feedback

bull Design feedbackbull Management Reviewbull Risk Management

bull Customer Complaintsbull CAPA Escalationbull Acceptable Risk

Proactive

Reactive

Balance

Risk

Benefit

Why Risk as Part of CAPA System

bull What is the impact of risk to the CAPA

system

bull What hurdles will you encounter

CAPA Connecting RiskManagement and Trending

Critical questions that drive into the CAPA process and determine the depth of investigationpriority of CAPAndash Is this a new or unknown problemndash Has the severity increased Decreasedndash Has the frequency of occurrence

increasedndash Have the causes of the problem been

confirmedndash Are there new causes of the problem

that have inadequate or no mitigation

Key Definitions

Nonconformance (NC)bull Any noncompliance with the requirements of the Quality

System (product and non-product)Correctionbull Repair rework or adjustment related to the disposition of an

existingnonconformity Corrections are typically one-time fixesCorrective Action (CA)bull Action taken to eliminate the causes of an existing

nonconformity defect or other undesirable situation in order to prevent recurrence

Preventive Action (PA)bull Action taken to eliminate the cause of a potential

nonconformity defect or other undesirable situation in order to prevent occurrence and improve quality trends

CAPA Process

Failure Investigation(Root Cause Analysis)

CAPA Plan

Approval andDissemination

Implementation(Change Control)

Follow-up for Effectiveness

Problem Identification (Risk Assessment)

Closure

Not EffectiveEffective

Inputs and Triggers -Internal

bull Acceptance activitiesbull Calibration and Maintenance recordsbull Design Control systembull Management ReviewsAnnual Product Reviewsbull Nonconformances (product and non-product)bull Packaging and Labeling materialsbull Quality Auditsbull Returned productsbull Risk Management documentsbull Service and Installation recordsbull Six SigmaProcess Excellence programsbull SPC monitoringbull And morehellip

Inputs and Triggers-External

bull Customer complaintsbull Customer feedbackbull External Quality Audit reportsbull ISOAS 9100 feedbackbull Product warrantybull Recallsfield actionsbull Identification of any other conditionissue that

does not comply withbull Your own Quality System andorbull ISOAS standards (eg ISO 9001 AS 9100 etc)bull And morehellip

Inputs and Triggers- Issues

bull Inputs not clearly defined or established

bull Trigger thresholds not establishedbull Focus on reactive metrics

(Nonconformances Complaints Audit

Observations)bull Data not easily retrievablebull Data not easy to analyze for trends

Root Cause Analysis-Issues

bull Poorlack of technical skills to conduct root cause analysis

bull Poorlack of writing skills in documenting root cause analysis

bull Poorlittle business knowledge in conducting root cause analysis across processes systems product lines and Quality Systems

Preventive Actions- Issues

bull When everything is corrective how can the organization assign resources to address Preventive Action

bull Risk assessment may not be designed to address elevation to CAPA for a potential issue or improvement (Preventive Action)

bull CAPA metrics tend to focus on closure rates cycle time number of open CAPAs etc Preventive Actions are in most cases longer-term solutions across processes systems product lines and Quality Systems and will take more time to close

From Corrective to Preventive

bull Clearly define inputs and establish thresholds

bull Implement predictive metricsindicators

bull Routinely review and act on sources of product and quality data

bull Make data reporting available and easy to users and management

From Corrective to Preventive

Risk Managementbull Establish elevation mechanisms to CAPAbull Use a risk assessment process to allow

prioritization of CAPAs and elevation to Management

bull Use a risk assessment process that allows CAPAs for Preventive Action

bull Link CAPA to Risk Management documentation (eg Design Control documents)

bull Make data reporting available and easy to users and management

From Corrective to Preventive

Root Cause Analysisbull Establish clear roles and responsibilities

for conducting investigationbull Increase technical skills on root cause

analysis toolsbull Improve writing skillsbull Use team approach to conduct

investigation to increase business and technical knowledge

From Corrective to Preventive

Preventive Actionbull Implement predictive metricsindicatorsbull Routinely review and act on sources of product

and quality databull Use a risk assessment process that allows CAPAs

for Preventive Actionbull Improve linkage between CAPA into Design

Controlsbull Take a holistic view of issuesbull Can it link to other Quality Systems product lines

systems andor processes

From Corrective to Preventive

Management Support and Oversightbull Ensure Management oversight and

commitmentbull Align CAPA with company departmental

and individual goals and objectivesbull Create rewards and recognition programsbull Establish joint partnership between

businesssystem owner and Information Technology for continuous improvement efforts

bull Align metrics from departmental to corporate level

Annual Product Review - Requirements

Written records subject to this review include but are not limited to the following

1048713 Manufacturing and quality records from lots or batches of products manufactured within the previous year including

bull ndash receiving inspectionbull ndash in-processbull ndash final release testing resultsbull ndash deviationsbull ndash investigationsbull ndash change control recordsbull ndash quality system trends

Annual Product Review - Requirements

Post market quality records such as

ndash Customer complaintsndash Adverse eventsndash Field actionsndash Product correctionsndash Regulatory submissionsndash Returned or salvaged products

Conclusions - Annual Product Review

bull Covers the product cradle to grave Presents management a view of product and process behavior over time

bull Is influenced by all aspects of the Quality System - including in process and release testing

bull Supports decisions related to design control process validation and control as well as user drift

bull Identifies trendsopportunities across mfg lines or sites

  • Slide 1
  • What Is Risk
  • Possibility
  • What Is Risk Management
  • What Is Acceptable Risk
  • The Seriousness of a Risk
  • Potential Risk Scenarios
  • Ways to Deal With Risk
  • Systems of Feedback
  • Balance
  • Why Risk as Part of CAPA System
  • CAPA Connecting Risk Management and Trending
  • Key Definitions
  • CAPA Process
  • Inputs and Triggers -Internal
  • Inputs and Triggers-External
  • Inputs and Triggers- Issues
  • Root Cause Analysis-Issues
  • Preventive Actions- Issues
  • From Corrective to Preventive
  • From Corrective to Preventive (2)
  • From Corrective to Preventive (3)
  • From Corrective to Preventive (4)
  • From Corrective to Preventive (5)
  • Annual Product Review - Requirements
  • Annual Product Review - Requirements (2)
  • Conclusions - Annual Product Review
Page 6: Risk Management Training

The Seriousness of a Risk

This can be determined by multiplying the probability of the event actually occurring by the potential negative impact to cost schedule or performance

Risk Severity = Probability of Occurrence x Potential Negative Impact

Potential Risk Scenarios

bull Scenario 1 Probability of occurrence is high and the potential impact is very low

bull Scenario 2 Probability of occurrence is low and the potential impact is very high

bull Scenario 3 Probability of occurrence is low and the potential impact is very low

bull Scenario 4 Probability of occurrence is high and the potential impact is very high

Ways to Deal With Risk

bull Proactive approach Risk Managementndash Analyzes future project events and past

projectsndash Identify potential risksndash Taking measures to reduce their probability

and or impactbull Reactive approach Crisis Management

ndash Resource-intensivendash Available options constrained or restricted by

events

Systems of Feedback

bull Design feedbackbull Management Reviewbull Risk Management

bull Customer Complaintsbull CAPA Escalationbull Acceptable Risk

Proactive

Reactive

Balance

Risk

Benefit

Why Risk as Part of CAPA System

bull What is the impact of risk to the CAPA

system

bull What hurdles will you encounter

CAPA Connecting RiskManagement and Trending

Critical questions that drive into the CAPA process and determine the depth of investigationpriority of CAPAndash Is this a new or unknown problemndash Has the severity increased Decreasedndash Has the frequency of occurrence

increasedndash Have the causes of the problem been

confirmedndash Are there new causes of the problem

that have inadequate or no mitigation

Key Definitions

Nonconformance (NC)bull Any noncompliance with the requirements of the Quality

System (product and non-product)Correctionbull Repair rework or adjustment related to the disposition of an

existingnonconformity Corrections are typically one-time fixesCorrective Action (CA)bull Action taken to eliminate the causes of an existing

nonconformity defect or other undesirable situation in order to prevent recurrence

Preventive Action (PA)bull Action taken to eliminate the cause of a potential

nonconformity defect or other undesirable situation in order to prevent occurrence and improve quality trends

CAPA Process

Failure Investigation(Root Cause Analysis)

CAPA Plan

Approval andDissemination

Implementation(Change Control)

Follow-up for Effectiveness

Problem Identification (Risk Assessment)

Closure

Not EffectiveEffective

Inputs and Triggers -Internal

bull Acceptance activitiesbull Calibration and Maintenance recordsbull Design Control systembull Management ReviewsAnnual Product Reviewsbull Nonconformances (product and non-product)bull Packaging and Labeling materialsbull Quality Auditsbull Returned productsbull Risk Management documentsbull Service and Installation recordsbull Six SigmaProcess Excellence programsbull SPC monitoringbull And morehellip

Inputs and Triggers-External

bull Customer complaintsbull Customer feedbackbull External Quality Audit reportsbull ISOAS 9100 feedbackbull Product warrantybull Recallsfield actionsbull Identification of any other conditionissue that

does not comply withbull Your own Quality System andorbull ISOAS standards (eg ISO 9001 AS 9100 etc)bull And morehellip

Inputs and Triggers- Issues

bull Inputs not clearly defined or established

bull Trigger thresholds not establishedbull Focus on reactive metrics

(Nonconformances Complaints Audit

Observations)bull Data not easily retrievablebull Data not easy to analyze for trends

Root Cause Analysis-Issues

bull Poorlack of technical skills to conduct root cause analysis

bull Poorlack of writing skills in documenting root cause analysis

bull Poorlittle business knowledge in conducting root cause analysis across processes systems product lines and Quality Systems

Preventive Actions- Issues

bull When everything is corrective how can the organization assign resources to address Preventive Action

bull Risk assessment may not be designed to address elevation to CAPA for a potential issue or improvement (Preventive Action)

bull CAPA metrics tend to focus on closure rates cycle time number of open CAPAs etc Preventive Actions are in most cases longer-term solutions across processes systems product lines and Quality Systems and will take more time to close

From Corrective to Preventive

bull Clearly define inputs and establish thresholds

bull Implement predictive metricsindicators

bull Routinely review and act on sources of product and quality data

bull Make data reporting available and easy to users and management

From Corrective to Preventive

Risk Managementbull Establish elevation mechanisms to CAPAbull Use a risk assessment process to allow

prioritization of CAPAs and elevation to Management

bull Use a risk assessment process that allows CAPAs for Preventive Action

bull Link CAPA to Risk Management documentation (eg Design Control documents)

bull Make data reporting available and easy to users and management

From Corrective to Preventive

Root Cause Analysisbull Establish clear roles and responsibilities

for conducting investigationbull Increase technical skills on root cause

analysis toolsbull Improve writing skillsbull Use team approach to conduct

investigation to increase business and technical knowledge

From Corrective to Preventive

Preventive Actionbull Implement predictive metricsindicatorsbull Routinely review and act on sources of product

and quality databull Use a risk assessment process that allows CAPAs

for Preventive Actionbull Improve linkage between CAPA into Design

Controlsbull Take a holistic view of issuesbull Can it link to other Quality Systems product lines

systems andor processes

From Corrective to Preventive

Management Support and Oversightbull Ensure Management oversight and

commitmentbull Align CAPA with company departmental

and individual goals and objectivesbull Create rewards and recognition programsbull Establish joint partnership between

businesssystem owner and Information Technology for continuous improvement efforts

bull Align metrics from departmental to corporate level

Annual Product Review - Requirements

Written records subject to this review include but are not limited to the following

1048713 Manufacturing and quality records from lots or batches of products manufactured within the previous year including

bull ndash receiving inspectionbull ndash in-processbull ndash final release testing resultsbull ndash deviationsbull ndash investigationsbull ndash change control recordsbull ndash quality system trends

Annual Product Review - Requirements

Post market quality records such as

ndash Customer complaintsndash Adverse eventsndash Field actionsndash Product correctionsndash Regulatory submissionsndash Returned or salvaged products

Conclusions - Annual Product Review

bull Covers the product cradle to grave Presents management a view of product and process behavior over time

bull Is influenced by all aspects of the Quality System - including in process and release testing

bull Supports decisions related to design control process validation and control as well as user drift

bull Identifies trendsopportunities across mfg lines or sites

  • Slide 1
  • What Is Risk
  • Possibility
  • What Is Risk Management
  • What Is Acceptable Risk
  • The Seriousness of a Risk
  • Potential Risk Scenarios
  • Ways to Deal With Risk
  • Systems of Feedback
  • Balance
  • Why Risk as Part of CAPA System
  • CAPA Connecting Risk Management and Trending
  • Key Definitions
  • CAPA Process
  • Inputs and Triggers -Internal
  • Inputs and Triggers-External
  • Inputs and Triggers- Issues
  • Root Cause Analysis-Issues
  • Preventive Actions- Issues
  • From Corrective to Preventive
  • From Corrective to Preventive (2)
  • From Corrective to Preventive (3)
  • From Corrective to Preventive (4)
  • From Corrective to Preventive (5)
  • Annual Product Review - Requirements
  • Annual Product Review - Requirements (2)
  • Conclusions - Annual Product Review
Page 7: Risk Management Training

Potential Risk Scenarios

bull Scenario 1 Probability of occurrence is high and the potential impact is very low

bull Scenario 2 Probability of occurrence is low and the potential impact is very high

bull Scenario 3 Probability of occurrence is low and the potential impact is very low

bull Scenario 4 Probability of occurrence is high and the potential impact is very high

Ways to Deal With Risk

bull Proactive approach Risk Managementndash Analyzes future project events and past

projectsndash Identify potential risksndash Taking measures to reduce their probability

and or impactbull Reactive approach Crisis Management

ndash Resource-intensivendash Available options constrained or restricted by

events

Systems of Feedback

bull Design feedbackbull Management Reviewbull Risk Management

bull Customer Complaintsbull CAPA Escalationbull Acceptable Risk

Proactive

Reactive

Balance

Risk

Benefit

Why Risk as Part of CAPA System

bull What is the impact of risk to the CAPA

system

bull What hurdles will you encounter

CAPA Connecting RiskManagement and Trending

Critical questions that drive into the CAPA process and determine the depth of investigationpriority of CAPAndash Is this a new or unknown problemndash Has the severity increased Decreasedndash Has the frequency of occurrence

increasedndash Have the causes of the problem been

confirmedndash Are there new causes of the problem

that have inadequate or no mitigation

Key Definitions

Nonconformance (NC)bull Any noncompliance with the requirements of the Quality

System (product and non-product)Correctionbull Repair rework or adjustment related to the disposition of an

existingnonconformity Corrections are typically one-time fixesCorrective Action (CA)bull Action taken to eliminate the causes of an existing

nonconformity defect or other undesirable situation in order to prevent recurrence

Preventive Action (PA)bull Action taken to eliminate the cause of a potential

nonconformity defect or other undesirable situation in order to prevent occurrence and improve quality trends

CAPA Process

Failure Investigation(Root Cause Analysis)

CAPA Plan

Approval andDissemination

Implementation(Change Control)

Follow-up for Effectiveness

Problem Identification (Risk Assessment)

Closure

Not EffectiveEffective

Inputs and Triggers -Internal

bull Acceptance activitiesbull Calibration and Maintenance recordsbull Design Control systembull Management ReviewsAnnual Product Reviewsbull Nonconformances (product and non-product)bull Packaging and Labeling materialsbull Quality Auditsbull Returned productsbull Risk Management documentsbull Service and Installation recordsbull Six SigmaProcess Excellence programsbull SPC monitoringbull And morehellip

Inputs and Triggers-External

bull Customer complaintsbull Customer feedbackbull External Quality Audit reportsbull ISOAS 9100 feedbackbull Product warrantybull Recallsfield actionsbull Identification of any other conditionissue that

does not comply withbull Your own Quality System andorbull ISOAS standards (eg ISO 9001 AS 9100 etc)bull And morehellip

Inputs and Triggers- Issues

bull Inputs not clearly defined or established

bull Trigger thresholds not establishedbull Focus on reactive metrics

(Nonconformances Complaints Audit

Observations)bull Data not easily retrievablebull Data not easy to analyze for trends

Root Cause Analysis-Issues

bull Poorlack of technical skills to conduct root cause analysis

bull Poorlack of writing skills in documenting root cause analysis

bull Poorlittle business knowledge in conducting root cause analysis across processes systems product lines and Quality Systems

Preventive Actions- Issues

bull When everything is corrective how can the organization assign resources to address Preventive Action

bull Risk assessment may not be designed to address elevation to CAPA for a potential issue or improvement (Preventive Action)

bull CAPA metrics tend to focus on closure rates cycle time number of open CAPAs etc Preventive Actions are in most cases longer-term solutions across processes systems product lines and Quality Systems and will take more time to close

From Corrective to Preventive

bull Clearly define inputs and establish thresholds

bull Implement predictive metricsindicators

bull Routinely review and act on sources of product and quality data

bull Make data reporting available and easy to users and management

From Corrective to Preventive

Risk Managementbull Establish elevation mechanisms to CAPAbull Use a risk assessment process to allow

prioritization of CAPAs and elevation to Management

bull Use a risk assessment process that allows CAPAs for Preventive Action

bull Link CAPA to Risk Management documentation (eg Design Control documents)

bull Make data reporting available and easy to users and management

From Corrective to Preventive

Root Cause Analysisbull Establish clear roles and responsibilities

for conducting investigationbull Increase technical skills on root cause

analysis toolsbull Improve writing skillsbull Use team approach to conduct

investigation to increase business and technical knowledge

From Corrective to Preventive

Preventive Actionbull Implement predictive metricsindicatorsbull Routinely review and act on sources of product

and quality databull Use a risk assessment process that allows CAPAs

for Preventive Actionbull Improve linkage between CAPA into Design

Controlsbull Take a holistic view of issuesbull Can it link to other Quality Systems product lines

systems andor processes

From Corrective to Preventive

Management Support and Oversightbull Ensure Management oversight and

commitmentbull Align CAPA with company departmental

and individual goals and objectivesbull Create rewards and recognition programsbull Establish joint partnership between

businesssystem owner and Information Technology for continuous improvement efforts

bull Align metrics from departmental to corporate level

Annual Product Review - Requirements

Written records subject to this review include but are not limited to the following

1048713 Manufacturing and quality records from lots or batches of products manufactured within the previous year including

bull ndash receiving inspectionbull ndash in-processbull ndash final release testing resultsbull ndash deviationsbull ndash investigationsbull ndash change control recordsbull ndash quality system trends

Annual Product Review - Requirements

Post market quality records such as

ndash Customer complaintsndash Adverse eventsndash Field actionsndash Product correctionsndash Regulatory submissionsndash Returned or salvaged products

Conclusions - Annual Product Review

bull Covers the product cradle to grave Presents management a view of product and process behavior over time

bull Is influenced by all aspects of the Quality System - including in process and release testing

bull Supports decisions related to design control process validation and control as well as user drift

bull Identifies trendsopportunities across mfg lines or sites

  • Slide 1
  • What Is Risk
  • Possibility
  • What Is Risk Management
  • What Is Acceptable Risk
  • The Seriousness of a Risk
  • Potential Risk Scenarios
  • Ways to Deal With Risk
  • Systems of Feedback
  • Balance
  • Why Risk as Part of CAPA System
  • CAPA Connecting Risk Management and Trending
  • Key Definitions
  • CAPA Process
  • Inputs and Triggers -Internal
  • Inputs and Triggers-External
  • Inputs and Triggers- Issues
  • Root Cause Analysis-Issues
  • Preventive Actions- Issues
  • From Corrective to Preventive
  • From Corrective to Preventive (2)
  • From Corrective to Preventive (3)
  • From Corrective to Preventive (4)
  • From Corrective to Preventive (5)
  • Annual Product Review - Requirements
  • Annual Product Review - Requirements (2)
  • Conclusions - Annual Product Review
Page 8: Risk Management Training

Ways to Deal With Risk

bull Proactive approach Risk Managementndash Analyzes future project events and past

projectsndash Identify potential risksndash Taking measures to reduce their probability

and or impactbull Reactive approach Crisis Management

ndash Resource-intensivendash Available options constrained or restricted by

events

Systems of Feedback

bull Design feedbackbull Management Reviewbull Risk Management

bull Customer Complaintsbull CAPA Escalationbull Acceptable Risk

Proactive

Reactive

Balance

Risk

Benefit

Why Risk as Part of CAPA System

bull What is the impact of risk to the CAPA

system

bull What hurdles will you encounter

CAPA Connecting RiskManagement and Trending

Critical questions that drive into the CAPA process and determine the depth of investigationpriority of CAPAndash Is this a new or unknown problemndash Has the severity increased Decreasedndash Has the frequency of occurrence

increasedndash Have the causes of the problem been

confirmedndash Are there new causes of the problem

that have inadequate or no mitigation

Key Definitions

Nonconformance (NC)bull Any noncompliance with the requirements of the Quality

System (product and non-product)Correctionbull Repair rework or adjustment related to the disposition of an

existingnonconformity Corrections are typically one-time fixesCorrective Action (CA)bull Action taken to eliminate the causes of an existing

nonconformity defect or other undesirable situation in order to prevent recurrence

Preventive Action (PA)bull Action taken to eliminate the cause of a potential

nonconformity defect or other undesirable situation in order to prevent occurrence and improve quality trends

CAPA Process

Failure Investigation(Root Cause Analysis)

CAPA Plan

Approval andDissemination

Implementation(Change Control)

Follow-up for Effectiveness

Problem Identification (Risk Assessment)

Closure

Not EffectiveEffective

Inputs and Triggers -Internal

bull Acceptance activitiesbull Calibration and Maintenance recordsbull Design Control systembull Management ReviewsAnnual Product Reviewsbull Nonconformances (product and non-product)bull Packaging and Labeling materialsbull Quality Auditsbull Returned productsbull Risk Management documentsbull Service and Installation recordsbull Six SigmaProcess Excellence programsbull SPC monitoringbull And morehellip

Inputs and Triggers-External

bull Customer complaintsbull Customer feedbackbull External Quality Audit reportsbull ISOAS 9100 feedbackbull Product warrantybull Recallsfield actionsbull Identification of any other conditionissue that

does not comply withbull Your own Quality System andorbull ISOAS standards (eg ISO 9001 AS 9100 etc)bull And morehellip

Inputs and Triggers- Issues

bull Inputs not clearly defined or established

bull Trigger thresholds not establishedbull Focus on reactive metrics

(Nonconformances Complaints Audit

Observations)bull Data not easily retrievablebull Data not easy to analyze for trends

Root Cause Analysis-Issues

bull Poorlack of technical skills to conduct root cause analysis

bull Poorlack of writing skills in documenting root cause analysis

bull Poorlittle business knowledge in conducting root cause analysis across processes systems product lines and Quality Systems

Preventive Actions- Issues

bull When everything is corrective how can the organization assign resources to address Preventive Action

bull Risk assessment may not be designed to address elevation to CAPA for a potential issue or improvement (Preventive Action)

bull CAPA metrics tend to focus on closure rates cycle time number of open CAPAs etc Preventive Actions are in most cases longer-term solutions across processes systems product lines and Quality Systems and will take more time to close

From Corrective to Preventive

bull Clearly define inputs and establish thresholds

bull Implement predictive metricsindicators

bull Routinely review and act on sources of product and quality data

bull Make data reporting available and easy to users and management

From Corrective to Preventive

Risk Managementbull Establish elevation mechanisms to CAPAbull Use a risk assessment process to allow

prioritization of CAPAs and elevation to Management

bull Use a risk assessment process that allows CAPAs for Preventive Action

bull Link CAPA to Risk Management documentation (eg Design Control documents)

bull Make data reporting available and easy to users and management

From Corrective to Preventive

Root Cause Analysisbull Establish clear roles and responsibilities

for conducting investigationbull Increase technical skills on root cause

analysis toolsbull Improve writing skillsbull Use team approach to conduct

investigation to increase business and technical knowledge

From Corrective to Preventive

Preventive Actionbull Implement predictive metricsindicatorsbull Routinely review and act on sources of product

and quality databull Use a risk assessment process that allows CAPAs

for Preventive Actionbull Improve linkage between CAPA into Design

Controlsbull Take a holistic view of issuesbull Can it link to other Quality Systems product lines

systems andor processes

From Corrective to Preventive

Management Support and Oversightbull Ensure Management oversight and

commitmentbull Align CAPA with company departmental

and individual goals and objectivesbull Create rewards and recognition programsbull Establish joint partnership between

businesssystem owner and Information Technology for continuous improvement efforts

bull Align metrics from departmental to corporate level

Annual Product Review - Requirements

Written records subject to this review include but are not limited to the following

1048713 Manufacturing and quality records from lots or batches of products manufactured within the previous year including

bull ndash receiving inspectionbull ndash in-processbull ndash final release testing resultsbull ndash deviationsbull ndash investigationsbull ndash change control recordsbull ndash quality system trends

Annual Product Review - Requirements

Post market quality records such as

ndash Customer complaintsndash Adverse eventsndash Field actionsndash Product correctionsndash Regulatory submissionsndash Returned or salvaged products

Conclusions - Annual Product Review

bull Covers the product cradle to grave Presents management a view of product and process behavior over time

bull Is influenced by all aspects of the Quality System - including in process and release testing

bull Supports decisions related to design control process validation and control as well as user drift

bull Identifies trendsopportunities across mfg lines or sites

  • Slide 1
  • What Is Risk
  • Possibility
  • What Is Risk Management
  • What Is Acceptable Risk
  • The Seriousness of a Risk
  • Potential Risk Scenarios
  • Ways to Deal With Risk
  • Systems of Feedback
  • Balance
  • Why Risk as Part of CAPA System
  • CAPA Connecting Risk Management and Trending
  • Key Definitions
  • CAPA Process
  • Inputs and Triggers -Internal
  • Inputs and Triggers-External
  • Inputs and Triggers- Issues
  • Root Cause Analysis-Issues
  • Preventive Actions- Issues
  • From Corrective to Preventive
  • From Corrective to Preventive (2)
  • From Corrective to Preventive (3)
  • From Corrective to Preventive (4)
  • From Corrective to Preventive (5)
  • Annual Product Review - Requirements
  • Annual Product Review - Requirements (2)
  • Conclusions - Annual Product Review
Page 9: Risk Management Training

Systems of Feedback

bull Design feedbackbull Management Reviewbull Risk Management

bull Customer Complaintsbull CAPA Escalationbull Acceptable Risk

Proactive

Reactive

Balance

Risk

Benefit

Why Risk as Part of CAPA System

bull What is the impact of risk to the CAPA

system

bull What hurdles will you encounter

CAPA Connecting RiskManagement and Trending

Critical questions that drive into the CAPA process and determine the depth of investigationpriority of CAPAndash Is this a new or unknown problemndash Has the severity increased Decreasedndash Has the frequency of occurrence

increasedndash Have the causes of the problem been

confirmedndash Are there new causes of the problem

that have inadequate or no mitigation

Key Definitions

Nonconformance (NC)bull Any noncompliance with the requirements of the Quality

System (product and non-product)Correctionbull Repair rework or adjustment related to the disposition of an

existingnonconformity Corrections are typically one-time fixesCorrective Action (CA)bull Action taken to eliminate the causes of an existing

nonconformity defect or other undesirable situation in order to prevent recurrence

Preventive Action (PA)bull Action taken to eliminate the cause of a potential

nonconformity defect or other undesirable situation in order to prevent occurrence and improve quality trends

CAPA Process

Failure Investigation(Root Cause Analysis)

CAPA Plan

Approval andDissemination

Implementation(Change Control)

Follow-up for Effectiveness

Problem Identification (Risk Assessment)

Closure

Not EffectiveEffective

Inputs and Triggers -Internal

bull Acceptance activitiesbull Calibration and Maintenance recordsbull Design Control systembull Management ReviewsAnnual Product Reviewsbull Nonconformances (product and non-product)bull Packaging and Labeling materialsbull Quality Auditsbull Returned productsbull Risk Management documentsbull Service and Installation recordsbull Six SigmaProcess Excellence programsbull SPC monitoringbull And morehellip

Inputs and Triggers-External

bull Customer complaintsbull Customer feedbackbull External Quality Audit reportsbull ISOAS 9100 feedbackbull Product warrantybull Recallsfield actionsbull Identification of any other conditionissue that

does not comply withbull Your own Quality System andorbull ISOAS standards (eg ISO 9001 AS 9100 etc)bull And morehellip

Inputs and Triggers- Issues

bull Inputs not clearly defined or established

bull Trigger thresholds not establishedbull Focus on reactive metrics

(Nonconformances Complaints Audit

Observations)bull Data not easily retrievablebull Data not easy to analyze for trends

Root Cause Analysis-Issues

bull Poorlack of technical skills to conduct root cause analysis

bull Poorlack of writing skills in documenting root cause analysis

bull Poorlittle business knowledge in conducting root cause analysis across processes systems product lines and Quality Systems

Preventive Actions- Issues

bull When everything is corrective how can the organization assign resources to address Preventive Action

bull Risk assessment may not be designed to address elevation to CAPA for a potential issue or improvement (Preventive Action)

bull CAPA metrics tend to focus on closure rates cycle time number of open CAPAs etc Preventive Actions are in most cases longer-term solutions across processes systems product lines and Quality Systems and will take more time to close

From Corrective to Preventive

bull Clearly define inputs and establish thresholds

bull Implement predictive metricsindicators

bull Routinely review and act on sources of product and quality data

bull Make data reporting available and easy to users and management

From Corrective to Preventive

Risk Managementbull Establish elevation mechanisms to CAPAbull Use a risk assessment process to allow

prioritization of CAPAs and elevation to Management

bull Use a risk assessment process that allows CAPAs for Preventive Action

bull Link CAPA to Risk Management documentation (eg Design Control documents)

bull Make data reporting available and easy to users and management

From Corrective to Preventive

Root Cause Analysisbull Establish clear roles and responsibilities

for conducting investigationbull Increase technical skills on root cause

analysis toolsbull Improve writing skillsbull Use team approach to conduct

investigation to increase business and technical knowledge

From Corrective to Preventive

Preventive Actionbull Implement predictive metricsindicatorsbull Routinely review and act on sources of product

and quality databull Use a risk assessment process that allows CAPAs

for Preventive Actionbull Improve linkage between CAPA into Design

Controlsbull Take a holistic view of issuesbull Can it link to other Quality Systems product lines

systems andor processes

From Corrective to Preventive

Management Support and Oversightbull Ensure Management oversight and

commitmentbull Align CAPA with company departmental

and individual goals and objectivesbull Create rewards and recognition programsbull Establish joint partnership between

businesssystem owner and Information Technology for continuous improvement efforts

bull Align metrics from departmental to corporate level

Annual Product Review - Requirements

Written records subject to this review include but are not limited to the following

1048713 Manufacturing and quality records from lots or batches of products manufactured within the previous year including

bull ndash receiving inspectionbull ndash in-processbull ndash final release testing resultsbull ndash deviationsbull ndash investigationsbull ndash change control recordsbull ndash quality system trends

Annual Product Review - Requirements

Post market quality records such as

ndash Customer complaintsndash Adverse eventsndash Field actionsndash Product correctionsndash Regulatory submissionsndash Returned or salvaged products

Conclusions - Annual Product Review

bull Covers the product cradle to grave Presents management a view of product and process behavior over time

bull Is influenced by all aspects of the Quality System - including in process and release testing

bull Supports decisions related to design control process validation and control as well as user drift

bull Identifies trendsopportunities across mfg lines or sites

  • Slide 1
  • What Is Risk
  • Possibility
  • What Is Risk Management
  • What Is Acceptable Risk
  • The Seriousness of a Risk
  • Potential Risk Scenarios
  • Ways to Deal With Risk
  • Systems of Feedback
  • Balance
  • Why Risk as Part of CAPA System
  • CAPA Connecting Risk Management and Trending
  • Key Definitions
  • CAPA Process
  • Inputs and Triggers -Internal
  • Inputs and Triggers-External
  • Inputs and Triggers- Issues
  • Root Cause Analysis-Issues
  • Preventive Actions- Issues
  • From Corrective to Preventive
  • From Corrective to Preventive (2)
  • From Corrective to Preventive (3)
  • From Corrective to Preventive (4)
  • From Corrective to Preventive (5)
  • Annual Product Review - Requirements
  • Annual Product Review - Requirements (2)
  • Conclusions - Annual Product Review
Page 10: Risk Management Training

Balance

Risk

Benefit

Why Risk as Part of CAPA System

bull What is the impact of risk to the CAPA

system

bull What hurdles will you encounter

CAPA Connecting RiskManagement and Trending

Critical questions that drive into the CAPA process and determine the depth of investigationpriority of CAPAndash Is this a new or unknown problemndash Has the severity increased Decreasedndash Has the frequency of occurrence

increasedndash Have the causes of the problem been

confirmedndash Are there new causes of the problem

that have inadequate or no mitigation

Key Definitions

Nonconformance (NC)bull Any noncompliance with the requirements of the Quality

System (product and non-product)Correctionbull Repair rework or adjustment related to the disposition of an

existingnonconformity Corrections are typically one-time fixesCorrective Action (CA)bull Action taken to eliminate the causes of an existing

nonconformity defect or other undesirable situation in order to prevent recurrence

Preventive Action (PA)bull Action taken to eliminate the cause of a potential

nonconformity defect or other undesirable situation in order to prevent occurrence and improve quality trends

CAPA Process

Failure Investigation(Root Cause Analysis)

CAPA Plan

Approval andDissemination

Implementation(Change Control)

Follow-up for Effectiveness

Problem Identification (Risk Assessment)

Closure

Not EffectiveEffective

Inputs and Triggers -Internal

bull Acceptance activitiesbull Calibration and Maintenance recordsbull Design Control systembull Management ReviewsAnnual Product Reviewsbull Nonconformances (product and non-product)bull Packaging and Labeling materialsbull Quality Auditsbull Returned productsbull Risk Management documentsbull Service and Installation recordsbull Six SigmaProcess Excellence programsbull SPC monitoringbull And morehellip

Inputs and Triggers-External

bull Customer complaintsbull Customer feedbackbull External Quality Audit reportsbull ISOAS 9100 feedbackbull Product warrantybull Recallsfield actionsbull Identification of any other conditionissue that

does not comply withbull Your own Quality System andorbull ISOAS standards (eg ISO 9001 AS 9100 etc)bull And morehellip

Inputs and Triggers- Issues

bull Inputs not clearly defined or established

bull Trigger thresholds not establishedbull Focus on reactive metrics

(Nonconformances Complaints Audit

Observations)bull Data not easily retrievablebull Data not easy to analyze for trends

Root Cause Analysis-Issues

bull Poorlack of technical skills to conduct root cause analysis

bull Poorlack of writing skills in documenting root cause analysis

bull Poorlittle business knowledge in conducting root cause analysis across processes systems product lines and Quality Systems

Preventive Actions- Issues

bull When everything is corrective how can the organization assign resources to address Preventive Action

bull Risk assessment may not be designed to address elevation to CAPA for a potential issue or improvement (Preventive Action)

bull CAPA metrics tend to focus on closure rates cycle time number of open CAPAs etc Preventive Actions are in most cases longer-term solutions across processes systems product lines and Quality Systems and will take more time to close

From Corrective to Preventive

bull Clearly define inputs and establish thresholds

bull Implement predictive metricsindicators

bull Routinely review and act on sources of product and quality data

bull Make data reporting available and easy to users and management

From Corrective to Preventive

Risk Managementbull Establish elevation mechanisms to CAPAbull Use a risk assessment process to allow

prioritization of CAPAs and elevation to Management

bull Use a risk assessment process that allows CAPAs for Preventive Action

bull Link CAPA to Risk Management documentation (eg Design Control documents)

bull Make data reporting available and easy to users and management

From Corrective to Preventive

Root Cause Analysisbull Establish clear roles and responsibilities

for conducting investigationbull Increase technical skills on root cause

analysis toolsbull Improve writing skillsbull Use team approach to conduct

investigation to increase business and technical knowledge

From Corrective to Preventive

Preventive Actionbull Implement predictive metricsindicatorsbull Routinely review and act on sources of product

and quality databull Use a risk assessment process that allows CAPAs

for Preventive Actionbull Improve linkage between CAPA into Design

Controlsbull Take a holistic view of issuesbull Can it link to other Quality Systems product lines

systems andor processes

From Corrective to Preventive

Management Support and Oversightbull Ensure Management oversight and

commitmentbull Align CAPA with company departmental

and individual goals and objectivesbull Create rewards and recognition programsbull Establish joint partnership between

businesssystem owner and Information Technology for continuous improvement efforts

bull Align metrics from departmental to corporate level

Annual Product Review - Requirements

Written records subject to this review include but are not limited to the following

1048713 Manufacturing and quality records from lots or batches of products manufactured within the previous year including

bull ndash receiving inspectionbull ndash in-processbull ndash final release testing resultsbull ndash deviationsbull ndash investigationsbull ndash change control recordsbull ndash quality system trends

Annual Product Review - Requirements

Post market quality records such as

ndash Customer complaintsndash Adverse eventsndash Field actionsndash Product correctionsndash Regulatory submissionsndash Returned or salvaged products

Conclusions - Annual Product Review

bull Covers the product cradle to grave Presents management a view of product and process behavior over time

bull Is influenced by all aspects of the Quality System - including in process and release testing

bull Supports decisions related to design control process validation and control as well as user drift

bull Identifies trendsopportunities across mfg lines or sites

  • Slide 1
  • What Is Risk
  • Possibility
  • What Is Risk Management
  • What Is Acceptable Risk
  • The Seriousness of a Risk
  • Potential Risk Scenarios
  • Ways to Deal With Risk
  • Systems of Feedback
  • Balance
  • Why Risk as Part of CAPA System
  • CAPA Connecting Risk Management and Trending
  • Key Definitions
  • CAPA Process
  • Inputs and Triggers -Internal
  • Inputs and Triggers-External
  • Inputs and Triggers- Issues
  • Root Cause Analysis-Issues
  • Preventive Actions- Issues
  • From Corrective to Preventive
  • From Corrective to Preventive (2)
  • From Corrective to Preventive (3)
  • From Corrective to Preventive (4)
  • From Corrective to Preventive (5)
  • Annual Product Review - Requirements
  • Annual Product Review - Requirements (2)
  • Conclusions - Annual Product Review
Page 11: Risk Management Training

Why Risk as Part of CAPA System

bull What is the impact of risk to the CAPA

system

bull What hurdles will you encounter

CAPA Connecting RiskManagement and Trending

Critical questions that drive into the CAPA process and determine the depth of investigationpriority of CAPAndash Is this a new or unknown problemndash Has the severity increased Decreasedndash Has the frequency of occurrence

increasedndash Have the causes of the problem been

confirmedndash Are there new causes of the problem

that have inadequate or no mitigation

Key Definitions

Nonconformance (NC)bull Any noncompliance with the requirements of the Quality

System (product and non-product)Correctionbull Repair rework or adjustment related to the disposition of an

existingnonconformity Corrections are typically one-time fixesCorrective Action (CA)bull Action taken to eliminate the causes of an existing

nonconformity defect or other undesirable situation in order to prevent recurrence

Preventive Action (PA)bull Action taken to eliminate the cause of a potential

nonconformity defect or other undesirable situation in order to prevent occurrence and improve quality trends

CAPA Process

Failure Investigation(Root Cause Analysis)

CAPA Plan

Approval andDissemination

Implementation(Change Control)

Follow-up for Effectiveness

Problem Identification (Risk Assessment)

Closure

Not EffectiveEffective

Inputs and Triggers -Internal

bull Acceptance activitiesbull Calibration and Maintenance recordsbull Design Control systembull Management ReviewsAnnual Product Reviewsbull Nonconformances (product and non-product)bull Packaging and Labeling materialsbull Quality Auditsbull Returned productsbull Risk Management documentsbull Service and Installation recordsbull Six SigmaProcess Excellence programsbull SPC monitoringbull And morehellip

Inputs and Triggers-External

bull Customer complaintsbull Customer feedbackbull External Quality Audit reportsbull ISOAS 9100 feedbackbull Product warrantybull Recallsfield actionsbull Identification of any other conditionissue that

does not comply withbull Your own Quality System andorbull ISOAS standards (eg ISO 9001 AS 9100 etc)bull And morehellip

Inputs and Triggers- Issues

bull Inputs not clearly defined or established

bull Trigger thresholds not establishedbull Focus on reactive metrics

(Nonconformances Complaints Audit

Observations)bull Data not easily retrievablebull Data not easy to analyze for trends

Root Cause Analysis-Issues

bull Poorlack of technical skills to conduct root cause analysis

bull Poorlack of writing skills in documenting root cause analysis

bull Poorlittle business knowledge in conducting root cause analysis across processes systems product lines and Quality Systems

Preventive Actions- Issues

bull When everything is corrective how can the organization assign resources to address Preventive Action

bull Risk assessment may not be designed to address elevation to CAPA for a potential issue or improvement (Preventive Action)

bull CAPA metrics tend to focus on closure rates cycle time number of open CAPAs etc Preventive Actions are in most cases longer-term solutions across processes systems product lines and Quality Systems and will take more time to close

From Corrective to Preventive

bull Clearly define inputs and establish thresholds

bull Implement predictive metricsindicators

bull Routinely review and act on sources of product and quality data

bull Make data reporting available and easy to users and management

From Corrective to Preventive

Risk Managementbull Establish elevation mechanisms to CAPAbull Use a risk assessment process to allow

prioritization of CAPAs and elevation to Management

bull Use a risk assessment process that allows CAPAs for Preventive Action

bull Link CAPA to Risk Management documentation (eg Design Control documents)

bull Make data reporting available and easy to users and management

From Corrective to Preventive

Root Cause Analysisbull Establish clear roles and responsibilities

for conducting investigationbull Increase technical skills on root cause

analysis toolsbull Improve writing skillsbull Use team approach to conduct

investigation to increase business and technical knowledge

From Corrective to Preventive

Preventive Actionbull Implement predictive metricsindicatorsbull Routinely review and act on sources of product

and quality databull Use a risk assessment process that allows CAPAs

for Preventive Actionbull Improve linkage between CAPA into Design

Controlsbull Take a holistic view of issuesbull Can it link to other Quality Systems product lines

systems andor processes

From Corrective to Preventive

Management Support and Oversightbull Ensure Management oversight and

commitmentbull Align CAPA with company departmental

and individual goals and objectivesbull Create rewards and recognition programsbull Establish joint partnership between

businesssystem owner and Information Technology for continuous improvement efforts

bull Align metrics from departmental to corporate level

Annual Product Review - Requirements

Written records subject to this review include but are not limited to the following

1048713 Manufacturing and quality records from lots or batches of products manufactured within the previous year including

bull ndash receiving inspectionbull ndash in-processbull ndash final release testing resultsbull ndash deviationsbull ndash investigationsbull ndash change control recordsbull ndash quality system trends

Annual Product Review - Requirements

Post market quality records such as

ndash Customer complaintsndash Adverse eventsndash Field actionsndash Product correctionsndash Regulatory submissionsndash Returned or salvaged products

Conclusions - Annual Product Review

bull Covers the product cradle to grave Presents management a view of product and process behavior over time

bull Is influenced by all aspects of the Quality System - including in process and release testing

bull Supports decisions related to design control process validation and control as well as user drift

bull Identifies trendsopportunities across mfg lines or sites

  • Slide 1
  • What Is Risk
  • Possibility
  • What Is Risk Management
  • What Is Acceptable Risk
  • The Seriousness of a Risk
  • Potential Risk Scenarios
  • Ways to Deal With Risk
  • Systems of Feedback
  • Balance
  • Why Risk as Part of CAPA System
  • CAPA Connecting Risk Management and Trending
  • Key Definitions
  • CAPA Process
  • Inputs and Triggers -Internal
  • Inputs and Triggers-External
  • Inputs and Triggers- Issues
  • Root Cause Analysis-Issues
  • Preventive Actions- Issues
  • From Corrective to Preventive
  • From Corrective to Preventive (2)
  • From Corrective to Preventive (3)
  • From Corrective to Preventive (4)
  • From Corrective to Preventive (5)
  • Annual Product Review - Requirements
  • Annual Product Review - Requirements (2)
  • Conclusions - Annual Product Review
Page 12: Risk Management Training

CAPA Connecting RiskManagement and Trending

Critical questions that drive into the CAPA process and determine the depth of investigationpriority of CAPAndash Is this a new or unknown problemndash Has the severity increased Decreasedndash Has the frequency of occurrence

increasedndash Have the causes of the problem been

confirmedndash Are there new causes of the problem

that have inadequate or no mitigation

Key Definitions

Nonconformance (NC)bull Any noncompliance with the requirements of the Quality

System (product and non-product)Correctionbull Repair rework or adjustment related to the disposition of an

existingnonconformity Corrections are typically one-time fixesCorrective Action (CA)bull Action taken to eliminate the causes of an existing

nonconformity defect or other undesirable situation in order to prevent recurrence

Preventive Action (PA)bull Action taken to eliminate the cause of a potential

nonconformity defect or other undesirable situation in order to prevent occurrence and improve quality trends

CAPA Process

Failure Investigation(Root Cause Analysis)

CAPA Plan

Approval andDissemination

Implementation(Change Control)

Follow-up for Effectiveness

Problem Identification (Risk Assessment)

Closure

Not EffectiveEffective

Inputs and Triggers -Internal

bull Acceptance activitiesbull Calibration and Maintenance recordsbull Design Control systembull Management ReviewsAnnual Product Reviewsbull Nonconformances (product and non-product)bull Packaging and Labeling materialsbull Quality Auditsbull Returned productsbull Risk Management documentsbull Service and Installation recordsbull Six SigmaProcess Excellence programsbull SPC monitoringbull And morehellip

Inputs and Triggers-External

bull Customer complaintsbull Customer feedbackbull External Quality Audit reportsbull ISOAS 9100 feedbackbull Product warrantybull Recallsfield actionsbull Identification of any other conditionissue that

does not comply withbull Your own Quality System andorbull ISOAS standards (eg ISO 9001 AS 9100 etc)bull And morehellip

Inputs and Triggers- Issues

bull Inputs not clearly defined or established

bull Trigger thresholds not establishedbull Focus on reactive metrics

(Nonconformances Complaints Audit

Observations)bull Data not easily retrievablebull Data not easy to analyze for trends

Root Cause Analysis-Issues

bull Poorlack of technical skills to conduct root cause analysis

bull Poorlack of writing skills in documenting root cause analysis

bull Poorlittle business knowledge in conducting root cause analysis across processes systems product lines and Quality Systems

Preventive Actions- Issues

bull When everything is corrective how can the organization assign resources to address Preventive Action

bull Risk assessment may not be designed to address elevation to CAPA for a potential issue or improvement (Preventive Action)

bull CAPA metrics tend to focus on closure rates cycle time number of open CAPAs etc Preventive Actions are in most cases longer-term solutions across processes systems product lines and Quality Systems and will take more time to close

From Corrective to Preventive

bull Clearly define inputs and establish thresholds

bull Implement predictive metricsindicators

bull Routinely review and act on sources of product and quality data

bull Make data reporting available and easy to users and management

From Corrective to Preventive

Risk Managementbull Establish elevation mechanisms to CAPAbull Use a risk assessment process to allow

prioritization of CAPAs and elevation to Management

bull Use a risk assessment process that allows CAPAs for Preventive Action

bull Link CAPA to Risk Management documentation (eg Design Control documents)

bull Make data reporting available and easy to users and management

From Corrective to Preventive

Root Cause Analysisbull Establish clear roles and responsibilities

for conducting investigationbull Increase technical skills on root cause

analysis toolsbull Improve writing skillsbull Use team approach to conduct

investigation to increase business and technical knowledge

From Corrective to Preventive

Preventive Actionbull Implement predictive metricsindicatorsbull Routinely review and act on sources of product

and quality databull Use a risk assessment process that allows CAPAs

for Preventive Actionbull Improve linkage between CAPA into Design

Controlsbull Take a holistic view of issuesbull Can it link to other Quality Systems product lines

systems andor processes

From Corrective to Preventive

Management Support and Oversightbull Ensure Management oversight and

commitmentbull Align CAPA with company departmental

and individual goals and objectivesbull Create rewards and recognition programsbull Establish joint partnership between

businesssystem owner and Information Technology for continuous improvement efforts

bull Align metrics from departmental to corporate level

Annual Product Review - Requirements

Written records subject to this review include but are not limited to the following

1048713 Manufacturing and quality records from lots or batches of products manufactured within the previous year including

bull ndash receiving inspectionbull ndash in-processbull ndash final release testing resultsbull ndash deviationsbull ndash investigationsbull ndash change control recordsbull ndash quality system trends

Annual Product Review - Requirements

Post market quality records such as

ndash Customer complaintsndash Adverse eventsndash Field actionsndash Product correctionsndash Regulatory submissionsndash Returned or salvaged products

Conclusions - Annual Product Review

bull Covers the product cradle to grave Presents management a view of product and process behavior over time

bull Is influenced by all aspects of the Quality System - including in process and release testing

bull Supports decisions related to design control process validation and control as well as user drift

bull Identifies trendsopportunities across mfg lines or sites

  • Slide 1
  • What Is Risk
  • Possibility
  • What Is Risk Management
  • What Is Acceptable Risk
  • The Seriousness of a Risk
  • Potential Risk Scenarios
  • Ways to Deal With Risk
  • Systems of Feedback
  • Balance
  • Why Risk as Part of CAPA System
  • CAPA Connecting Risk Management and Trending
  • Key Definitions
  • CAPA Process
  • Inputs and Triggers -Internal
  • Inputs and Triggers-External
  • Inputs and Triggers- Issues
  • Root Cause Analysis-Issues
  • Preventive Actions- Issues
  • From Corrective to Preventive
  • From Corrective to Preventive (2)
  • From Corrective to Preventive (3)
  • From Corrective to Preventive (4)
  • From Corrective to Preventive (5)
  • Annual Product Review - Requirements
  • Annual Product Review - Requirements (2)
  • Conclusions - Annual Product Review
Page 13: Risk Management Training

Key Definitions

Nonconformance (NC)bull Any noncompliance with the requirements of the Quality

System (product and non-product)Correctionbull Repair rework or adjustment related to the disposition of an

existingnonconformity Corrections are typically one-time fixesCorrective Action (CA)bull Action taken to eliminate the causes of an existing

nonconformity defect or other undesirable situation in order to prevent recurrence

Preventive Action (PA)bull Action taken to eliminate the cause of a potential

nonconformity defect or other undesirable situation in order to prevent occurrence and improve quality trends

CAPA Process

Failure Investigation(Root Cause Analysis)

CAPA Plan

Approval andDissemination

Implementation(Change Control)

Follow-up for Effectiveness

Problem Identification (Risk Assessment)

Closure

Not EffectiveEffective

Inputs and Triggers -Internal

bull Acceptance activitiesbull Calibration and Maintenance recordsbull Design Control systembull Management ReviewsAnnual Product Reviewsbull Nonconformances (product and non-product)bull Packaging and Labeling materialsbull Quality Auditsbull Returned productsbull Risk Management documentsbull Service and Installation recordsbull Six SigmaProcess Excellence programsbull SPC monitoringbull And morehellip

Inputs and Triggers-External

bull Customer complaintsbull Customer feedbackbull External Quality Audit reportsbull ISOAS 9100 feedbackbull Product warrantybull Recallsfield actionsbull Identification of any other conditionissue that

does not comply withbull Your own Quality System andorbull ISOAS standards (eg ISO 9001 AS 9100 etc)bull And morehellip

Inputs and Triggers- Issues

bull Inputs not clearly defined or established

bull Trigger thresholds not establishedbull Focus on reactive metrics

(Nonconformances Complaints Audit

Observations)bull Data not easily retrievablebull Data not easy to analyze for trends

Root Cause Analysis-Issues

bull Poorlack of technical skills to conduct root cause analysis

bull Poorlack of writing skills in documenting root cause analysis

bull Poorlittle business knowledge in conducting root cause analysis across processes systems product lines and Quality Systems

Preventive Actions- Issues

bull When everything is corrective how can the organization assign resources to address Preventive Action

bull Risk assessment may not be designed to address elevation to CAPA for a potential issue or improvement (Preventive Action)

bull CAPA metrics tend to focus on closure rates cycle time number of open CAPAs etc Preventive Actions are in most cases longer-term solutions across processes systems product lines and Quality Systems and will take more time to close

From Corrective to Preventive

bull Clearly define inputs and establish thresholds

bull Implement predictive metricsindicators

bull Routinely review and act on sources of product and quality data

bull Make data reporting available and easy to users and management

From Corrective to Preventive

Risk Managementbull Establish elevation mechanisms to CAPAbull Use a risk assessment process to allow

prioritization of CAPAs and elevation to Management

bull Use a risk assessment process that allows CAPAs for Preventive Action

bull Link CAPA to Risk Management documentation (eg Design Control documents)

bull Make data reporting available and easy to users and management

From Corrective to Preventive

Root Cause Analysisbull Establish clear roles and responsibilities

for conducting investigationbull Increase technical skills on root cause

analysis toolsbull Improve writing skillsbull Use team approach to conduct

investigation to increase business and technical knowledge

From Corrective to Preventive

Preventive Actionbull Implement predictive metricsindicatorsbull Routinely review and act on sources of product

and quality databull Use a risk assessment process that allows CAPAs

for Preventive Actionbull Improve linkage between CAPA into Design

Controlsbull Take a holistic view of issuesbull Can it link to other Quality Systems product lines

systems andor processes

From Corrective to Preventive

Management Support and Oversightbull Ensure Management oversight and

commitmentbull Align CAPA with company departmental

and individual goals and objectivesbull Create rewards and recognition programsbull Establish joint partnership between

businesssystem owner and Information Technology for continuous improvement efforts

bull Align metrics from departmental to corporate level

Annual Product Review - Requirements

Written records subject to this review include but are not limited to the following

1048713 Manufacturing and quality records from lots or batches of products manufactured within the previous year including

bull ndash receiving inspectionbull ndash in-processbull ndash final release testing resultsbull ndash deviationsbull ndash investigationsbull ndash change control recordsbull ndash quality system trends

Annual Product Review - Requirements

Post market quality records such as

ndash Customer complaintsndash Adverse eventsndash Field actionsndash Product correctionsndash Regulatory submissionsndash Returned or salvaged products

Conclusions - Annual Product Review

bull Covers the product cradle to grave Presents management a view of product and process behavior over time

bull Is influenced by all aspects of the Quality System - including in process and release testing

bull Supports decisions related to design control process validation and control as well as user drift

bull Identifies trendsopportunities across mfg lines or sites

  • Slide 1
  • What Is Risk
  • Possibility
  • What Is Risk Management
  • What Is Acceptable Risk
  • The Seriousness of a Risk
  • Potential Risk Scenarios
  • Ways to Deal With Risk
  • Systems of Feedback
  • Balance
  • Why Risk as Part of CAPA System
  • CAPA Connecting Risk Management and Trending
  • Key Definitions
  • CAPA Process
  • Inputs and Triggers -Internal
  • Inputs and Triggers-External
  • Inputs and Triggers- Issues
  • Root Cause Analysis-Issues
  • Preventive Actions- Issues
  • From Corrective to Preventive
  • From Corrective to Preventive (2)
  • From Corrective to Preventive (3)
  • From Corrective to Preventive (4)
  • From Corrective to Preventive (5)
  • Annual Product Review - Requirements
  • Annual Product Review - Requirements (2)
  • Conclusions - Annual Product Review
Page 14: Risk Management Training

CAPA Process

Failure Investigation(Root Cause Analysis)

CAPA Plan

Approval andDissemination

Implementation(Change Control)

Follow-up for Effectiveness

Problem Identification (Risk Assessment)

Closure

Not EffectiveEffective

Inputs and Triggers -Internal

bull Acceptance activitiesbull Calibration and Maintenance recordsbull Design Control systembull Management ReviewsAnnual Product Reviewsbull Nonconformances (product and non-product)bull Packaging and Labeling materialsbull Quality Auditsbull Returned productsbull Risk Management documentsbull Service and Installation recordsbull Six SigmaProcess Excellence programsbull SPC monitoringbull And morehellip

Inputs and Triggers-External

bull Customer complaintsbull Customer feedbackbull External Quality Audit reportsbull ISOAS 9100 feedbackbull Product warrantybull Recallsfield actionsbull Identification of any other conditionissue that

does not comply withbull Your own Quality System andorbull ISOAS standards (eg ISO 9001 AS 9100 etc)bull And morehellip

Inputs and Triggers- Issues

bull Inputs not clearly defined or established

bull Trigger thresholds not establishedbull Focus on reactive metrics

(Nonconformances Complaints Audit

Observations)bull Data not easily retrievablebull Data not easy to analyze for trends

Root Cause Analysis-Issues

bull Poorlack of technical skills to conduct root cause analysis

bull Poorlack of writing skills in documenting root cause analysis

bull Poorlittle business knowledge in conducting root cause analysis across processes systems product lines and Quality Systems

Preventive Actions- Issues

bull When everything is corrective how can the organization assign resources to address Preventive Action

bull Risk assessment may not be designed to address elevation to CAPA for a potential issue or improvement (Preventive Action)

bull CAPA metrics tend to focus on closure rates cycle time number of open CAPAs etc Preventive Actions are in most cases longer-term solutions across processes systems product lines and Quality Systems and will take more time to close

From Corrective to Preventive

bull Clearly define inputs and establish thresholds

bull Implement predictive metricsindicators

bull Routinely review and act on sources of product and quality data

bull Make data reporting available and easy to users and management

From Corrective to Preventive

Risk Managementbull Establish elevation mechanisms to CAPAbull Use a risk assessment process to allow

prioritization of CAPAs and elevation to Management

bull Use a risk assessment process that allows CAPAs for Preventive Action

bull Link CAPA to Risk Management documentation (eg Design Control documents)

bull Make data reporting available and easy to users and management

From Corrective to Preventive

Root Cause Analysisbull Establish clear roles and responsibilities

for conducting investigationbull Increase technical skills on root cause

analysis toolsbull Improve writing skillsbull Use team approach to conduct

investigation to increase business and technical knowledge

From Corrective to Preventive

Preventive Actionbull Implement predictive metricsindicatorsbull Routinely review and act on sources of product

and quality databull Use a risk assessment process that allows CAPAs

for Preventive Actionbull Improve linkage between CAPA into Design

Controlsbull Take a holistic view of issuesbull Can it link to other Quality Systems product lines

systems andor processes

From Corrective to Preventive

Management Support and Oversightbull Ensure Management oversight and

commitmentbull Align CAPA with company departmental

and individual goals and objectivesbull Create rewards and recognition programsbull Establish joint partnership between

businesssystem owner and Information Technology for continuous improvement efforts

bull Align metrics from departmental to corporate level

Annual Product Review - Requirements

Written records subject to this review include but are not limited to the following

1048713 Manufacturing and quality records from lots or batches of products manufactured within the previous year including

bull ndash receiving inspectionbull ndash in-processbull ndash final release testing resultsbull ndash deviationsbull ndash investigationsbull ndash change control recordsbull ndash quality system trends

Annual Product Review - Requirements

Post market quality records such as

ndash Customer complaintsndash Adverse eventsndash Field actionsndash Product correctionsndash Regulatory submissionsndash Returned or salvaged products

Conclusions - Annual Product Review

bull Covers the product cradle to grave Presents management a view of product and process behavior over time

bull Is influenced by all aspects of the Quality System - including in process and release testing

bull Supports decisions related to design control process validation and control as well as user drift

bull Identifies trendsopportunities across mfg lines or sites

  • Slide 1
  • What Is Risk
  • Possibility
  • What Is Risk Management
  • What Is Acceptable Risk
  • The Seriousness of a Risk
  • Potential Risk Scenarios
  • Ways to Deal With Risk
  • Systems of Feedback
  • Balance
  • Why Risk as Part of CAPA System
  • CAPA Connecting Risk Management and Trending
  • Key Definitions
  • CAPA Process
  • Inputs and Triggers -Internal
  • Inputs and Triggers-External
  • Inputs and Triggers- Issues
  • Root Cause Analysis-Issues
  • Preventive Actions- Issues
  • From Corrective to Preventive
  • From Corrective to Preventive (2)
  • From Corrective to Preventive (3)
  • From Corrective to Preventive (4)
  • From Corrective to Preventive (5)
  • Annual Product Review - Requirements
  • Annual Product Review - Requirements (2)
  • Conclusions - Annual Product Review
Page 15: Risk Management Training

Inputs and Triggers -Internal

bull Acceptance activitiesbull Calibration and Maintenance recordsbull Design Control systembull Management ReviewsAnnual Product Reviewsbull Nonconformances (product and non-product)bull Packaging and Labeling materialsbull Quality Auditsbull Returned productsbull Risk Management documentsbull Service and Installation recordsbull Six SigmaProcess Excellence programsbull SPC monitoringbull And morehellip

Inputs and Triggers-External

bull Customer complaintsbull Customer feedbackbull External Quality Audit reportsbull ISOAS 9100 feedbackbull Product warrantybull Recallsfield actionsbull Identification of any other conditionissue that

does not comply withbull Your own Quality System andorbull ISOAS standards (eg ISO 9001 AS 9100 etc)bull And morehellip

Inputs and Triggers- Issues

bull Inputs not clearly defined or established

bull Trigger thresholds not establishedbull Focus on reactive metrics

(Nonconformances Complaints Audit

Observations)bull Data not easily retrievablebull Data not easy to analyze for trends

Root Cause Analysis-Issues

bull Poorlack of technical skills to conduct root cause analysis

bull Poorlack of writing skills in documenting root cause analysis

bull Poorlittle business knowledge in conducting root cause analysis across processes systems product lines and Quality Systems

Preventive Actions- Issues

bull When everything is corrective how can the organization assign resources to address Preventive Action

bull Risk assessment may not be designed to address elevation to CAPA for a potential issue or improvement (Preventive Action)

bull CAPA metrics tend to focus on closure rates cycle time number of open CAPAs etc Preventive Actions are in most cases longer-term solutions across processes systems product lines and Quality Systems and will take more time to close

From Corrective to Preventive

bull Clearly define inputs and establish thresholds

bull Implement predictive metricsindicators

bull Routinely review and act on sources of product and quality data

bull Make data reporting available and easy to users and management

From Corrective to Preventive

Risk Managementbull Establish elevation mechanisms to CAPAbull Use a risk assessment process to allow

prioritization of CAPAs and elevation to Management

bull Use a risk assessment process that allows CAPAs for Preventive Action

bull Link CAPA to Risk Management documentation (eg Design Control documents)

bull Make data reporting available and easy to users and management

From Corrective to Preventive

Root Cause Analysisbull Establish clear roles and responsibilities

for conducting investigationbull Increase technical skills on root cause

analysis toolsbull Improve writing skillsbull Use team approach to conduct

investigation to increase business and technical knowledge

From Corrective to Preventive

Preventive Actionbull Implement predictive metricsindicatorsbull Routinely review and act on sources of product

and quality databull Use a risk assessment process that allows CAPAs

for Preventive Actionbull Improve linkage between CAPA into Design

Controlsbull Take a holistic view of issuesbull Can it link to other Quality Systems product lines

systems andor processes

From Corrective to Preventive

Management Support and Oversightbull Ensure Management oversight and

commitmentbull Align CAPA with company departmental

and individual goals and objectivesbull Create rewards and recognition programsbull Establish joint partnership between

businesssystem owner and Information Technology for continuous improvement efforts

bull Align metrics from departmental to corporate level

Annual Product Review - Requirements

Written records subject to this review include but are not limited to the following

1048713 Manufacturing and quality records from lots or batches of products manufactured within the previous year including

bull ndash receiving inspectionbull ndash in-processbull ndash final release testing resultsbull ndash deviationsbull ndash investigationsbull ndash change control recordsbull ndash quality system trends

Annual Product Review - Requirements

Post market quality records such as

ndash Customer complaintsndash Adverse eventsndash Field actionsndash Product correctionsndash Regulatory submissionsndash Returned or salvaged products

Conclusions - Annual Product Review

bull Covers the product cradle to grave Presents management a view of product and process behavior over time

bull Is influenced by all aspects of the Quality System - including in process and release testing

bull Supports decisions related to design control process validation and control as well as user drift

bull Identifies trendsopportunities across mfg lines or sites

  • Slide 1
  • What Is Risk
  • Possibility
  • What Is Risk Management
  • What Is Acceptable Risk
  • The Seriousness of a Risk
  • Potential Risk Scenarios
  • Ways to Deal With Risk
  • Systems of Feedback
  • Balance
  • Why Risk as Part of CAPA System
  • CAPA Connecting Risk Management and Trending
  • Key Definitions
  • CAPA Process
  • Inputs and Triggers -Internal
  • Inputs and Triggers-External
  • Inputs and Triggers- Issues
  • Root Cause Analysis-Issues
  • Preventive Actions- Issues
  • From Corrective to Preventive
  • From Corrective to Preventive (2)
  • From Corrective to Preventive (3)
  • From Corrective to Preventive (4)
  • From Corrective to Preventive (5)
  • Annual Product Review - Requirements
  • Annual Product Review - Requirements (2)
  • Conclusions - Annual Product Review
Page 16: Risk Management Training

Inputs and Triggers-External

bull Customer complaintsbull Customer feedbackbull External Quality Audit reportsbull ISOAS 9100 feedbackbull Product warrantybull Recallsfield actionsbull Identification of any other conditionissue that

does not comply withbull Your own Quality System andorbull ISOAS standards (eg ISO 9001 AS 9100 etc)bull And morehellip

Inputs and Triggers- Issues

bull Inputs not clearly defined or established

bull Trigger thresholds not establishedbull Focus on reactive metrics

(Nonconformances Complaints Audit

Observations)bull Data not easily retrievablebull Data not easy to analyze for trends

Root Cause Analysis-Issues

bull Poorlack of technical skills to conduct root cause analysis

bull Poorlack of writing skills in documenting root cause analysis

bull Poorlittle business knowledge in conducting root cause analysis across processes systems product lines and Quality Systems

Preventive Actions- Issues

bull When everything is corrective how can the organization assign resources to address Preventive Action

bull Risk assessment may not be designed to address elevation to CAPA for a potential issue or improvement (Preventive Action)

bull CAPA metrics tend to focus on closure rates cycle time number of open CAPAs etc Preventive Actions are in most cases longer-term solutions across processes systems product lines and Quality Systems and will take more time to close

From Corrective to Preventive

bull Clearly define inputs and establish thresholds

bull Implement predictive metricsindicators

bull Routinely review and act on sources of product and quality data

bull Make data reporting available and easy to users and management

From Corrective to Preventive

Risk Managementbull Establish elevation mechanisms to CAPAbull Use a risk assessment process to allow

prioritization of CAPAs and elevation to Management

bull Use a risk assessment process that allows CAPAs for Preventive Action

bull Link CAPA to Risk Management documentation (eg Design Control documents)

bull Make data reporting available and easy to users and management

From Corrective to Preventive

Root Cause Analysisbull Establish clear roles and responsibilities

for conducting investigationbull Increase technical skills on root cause

analysis toolsbull Improve writing skillsbull Use team approach to conduct

investigation to increase business and technical knowledge

From Corrective to Preventive

Preventive Actionbull Implement predictive metricsindicatorsbull Routinely review and act on sources of product

and quality databull Use a risk assessment process that allows CAPAs

for Preventive Actionbull Improve linkage between CAPA into Design

Controlsbull Take a holistic view of issuesbull Can it link to other Quality Systems product lines

systems andor processes

From Corrective to Preventive

Management Support and Oversightbull Ensure Management oversight and

commitmentbull Align CAPA with company departmental

and individual goals and objectivesbull Create rewards and recognition programsbull Establish joint partnership between

businesssystem owner and Information Technology for continuous improvement efforts

bull Align metrics from departmental to corporate level

Annual Product Review - Requirements

Written records subject to this review include but are not limited to the following

1048713 Manufacturing and quality records from lots or batches of products manufactured within the previous year including

bull ndash receiving inspectionbull ndash in-processbull ndash final release testing resultsbull ndash deviationsbull ndash investigationsbull ndash change control recordsbull ndash quality system trends

Annual Product Review - Requirements

Post market quality records such as

ndash Customer complaintsndash Adverse eventsndash Field actionsndash Product correctionsndash Regulatory submissionsndash Returned or salvaged products

Conclusions - Annual Product Review

bull Covers the product cradle to grave Presents management a view of product and process behavior over time

bull Is influenced by all aspects of the Quality System - including in process and release testing

bull Supports decisions related to design control process validation and control as well as user drift

bull Identifies trendsopportunities across mfg lines or sites

  • Slide 1
  • What Is Risk
  • Possibility
  • What Is Risk Management
  • What Is Acceptable Risk
  • The Seriousness of a Risk
  • Potential Risk Scenarios
  • Ways to Deal With Risk
  • Systems of Feedback
  • Balance
  • Why Risk as Part of CAPA System
  • CAPA Connecting Risk Management and Trending
  • Key Definitions
  • CAPA Process
  • Inputs and Triggers -Internal
  • Inputs and Triggers-External
  • Inputs and Triggers- Issues
  • Root Cause Analysis-Issues
  • Preventive Actions- Issues
  • From Corrective to Preventive
  • From Corrective to Preventive (2)
  • From Corrective to Preventive (3)
  • From Corrective to Preventive (4)
  • From Corrective to Preventive (5)
  • Annual Product Review - Requirements
  • Annual Product Review - Requirements (2)
  • Conclusions - Annual Product Review
Page 17: Risk Management Training

Inputs and Triggers- Issues

bull Inputs not clearly defined or established

bull Trigger thresholds not establishedbull Focus on reactive metrics

(Nonconformances Complaints Audit

Observations)bull Data not easily retrievablebull Data not easy to analyze for trends

Root Cause Analysis-Issues

bull Poorlack of technical skills to conduct root cause analysis

bull Poorlack of writing skills in documenting root cause analysis

bull Poorlittle business knowledge in conducting root cause analysis across processes systems product lines and Quality Systems

Preventive Actions- Issues

bull When everything is corrective how can the organization assign resources to address Preventive Action

bull Risk assessment may not be designed to address elevation to CAPA for a potential issue or improvement (Preventive Action)

bull CAPA metrics tend to focus on closure rates cycle time number of open CAPAs etc Preventive Actions are in most cases longer-term solutions across processes systems product lines and Quality Systems and will take more time to close

From Corrective to Preventive

bull Clearly define inputs and establish thresholds

bull Implement predictive metricsindicators

bull Routinely review and act on sources of product and quality data

bull Make data reporting available and easy to users and management

From Corrective to Preventive

Risk Managementbull Establish elevation mechanisms to CAPAbull Use a risk assessment process to allow

prioritization of CAPAs and elevation to Management

bull Use a risk assessment process that allows CAPAs for Preventive Action

bull Link CAPA to Risk Management documentation (eg Design Control documents)

bull Make data reporting available and easy to users and management

From Corrective to Preventive

Root Cause Analysisbull Establish clear roles and responsibilities

for conducting investigationbull Increase technical skills on root cause

analysis toolsbull Improve writing skillsbull Use team approach to conduct

investigation to increase business and technical knowledge

From Corrective to Preventive

Preventive Actionbull Implement predictive metricsindicatorsbull Routinely review and act on sources of product

and quality databull Use a risk assessment process that allows CAPAs

for Preventive Actionbull Improve linkage between CAPA into Design

Controlsbull Take a holistic view of issuesbull Can it link to other Quality Systems product lines

systems andor processes

From Corrective to Preventive

Management Support and Oversightbull Ensure Management oversight and

commitmentbull Align CAPA with company departmental

and individual goals and objectivesbull Create rewards and recognition programsbull Establish joint partnership between

businesssystem owner and Information Technology for continuous improvement efforts

bull Align metrics from departmental to corporate level

Annual Product Review - Requirements

Written records subject to this review include but are not limited to the following

1048713 Manufacturing and quality records from lots or batches of products manufactured within the previous year including

bull ndash receiving inspectionbull ndash in-processbull ndash final release testing resultsbull ndash deviationsbull ndash investigationsbull ndash change control recordsbull ndash quality system trends

Annual Product Review - Requirements

Post market quality records such as

ndash Customer complaintsndash Adverse eventsndash Field actionsndash Product correctionsndash Regulatory submissionsndash Returned or salvaged products

Conclusions - Annual Product Review

bull Covers the product cradle to grave Presents management a view of product and process behavior over time

bull Is influenced by all aspects of the Quality System - including in process and release testing

bull Supports decisions related to design control process validation and control as well as user drift

bull Identifies trendsopportunities across mfg lines or sites

  • Slide 1
  • What Is Risk
  • Possibility
  • What Is Risk Management
  • What Is Acceptable Risk
  • The Seriousness of a Risk
  • Potential Risk Scenarios
  • Ways to Deal With Risk
  • Systems of Feedback
  • Balance
  • Why Risk as Part of CAPA System
  • CAPA Connecting Risk Management and Trending
  • Key Definitions
  • CAPA Process
  • Inputs and Triggers -Internal
  • Inputs and Triggers-External
  • Inputs and Triggers- Issues
  • Root Cause Analysis-Issues
  • Preventive Actions- Issues
  • From Corrective to Preventive
  • From Corrective to Preventive (2)
  • From Corrective to Preventive (3)
  • From Corrective to Preventive (4)
  • From Corrective to Preventive (5)
  • Annual Product Review - Requirements
  • Annual Product Review - Requirements (2)
  • Conclusions - Annual Product Review
Page 18: Risk Management Training

Root Cause Analysis-Issues

bull Poorlack of technical skills to conduct root cause analysis

bull Poorlack of writing skills in documenting root cause analysis

bull Poorlittle business knowledge in conducting root cause analysis across processes systems product lines and Quality Systems

Preventive Actions- Issues

bull When everything is corrective how can the organization assign resources to address Preventive Action

bull Risk assessment may not be designed to address elevation to CAPA for a potential issue or improvement (Preventive Action)

bull CAPA metrics tend to focus on closure rates cycle time number of open CAPAs etc Preventive Actions are in most cases longer-term solutions across processes systems product lines and Quality Systems and will take more time to close

From Corrective to Preventive

bull Clearly define inputs and establish thresholds

bull Implement predictive metricsindicators

bull Routinely review and act on sources of product and quality data

bull Make data reporting available and easy to users and management

From Corrective to Preventive

Risk Managementbull Establish elevation mechanisms to CAPAbull Use a risk assessment process to allow

prioritization of CAPAs and elevation to Management

bull Use a risk assessment process that allows CAPAs for Preventive Action

bull Link CAPA to Risk Management documentation (eg Design Control documents)

bull Make data reporting available and easy to users and management

From Corrective to Preventive

Root Cause Analysisbull Establish clear roles and responsibilities

for conducting investigationbull Increase technical skills on root cause

analysis toolsbull Improve writing skillsbull Use team approach to conduct

investigation to increase business and technical knowledge

From Corrective to Preventive

Preventive Actionbull Implement predictive metricsindicatorsbull Routinely review and act on sources of product

and quality databull Use a risk assessment process that allows CAPAs

for Preventive Actionbull Improve linkage between CAPA into Design

Controlsbull Take a holistic view of issuesbull Can it link to other Quality Systems product lines

systems andor processes

From Corrective to Preventive

Management Support and Oversightbull Ensure Management oversight and

commitmentbull Align CAPA with company departmental

and individual goals and objectivesbull Create rewards and recognition programsbull Establish joint partnership between

businesssystem owner and Information Technology for continuous improvement efforts

bull Align metrics from departmental to corporate level

Annual Product Review - Requirements

Written records subject to this review include but are not limited to the following

1048713 Manufacturing and quality records from lots or batches of products manufactured within the previous year including

bull ndash receiving inspectionbull ndash in-processbull ndash final release testing resultsbull ndash deviationsbull ndash investigationsbull ndash change control recordsbull ndash quality system trends

Annual Product Review - Requirements

Post market quality records such as

ndash Customer complaintsndash Adverse eventsndash Field actionsndash Product correctionsndash Regulatory submissionsndash Returned or salvaged products

Conclusions - Annual Product Review

bull Covers the product cradle to grave Presents management a view of product and process behavior over time

bull Is influenced by all aspects of the Quality System - including in process and release testing

bull Supports decisions related to design control process validation and control as well as user drift

bull Identifies trendsopportunities across mfg lines or sites

  • Slide 1
  • What Is Risk
  • Possibility
  • What Is Risk Management
  • What Is Acceptable Risk
  • The Seriousness of a Risk
  • Potential Risk Scenarios
  • Ways to Deal With Risk
  • Systems of Feedback
  • Balance
  • Why Risk as Part of CAPA System
  • CAPA Connecting Risk Management and Trending
  • Key Definitions
  • CAPA Process
  • Inputs and Triggers -Internal
  • Inputs and Triggers-External
  • Inputs and Triggers- Issues
  • Root Cause Analysis-Issues
  • Preventive Actions- Issues
  • From Corrective to Preventive
  • From Corrective to Preventive (2)
  • From Corrective to Preventive (3)
  • From Corrective to Preventive (4)
  • From Corrective to Preventive (5)
  • Annual Product Review - Requirements
  • Annual Product Review - Requirements (2)
  • Conclusions - Annual Product Review
Page 19: Risk Management Training

Preventive Actions- Issues

bull When everything is corrective how can the organization assign resources to address Preventive Action

bull Risk assessment may not be designed to address elevation to CAPA for a potential issue or improvement (Preventive Action)

bull CAPA metrics tend to focus on closure rates cycle time number of open CAPAs etc Preventive Actions are in most cases longer-term solutions across processes systems product lines and Quality Systems and will take more time to close

From Corrective to Preventive

bull Clearly define inputs and establish thresholds

bull Implement predictive metricsindicators

bull Routinely review and act on sources of product and quality data

bull Make data reporting available and easy to users and management

From Corrective to Preventive

Risk Managementbull Establish elevation mechanisms to CAPAbull Use a risk assessment process to allow

prioritization of CAPAs and elevation to Management

bull Use a risk assessment process that allows CAPAs for Preventive Action

bull Link CAPA to Risk Management documentation (eg Design Control documents)

bull Make data reporting available and easy to users and management

From Corrective to Preventive

Root Cause Analysisbull Establish clear roles and responsibilities

for conducting investigationbull Increase technical skills on root cause

analysis toolsbull Improve writing skillsbull Use team approach to conduct

investigation to increase business and technical knowledge

From Corrective to Preventive

Preventive Actionbull Implement predictive metricsindicatorsbull Routinely review and act on sources of product

and quality databull Use a risk assessment process that allows CAPAs

for Preventive Actionbull Improve linkage between CAPA into Design

Controlsbull Take a holistic view of issuesbull Can it link to other Quality Systems product lines

systems andor processes

From Corrective to Preventive

Management Support and Oversightbull Ensure Management oversight and

commitmentbull Align CAPA with company departmental

and individual goals and objectivesbull Create rewards and recognition programsbull Establish joint partnership between

businesssystem owner and Information Technology for continuous improvement efforts

bull Align metrics from departmental to corporate level

Annual Product Review - Requirements

Written records subject to this review include but are not limited to the following

1048713 Manufacturing and quality records from lots or batches of products manufactured within the previous year including

bull ndash receiving inspectionbull ndash in-processbull ndash final release testing resultsbull ndash deviationsbull ndash investigationsbull ndash change control recordsbull ndash quality system trends

Annual Product Review - Requirements

Post market quality records such as

ndash Customer complaintsndash Adverse eventsndash Field actionsndash Product correctionsndash Regulatory submissionsndash Returned or salvaged products

Conclusions - Annual Product Review

bull Covers the product cradle to grave Presents management a view of product and process behavior over time

bull Is influenced by all aspects of the Quality System - including in process and release testing

bull Supports decisions related to design control process validation and control as well as user drift

bull Identifies trendsopportunities across mfg lines or sites

  • Slide 1
  • What Is Risk
  • Possibility
  • What Is Risk Management
  • What Is Acceptable Risk
  • The Seriousness of a Risk
  • Potential Risk Scenarios
  • Ways to Deal With Risk
  • Systems of Feedback
  • Balance
  • Why Risk as Part of CAPA System
  • CAPA Connecting Risk Management and Trending
  • Key Definitions
  • CAPA Process
  • Inputs and Triggers -Internal
  • Inputs and Triggers-External
  • Inputs and Triggers- Issues
  • Root Cause Analysis-Issues
  • Preventive Actions- Issues
  • From Corrective to Preventive
  • From Corrective to Preventive (2)
  • From Corrective to Preventive (3)
  • From Corrective to Preventive (4)
  • From Corrective to Preventive (5)
  • Annual Product Review - Requirements
  • Annual Product Review - Requirements (2)
  • Conclusions - Annual Product Review
Page 20: Risk Management Training

From Corrective to Preventive

bull Clearly define inputs and establish thresholds

bull Implement predictive metricsindicators

bull Routinely review and act on sources of product and quality data

bull Make data reporting available and easy to users and management

From Corrective to Preventive

Risk Managementbull Establish elevation mechanisms to CAPAbull Use a risk assessment process to allow

prioritization of CAPAs and elevation to Management

bull Use a risk assessment process that allows CAPAs for Preventive Action

bull Link CAPA to Risk Management documentation (eg Design Control documents)

bull Make data reporting available and easy to users and management

From Corrective to Preventive

Root Cause Analysisbull Establish clear roles and responsibilities

for conducting investigationbull Increase technical skills on root cause

analysis toolsbull Improve writing skillsbull Use team approach to conduct

investigation to increase business and technical knowledge

From Corrective to Preventive

Preventive Actionbull Implement predictive metricsindicatorsbull Routinely review and act on sources of product

and quality databull Use a risk assessment process that allows CAPAs

for Preventive Actionbull Improve linkage between CAPA into Design

Controlsbull Take a holistic view of issuesbull Can it link to other Quality Systems product lines

systems andor processes

From Corrective to Preventive

Management Support and Oversightbull Ensure Management oversight and

commitmentbull Align CAPA with company departmental

and individual goals and objectivesbull Create rewards and recognition programsbull Establish joint partnership between

businesssystem owner and Information Technology for continuous improvement efforts

bull Align metrics from departmental to corporate level

Annual Product Review - Requirements

Written records subject to this review include but are not limited to the following

1048713 Manufacturing and quality records from lots or batches of products manufactured within the previous year including

bull ndash receiving inspectionbull ndash in-processbull ndash final release testing resultsbull ndash deviationsbull ndash investigationsbull ndash change control recordsbull ndash quality system trends

Annual Product Review - Requirements

Post market quality records such as

ndash Customer complaintsndash Adverse eventsndash Field actionsndash Product correctionsndash Regulatory submissionsndash Returned or salvaged products

Conclusions - Annual Product Review

bull Covers the product cradle to grave Presents management a view of product and process behavior over time

bull Is influenced by all aspects of the Quality System - including in process and release testing

bull Supports decisions related to design control process validation and control as well as user drift

bull Identifies trendsopportunities across mfg lines or sites

  • Slide 1
  • What Is Risk
  • Possibility
  • What Is Risk Management
  • What Is Acceptable Risk
  • The Seriousness of a Risk
  • Potential Risk Scenarios
  • Ways to Deal With Risk
  • Systems of Feedback
  • Balance
  • Why Risk as Part of CAPA System
  • CAPA Connecting Risk Management and Trending
  • Key Definitions
  • CAPA Process
  • Inputs and Triggers -Internal
  • Inputs and Triggers-External
  • Inputs and Triggers- Issues
  • Root Cause Analysis-Issues
  • Preventive Actions- Issues
  • From Corrective to Preventive
  • From Corrective to Preventive (2)
  • From Corrective to Preventive (3)
  • From Corrective to Preventive (4)
  • From Corrective to Preventive (5)
  • Annual Product Review - Requirements
  • Annual Product Review - Requirements (2)
  • Conclusions - Annual Product Review
Page 21: Risk Management Training

From Corrective to Preventive

Risk Managementbull Establish elevation mechanisms to CAPAbull Use a risk assessment process to allow

prioritization of CAPAs and elevation to Management

bull Use a risk assessment process that allows CAPAs for Preventive Action

bull Link CAPA to Risk Management documentation (eg Design Control documents)

bull Make data reporting available and easy to users and management

From Corrective to Preventive

Root Cause Analysisbull Establish clear roles and responsibilities

for conducting investigationbull Increase technical skills on root cause

analysis toolsbull Improve writing skillsbull Use team approach to conduct

investigation to increase business and technical knowledge

From Corrective to Preventive

Preventive Actionbull Implement predictive metricsindicatorsbull Routinely review and act on sources of product

and quality databull Use a risk assessment process that allows CAPAs

for Preventive Actionbull Improve linkage between CAPA into Design

Controlsbull Take a holistic view of issuesbull Can it link to other Quality Systems product lines

systems andor processes

From Corrective to Preventive

Management Support and Oversightbull Ensure Management oversight and

commitmentbull Align CAPA with company departmental

and individual goals and objectivesbull Create rewards and recognition programsbull Establish joint partnership between

businesssystem owner and Information Technology for continuous improvement efforts

bull Align metrics from departmental to corporate level

Annual Product Review - Requirements

Written records subject to this review include but are not limited to the following

1048713 Manufacturing and quality records from lots or batches of products manufactured within the previous year including

bull ndash receiving inspectionbull ndash in-processbull ndash final release testing resultsbull ndash deviationsbull ndash investigationsbull ndash change control recordsbull ndash quality system trends

Annual Product Review - Requirements

Post market quality records such as

ndash Customer complaintsndash Adverse eventsndash Field actionsndash Product correctionsndash Regulatory submissionsndash Returned or salvaged products

Conclusions - Annual Product Review

bull Covers the product cradle to grave Presents management a view of product and process behavior over time

bull Is influenced by all aspects of the Quality System - including in process and release testing

bull Supports decisions related to design control process validation and control as well as user drift

bull Identifies trendsopportunities across mfg lines or sites

  • Slide 1
  • What Is Risk
  • Possibility
  • What Is Risk Management
  • What Is Acceptable Risk
  • The Seriousness of a Risk
  • Potential Risk Scenarios
  • Ways to Deal With Risk
  • Systems of Feedback
  • Balance
  • Why Risk as Part of CAPA System
  • CAPA Connecting Risk Management and Trending
  • Key Definitions
  • CAPA Process
  • Inputs and Triggers -Internal
  • Inputs and Triggers-External
  • Inputs and Triggers- Issues
  • Root Cause Analysis-Issues
  • Preventive Actions- Issues
  • From Corrective to Preventive
  • From Corrective to Preventive (2)
  • From Corrective to Preventive (3)
  • From Corrective to Preventive (4)
  • From Corrective to Preventive (5)
  • Annual Product Review - Requirements
  • Annual Product Review - Requirements (2)
  • Conclusions - Annual Product Review
Page 22: Risk Management Training

From Corrective to Preventive

Root Cause Analysisbull Establish clear roles and responsibilities

for conducting investigationbull Increase technical skills on root cause

analysis toolsbull Improve writing skillsbull Use team approach to conduct

investigation to increase business and technical knowledge

From Corrective to Preventive

Preventive Actionbull Implement predictive metricsindicatorsbull Routinely review and act on sources of product

and quality databull Use a risk assessment process that allows CAPAs

for Preventive Actionbull Improve linkage between CAPA into Design

Controlsbull Take a holistic view of issuesbull Can it link to other Quality Systems product lines

systems andor processes

From Corrective to Preventive

Management Support and Oversightbull Ensure Management oversight and

commitmentbull Align CAPA with company departmental

and individual goals and objectivesbull Create rewards and recognition programsbull Establish joint partnership between

businesssystem owner and Information Technology for continuous improvement efforts

bull Align metrics from departmental to corporate level

Annual Product Review - Requirements

Written records subject to this review include but are not limited to the following

1048713 Manufacturing and quality records from lots or batches of products manufactured within the previous year including

bull ndash receiving inspectionbull ndash in-processbull ndash final release testing resultsbull ndash deviationsbull ndash investigationsbull ndash change control recordsbull ndash quality system trends

Annual Product Review - Requirements

Post market quality records such as

ndash Customer complaintsndash Adverse eventsndash Field actionsndash Product correctionsndash Regulatory submissionsndash Returned or salvaged products

Conclusions - Annual Product Review

bull Covers the product cradle to grave Presents management a view of product and process behavior over time

bull Is influenced by all aspects of the Quality System - including in process and release testing

bull Supports decisions related to design control process validation and control as well as user drift

bull Identifies trendsopportunities across mfg lines or sites

  • Slide 1
  • What Is Risk
  • Possibility
  • What Is Risk Management
  • What Is Acceptable Risk
  • The Seriousness of a Risk
  • Potential Risk Scenarios
  • Ways to Deal With Risk
  • Systems of Feedback
  • Balance
  • Why Risk as Part of CAPA System
  • CAPA Connecting Risk Management and Trending
  • Key Definitions
  • CAPA Process
  • Inputs and Triggers -Internal
  • Inputs and Triggers-External
  • Inputs and Triggers- Issues
  • Root Cause Analysis-Issues
  • Preventive Actions- Issues
  • From Corrective to Preventive
  • From Corrective to Preventive (2)
  • From Corrective to Preventive (3)
  • From Corrective to Preventive (4)
  • From Corrective to Preventive (5)
  • Annual Product Review - Requirements
  • Annual Product Review - Requirements (2)
  • Conclusions - Annual Product Review
Page 23: Risk Management Training

From Corrective to Preventive

Preventive Actionbull Implement predictive metricsindicatorsbull Routinely review and act on sources of product

and quality databull Use a risk assessment process that allows CAPAs

for Preventive Actionbull Improve linkage between CAPA into Design

Controlsbull Take a holistic view of issuesbull Can it link to other Quality Systems product lines

systems andor processes

From Corrective to Preventive

Management Support and Oversightbull Ensure Management oversight and

commitmentbull Align CAPA with company departmental

and individual goals and objectivesbull Create rewards and recognition programsbull Establish joint partnership between

businesssystem owner and Information Technology for continuous improvement efforts

bull Align metrics from departmental to corporate level

Annual Product Review - Requirements

Written records subject to this review include but are not limited to the following

1048713 Manufacturing and quality records from lots or batches of products manufactured within the previous year including

bull ndash receiving inspectionbull ndash in-processbull ndash final release testing resultsbull ndash deviationsbull ndash investigationsbull ndash change control recordsbull ndash quality system trends

Annual Product Review - Requirements

Post market quality records such as

ndash Customer complaintsndash Adverse eventsndash Field actionsndash Product correctionsndash Regulatory submissionsndash Returned or salvaged products

Conclusions - Annual Product Review

bull Covers the product cradle to grave Presents management a view of product and process behavior over time

bull Is influenced by all aspects of the Quality System - including in process and release testing

bull Supports decisions related to design control process validation and control as well as user drift

bull Identifies trendsopportunities across mfg lines or sites

  • Slide 1
  • What Is Risk
  • Possibility
  • What Is Risk Management
  • What Is Acceptable Risk
  • The Seriousness of a Risk
  • Potential Risk Scenarios
  • Ways to Deal With Risk
  • Systems of Feedback
  • Balance
  • Why Risk as Part of CAPA System
  • CAPA Connecting Risk Management and Trending
  • Key Definitions
  • CAPA Process
  • Inputs and Triggers -Internal
  • Inputs and Triggers-External
  • Inputs and Triggers- Issues
  • Root Cause Analysis-Issues
  • Preventive Actions- Issues
  • From Corrective to Preventive
  • From Corrective to Preventive (2)
  • From Corrective to Preventive (3)
  • From Corrective to Preventive (4)
  • From Corrective to Preventive (5)
  • Annual Product Review - Requirements
  • Annual Product Review - Requirements (2)
  • Conclusions - Annual Product Review
Page 24: Risk Management Training

From Corrective to Preventive

Management Support and Oversightbull Ensure Management oversight and

commitmentbull Align CAPA with company departmental

and individual goals and objectivesbull Create rewards and recognition programsbull Establish joint partnership between

businesssystem owner and Information Technology for continuous improvement efforts

bull Align metrics from departmental to corporate level

Annual Product Review - Requirements

Written records subject to this review include but are not limited to the following

1048713 Manufacturing and quality records from lots or batches of products manufactured within the previous year including

bull ndash receiving inspectionbull ndash in-processbull ndash final release testing resultsbull ndash deviationsbull ndash investigationsbull ndash change control recordsbull ndash quality system trends

Annual Product Review - Requirements

Post market quality records such as

ndash Customer complaintsndash Adverse eventsndash Field actionsndash Product correctionsndash Regulatory submissionsndash Returned or salvaged products

Conclusions - Annual Product Review

bull Covers the product cradle to grave Presents management a view of product and process behavior over time

bull Is influenced by all aspects of the Quality System - including in process and release testing

bull Supports decisions related to design control process validation and control as well as user drift

bull Identifies trendsopportunities across mfg lines or sites

  • Slide 1
  • What Is Risk
  • Possibility
  • What Is Risk Management
  • What Is Acceptable Risk
  • The Seriousness of a Risk
  • Potential Risk Scenarios
  • Ways to Deal With Risk
  • Systems of Feedback
  • Balance
  • Why Risk as Part of CAPA System
  • CAPA Connecting Risk Management and Trending
  • Key Definitions
  • CAPA Process
  • Inputs and Triggers -Internal
  • Inputs and Triggers-External
  • Inputs and Triggers- Issues
  • Root Cause Analysis-Issues
  • Preventive Actions- Issues
  • From Corrective to Preventive
  • From Corrective to Preventive (2)
  • From Corrective to Preventive (3)
  • From Corrective to Preventive (4)
  • From Corrective to Preventive (5)
  • Annual Product Review - Requirements
  • Annual Product Review - Requirements (2)
  • Conclusions - Annual Product Review
Page 25: Risk Management Training

Annual Product Review - Requirements

Written records subject to this review include but are not limited to the following

1048713 Manufacturing and quality records from lots or batches of products manufactured within the previous year including

bull ndash receiving inspectionbull ndash in-processbull ndash final release testing resultsbull ndash deviationsbull ndash investigationsbull ndash change control recordsbull ndash quality system trends

Annual Product Review - Requirements

Post market quality records such as

ndash Customer complaintsndash Adverse eventsndash Field actionsndash Product correctionsndash Regulatory submissionsndash Returned or salvaged products

Conclusions - Annual Product Review

bull Covers the product cradle to grave Presents management a view of product and process behavior over time

bull Is influenced by all aspects of the Quality System - including in process and release testing

bull Supports decisions related to design control process validation and control as well as user drift

bull Identifies trendsopportunities across mfg lines or sites

  • Slide 1
  • What Is Risk
  • Possibility
  • What Is Risk Management
  • What Is Acceptable Risk
  • The Seriousness of a Risk
  • Potential Risk Scenarios
  • Ways to Deal With Risk
  • Systems of Feedback
  • Balance
  • Why Risk as Part of CAPA System
  • CAPA Connecting Risk Management and Trending
  • Key Definitions
  • CAPA Process
  • Inputs and Triggers -Internal
  • Inputs and Triggers-External
  • Inputs and Triggers- Issues
  • Root Cause Analysis-Issues
  • Preventive Actions- Issues
  • From Corrective to Preventive
  • From Corrective to Preventive (2)
  • From Corrective to Preventive (3)
  • From Corrective to Preventive (4)
  • From Corrective to Preventive (5)
  • Annual Product Review - Requirements
  • Annual Product Review - Requirements (2)
  • Conclusions - Annual Product Review
Page 26: Risk Management Training

Annual Product Review - Requirements

Post market quality records such as

ndash Customer complaintsndash Adverse eventsndash Field actionsndash Product correctionsndash Regulatory submissionsndash Returned or salvaged products

Conclusions - Annual Product Review

bull Covers the product cradle to grave Presents management a view of product and process behavior over time

bull Is influenced by all aspects of the Quality System - including in process and release testing

bull Supports decisions related to design control process validation and control as well as user drift

bull Identifies trendsopportunities across mfg lines or sites

  • Slide 1
  • What Is Risk
  • Possibility
  • What Is Risk Management
  • What Is Acceptable Risk
  • The Seriousness of a Risk
  • Potential Risk Scenarios
  • Ways to Deal With Risk
  • Systems of Feedback
  • Balance
  • Why Risk as Part of CAPA System
  • CAPA Connecting Risk Management and Trending
  • Key Definitions
  • CAPA Process
  • Inputs and Triggers -Internal
  • Inputs and Triggers-External
  • Inputs and Triggers- Issues
  • Root Cause Analysis-Issues
  • Preventive Actions- Issues
  • From Corrective to Preventive
  • From Corrective to Preventive (2)
  • From Corrective to Preventive (3)
  • From Corrective to Preventive (4)
  • From Corrective to Preventive (5)
  • Annual Product Review - Requirements
  • Annual Product Review - Requirements (2)
  • Conclusions - Annual Product Review
Page 27: Risk Management Training

Conclusions - Annual Product Review

bull Covers the product cradle to grave Presents management a view of product and process behavior over time

bull Is influenced by all aspects of the Quality System - including in process and release testing

bull Supports decisions related to design control process validation and control as well as user drift

bull Identifies trendsopportunities across mfg lines or sites

  • Slide 1
  • What Is Risk
  • Possibility
  • What Is Risk Management
  • What Is Acceptable Risk
  • The Seriousness of a Risk
  • Potential Risk Scenarios
  • Ways to Deal With Risk
  • Systems of Feedback
  • Balance
  • Why Risk as Part of CAPA System
  • CAPA Connecting Risk Management and Trending
  • Key Definitions
  • CAPA Process
  • Inputs and Triggers -Internal
  • Inputs and Triggers-External
  • Inputs and Triggers- Issues
  • Root Cause Analysis-Issues
  • Preventive Actions- Issues
  • From Corrective to Preventive
  • From Corrective to Preventive (2)
  • From Corrective to Preventive (3)
  • From Corrective to Preventive (4)
  • From Corrective to Preventive (5)
  • Annual Product Review - Requirements
  • Annual Product Review - Requirements (2)
  • Conclusions - Annual Product Review