Empowering Operations and Perfecting Compliance Technical Knowledge Management
Jun 02, 2015
Empowering Operations and Perfecting Compliance
Technical Knowledge Management
Bespoken Instructions
Learning pathway
Knowledge definition*
The psychological result of perception, learning and reasoning
• Something you have observed
• That you have interpreted and stored
• That you can apply to future situations
*Webster
How we work
Storyboard• Transfer the full actual instructions into a synopsis of
operations• Customer project team approval
Capture• Video capture on-site• Selection of key steps
Project• Organize the procedure relevant information• Project Mediabooks
Libraries• Released Mediabooks• SOPs, Specimens, Warnings & Symbols Publishing• Simplifying update and revision exercise
NDA
Agenda
1. Single Use Ecosystem
2. Shop floor Set Up & Operations
3. Compliance
4. Case Study
5. Lessons Learnt and Conclusion
1. Single Use Ecosystem
«Production blog»
• Paradigm changes: Single-use, global operations, flexibility…
• “Disposables do not come with instruction manuals; you have to figure out yourself how to make them work in your specific context.”
• “ Operations in modern stainless steel plants do not have extensive manual skills therefore a considerable amount of retraining is required (even for experienced operators) to provide reproducible, accurate and compliant operations.”
• “Since operations are more manual they are highly susceptible to operator-to-operator variation.”
• “Balance cost and compliance”
Single Use Last Decade Journey
Single Use in production are pre-fabricated Units
On-The-Job: Successful model…
IKEA
could never achieve such a lowcost position if customers did not agree to take on some of the tasks usually performed by manufacturers and retailers, such as delivering furniture to their homes and assembling it.
Jérôme Barthélemy: (Excerpts) FALL 2006 MIT SLOAN MANAGEMENT REVIEW
Single Use is changing personnel daily life
Instructions at point-of-use
Yet know-how and knowledge do not fully stand out from SOPs
Agenda
1. Single Use Ecosystem
2. Shop floor Set Up & Operations
3. Compliance
4. Case Study
5. Lessons Learnt and Conclusion
Set up a 50L Bioreactor
S.U versus 50L Bio preparation S.S
50L Bio Single Use - courtesy of Crucell B.V.
CIP - SIP
50L Bio Stainless Steel
Benchmark activities with Mediabooks
• Single Use activities– Deliver at point of use,
– Unpacking and check
– Installation
– Inflation
– Sensors and fluids
connections
– Run
• Stainless Steel– Gaskets/ Seals
– Valves & Air Filters connections
– Sensors
– SIP CIP
– Run
1000L Bioreators Set up comparison time wiseCourtesy of Sartorius Stedim biotech
Single-Use Stainless Steel
The Last Mile:
• Activities Changed
• Skill Sets Changed
• Logistic Changed
• Risks Changed
• Labor more Complex
Disposables require to cope with a Shopfloor ECOSYSTEM change
Agenda
1. Single Use Ecosystem
2. Shop floor Set Up & Operations
3. Compliance
4. Case Study
5. Lessons Learnt and Conclusion
Compliance
• CDER Enforcement Actions Top 20 483s FY 2012
• 44% SOP related
• 11% Training related
Top 20 Inspectional Observations CDERTraining related 483 citations
How to ensure the training translate into less deviation and more efficient processes?
«Retrain is not doing better»
FDA White Paper: March 2011
How To Reduce Human Error By Managing Human Factors White Paper
DRUGS FY 2006 483 FY citations analysis rank freqTraining-operations, GMPs, written procedures 21 CFR 211.25(a) 9 60.00GMP Training Frequency 21 CFR 211.25(a) 23 38.00Training, Education, Experience overall 21 CFR 211.25(a) 62 16.00Supervisor Training/Education/Experience 21 CFR 211.25(b) 77 13.00 # Total Training citations in top 20 60.00% training citations in top 20 4.75%
2012 rank Freq
8 65.0013 54.0019 44.0097 9.00163.00
11.31%
Procedures not in writing/ fully followed
21 CFR 211.22(d)1 127 1 150 1 112 1 157 1 165 1 201 1 169
Absence of Written Procedures
21 CFR 211.100(a)5 83 7 62 7 52 6 75 6 89 2 128 3 116
Written procedures not established/ followed
21 CFR 211.67(b)10 54 10 52 9 43 9 64 7 80 7 89 7 73
SOPs not followed / documented
21 CFR 211.100(b)6 82 5 72 5 58 4 81 2 115 6 89 10 64
# Total SOPs related out of top 10 citations
2008 2009 2010 2011 2012
346 336 265 377 449 507 422
2006 2007
46.99% 44.70%42.51% 43.75% 43.09% 45.53% 46.72%
Responsibilities of quality control unit
Production and Process Controls
Cleaning and Maintenance
Production and Process Controls
How to ensure the instructions pertained in SOPs are fully understood and performed on a daily basis?Augment ownership of operations?
Top 10 Inspectional Observations – CDER SOP related 483 citations
Agenda
1. Single Use Ecosystem
2. Shop floor Set Up & Operations
3. Compliance
4. Case Study
5. Lessons Learnt and Conclusion
Minimizing variability in process operations using knowledge management platform
Herman van HerkScientist USPVaccine Process and Analytical Development Archimedesweg 4-6PO Box 20482301 CA LeidenThe NetherlandsTel: +31 (0)71 519 9197Email: [email protected]
Leiden-USP-Valerio
Bern-Cell & virus banking-USP-Process characterization
Solna
Springhouse
External-Licensees-Partners
Key elements:-Training-Standardized Operation
Knowledge transfer for USP processes
Training & standardized operation
• Training on a process, is dependent on factors like...– Quality of procedures– Know-how of trainer/trainee– Scattered information
• Standardized operations– Without a standard,
there can be no improvement
Sources: http://www.shmula.com
Project Sequence of Events
• Exploratory discussions and NDA• Detailed definition of scope of work:
– Exchange of existing procedures– Definition of ‘script’
• Detailed discussions on procedures– Need for alignment how things should be done
• Video recording ‘as is’ – multi-angle video shooting
• Review of draft videos and finalize• Finalization in Mediabook platform
Video platform
• Current platform:
7 applications with > 50 Mediabooks
Used across different sites within Crucell
Used for training of external parties as well
Conclusion
• Multi-media tools help to:• Learn from each other and analyze• Show what cannot be written• Train by reviewing key steps at its own pace
For Crucell, it is a strong tool for both training and standardization of USP processes
Agenda
1. Single Use Ecosystem
2. Shop floor Set Up & Operations
3. Compliance
4. Case Study
5. Lessons Learnt and Conclusion
Lessons Learnt and Questions
1. SOPs: Classrooms – Hands-on
Training efficacy?
Sole training material ?
2. «Retrain is not doing better»
FDA White Paper: March 2011
How To Reduce Human Error By Managing Human Factors
3. Resources:
– Experts / Trainers availability
– Mentoring & Learn-by-peers
– On-the-Job
4. Deviation costs avoidable?
Back to the roots?
“Flip the Classroom”
Assign «Lectures» as Homework:
Watch contextualized operations prior to hands-on sessionsi. Start, Pause, Replay, without fearing interrupting ii. Free up Expert time
Hands-on sessions
i. Efficient vs time and costsii. Minimize risk on production lines
Optimize skill sets
i. On-the-job assistanceii. Mentoring, learn by peer
Conclusion
Compliance & Cost controlFirst Hand Reference Tutorials
Efficient documentation process
Less deviations
CoordinationIrrespective of language
“Watch it and do it”
Expandable
Empower Personnel: Move from “certainty” to “routine dexterity”
Thank you
Expandable and language free www.sourcin.com