excipient knowledge management mumbai 12 march 2015 part 1 & 2
TRANSCRIPT
[lsquoExcipientrsquo] Knowledge Management 2015 amp Beyond
Ajaz S Hussain PhD
Insight Advice amp Solutions LLCMaryland USA
Executive Director the National Institute for Pharmaceutical Technology amp Education
3122015 Ajaz S Hussain PhD 1
Acknowledgment
bull Thanks to Arihant Innochem Pvt Ltd for inviting me to speak and also for accepting my requests to (a) expand the program and include other speakers and (b) inviting faculty members from local schools of pharmacy
bull For me this is an opportunity to share my insights on excipients and more importantly learn something about excipient supplier ndash Pharma interactions in India
bull Arihant Innochem Pvt Ltd made the travel arrangements for my trip to Mumbai We have no other business or financial relationship They did not request to see nor did I provide an advance copy of my slides
3122015 Ajaz S Hussain PhD 2
Insights
bull Why attention to excipient knowledge management (specifically their functionality) is critical to mitigating risks (or to leverage opportunities) posed by the rapidly increasing complexity and uncertaintybull Note Knowledge management in
the context of lsquointellectual propertyrsquo is not the focus of this talk
bull In the second talk end of the day I plan to discuss how certain management practices can impact effectiveness of knowledge managementbull Note Knowledge management is
a combination of both IT and human aspects I intend to focus on lsquohuman factorsrsquo
3122015 Ajaz S Hussain PhD 3
Outline
bull Declaring my interests acknowledging experiences contributing to my current thinking
bull Current hot topics ndash lsquoexcipientsrsquo regulatory trends amp insights
bull Why attention to (excipient) knowledge management (specifically physical functionalityperformance) is critical
3122015 Ajaz S Hussain PhD 4
My interest in [lsquoexcipientsrsquo] KMacknowledging experiences contributing to my current thinking
bull Business decisions
bull Regulatory research policy amp enforcement
bull Academic research
3122015 Ajaz S Hussain PhD 5
Business decisions
bull Management responsibilitiesbull VP amp Global Head Biopharmaceutical Development Sandoz (2005-2009)
bull Developmentregulatory submission Omnitropereg Binocritreg Zarzioreg Generic Enoxaparin amp Glatiramer acetate
bull VP Next Generation Product Assessment amp CSO Philip Morris International (2009 -2012)
bull Developmentevidence qualityregulatory strategy Plant based vaccines amp assessment of products intended for tobacco harm reduction
bull President Biotechnology amp CSO Wockhardt (2012-2013)
bull Biosimilar and Complex Generic Strategy Improvement
bull AdvisoryConsulting (2013 ndash currently)
bull Mitigating risks in development of complex products Framework for effective compliance amp remediation Strengthening Culture of Quality
3122015 Ajaz S Hussain PhD 6
Regulatory research policy amp enforcement support US FDA (1995 ndash 2005)
bull Research to Policybull SUPAC BCS IVIVC hellipTopical Microbicideshellipseveral others
bull Policybull SUPAC-MR IVIVC BCS helliphellip PAT ICH FDA Lead (Quality) ndash
ldquodesired state for 21st Centuryrdquo ICH Q8 ndash 10
bull Enforcement Supportbull Expert witness for the prosecution (1995)
bull Facilitating resolution of difficult WLs linked to shortages
3122015 Ajaz S Hussain PhD 7
Knowledge to inform policy improvement
3122015 Ajaz S Hussain PhD 8
Physical Attributes Can be critical for safety efficacy and quality
3122015 Ajaz S Hussain PhD 9
July 15 2005 FDA Public Health Advisory Safety Warnings Regarding Use of Fentanyl Transdermal (Skin) Patches
Also relevant today Pattern Recognition
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Preliminary illustration of a concept Going forward expect to see regulators utilize state-of ndashthe ndashart pattern recognition and modeling systems
Effective Regulatory System Importance of Process Understanding and Quality by DesignAjaz Hussain Pharmaceutical Quality Forum 3rd Symposium November 2004 Tokyo Japan
Academic research
University of Cincinnati (1989-1994)
bull Formulation designbull Several projects ndash oral topical and
transdermalbull Example Elaborating the utility of
Transcutolreg (Gattefosseacute)
bull Computer aided formulation designbull Artificial Neural Network based
lsquoexpert systemsrsquobull Example Prototype for lsquoTechnical
Service Supportrsquo (funding - Aqualon)
NIPTE (Currently)
bull NIPTErsquos Excipient Knowledge basebull Available since 2007 at
httppharmahuborg
bull The goal of this project is to share information and modeling tools to support pharmaceutical product
3122015 Ajaz S Hussain PhD 11
Prototype for lsquoTechnical Service Supportrsquo
3122015 Ajaz S Hussain PhD 12
From a lsquoDatabasersquo to a lsquoKnowledge basersquo
bull lsquoLook-up tablesrsquo to lsquoAbility to Predictrsquo
bull Ability to predict = generate hypotheses
bull Ability (simulate) ask questions - what if
NIPTE Knowledge Management
3122015 Ajaz S Hussain PhD 13
Contact Prof Hoag Univ Maryland shoagrxumarylandedu
3122015 Ajaz S Hussain PhD 14
NIPTE Knowledge Management
This study was funded by the FDA-sponsored contract ldquoDevelopment of Quality by Design (QbD) Guidance Elements on Design Specifications across Scales with Stability Considerationsrdquo (contract number HHSF223200819929C)
3122015 Ajaz S Hussain PhD 15
Current hot topics ndashrsquoexcipientsrsquo regulatory trends amp insights ExcipientFest on 28-29 April 2015 in Washington Organizational Changes CDERFDA and Inspectional Trendshellip(Complex Genericshellip Continuous Manufacturing)
3122015 Ajaz S Hussain PhD 16
Current experience with lsquoSupplier Qualificationrsquo
bull Recent observations are summarized in this report by ECA Academy (21012015) Areas of attention
bull Accuracy and completeness of administrative documentation
bull Evidence to justify excipient and supplier qualification
bull Risk-assessment and effective integration within in QMS
bull Quality agreements
bull Going forward I envision a need to emphasize a life-cycle approach (eg linking to CAPA change control)
3122015 Ajaz S Hussain PhD 17
FDArsquos Inactive Ingredient Database -statusbull Substance Registration System (SRS)
bull Generic listing vs Specific Grade listing for commonly used excipients ndashmax precedent levels
bull Listing of Mixtures
bull The UNII code confusing the National Library of Medicine yet to finalize standards for assigning UNII codes for polymers
bull Individual Grades vs Family Data
bull Legal status of the IID and FDA communications of changes to the IID
bull DMF Implications
bull Impact on ANDAs ndash lsquoDelaysrsquo amp lsquoRefuse to File Lettersrsquo
3122015 Ajaz S Hussain PhD 18
3122015 Ajaz S Hussain PhD 19
Inactive Ingredientsrsquo to lsquoExcipientsrsquo to lsquoFunctionalityrsquo Where are we in this journeylsquo
Status of lsquoSubstances In Regulatory Practicersquo
Clearly we need a global database with improved precision and accuracy of naming (and coding) to identify describe compare and link (to products and AERs)
INDs NDAs BLAs CFRrsquos Orphan Drug ApplicationsProducts that Contain Each Substance
Pharmacological ClassificationActive Moieties Related Moieties and Salts
LADMERMetabolites
Metabolic Enzymes Transporters and EffectsDrug target (therapeutic and other) type of interaction
Solubility and Permeability (BCS)Protein Binding
Impurities and Related Substance
ISO 11238 (ISO IDMP) some challenges
Both substances amp specified substances
Implementation in EU EMA Task force
Global Ingredients Archive System (GInAS)
3122015 Ajaz S Hussain PhD 20
The War Against Fake Medicines Update on FDASIA - Guidance and Impact on Excipient Suppliers and
Users QbD Sampling Guidelines The NSFIPECANSI 363 2014 GMP standardsexplained Good Supply Practices ndash Using Cross Industry Knowledge to Devise Pragmatic Solutions Impact
of Non-harmonized Standards and What is Needed to Achieve Harmonization Advancements in the Question Based Review approach and various other excipient specific related topics An Overview of the FDA OGD
IID EWG activities Effective Sourcing and Purchasing of Excipients
Industry Collaboration for Science Based Implementation of Elemental Impurities Challenges And Opportunities In Developing
And Modernizing Public Standards For NF Excipients Monographs For Regulated Drug
Products Marketed In The USA Future Pharma Manufacturing Efficiencies and the Role of Innovative Excipient Technologies
IPEC ExcipientFest 2015
Current Hot Topics ExcipientFest on 28-29 April 2015 in Washington
3122015 Ajaz S Hussain PhD 21
The War Against Fake Medicines Update on FDASIA - Guidance and Impact on Excipient
Suppliers and Users QbD Sampling Guidelines The NSFIPECANSI 363 2014 GMP standards explained Good Supply Practices ndash Using Cross Industry Knowledge to Devise
Pragmatic Solutions Impact of Non-harmonized Standards and What is Needed to Achieve
Harmonization Advancements in the Question Based Review approach and various other
excipient specific related topics An Overview of the FDA OGD IID EWG activities Effective
Sourcing and Purchasing of Excipients Industry Collaboration for Science Based Implementation of Elemental Impurities Challenges And
Opportunities In Developing And Modernizing Public Standards For NF ExcipientsMonographs For Regulated Drug Products Marketed In The USA Future Pharma Manufacturing Efficiencies and the Role of Innovative Excipient Technologies
IPEC ExcipientFest 2015
Inspectional trends in data integrity (Bangalore Nov
2014)
22(d)
192
100(a)
160(b)
110(a)
67(b)
68(a)
25(a)
67(a)
100(b)
Recurring 483 Observations Top 10
22(d) 192 100(a) 160(b)110(a) 67(b) 68(a) 25(a)67(a) 100(b)
Jeff Medwid NIPTE-FDA Conference 13 June 2012
International Society for Pharmaceutical Engineering (ISPE) in conjunction with McKinsey amp Co will release preliminary data and findings from its Quality Metrics Pilot Program at the ISPE Quality Metrics Summit on April 21ndash22 in Baltimore
FDA Launches New Drug Quality Office With Goal of Improving the Pharmaceutical IndustryPosted 13 January 2015By Alexander Gaffney RAC
FDArsquos New Pharma Quality
Office Will Take a Team Approach
Yu Explains
Regulatory Recon Investigations Find Major Quality Problems at Indian Pharma Companies (3 December 2014)Posted 03 December 2014By Alexander Gaffney RAC
Currently the environment is complex there is high uncertainty D
on
rsquot f
org
et
fun
ctio
na
lity
o
f e
xcip
ien
ts i
s im
po
rta
nt
3122015 Ajaz S Hussain PhD 22
Need for urgent progress lsquoInactive Ingredientsrsquo to lsquoExcipientsrsquo to lsquoFunctional Excipientsrsquo
Importance of assuring quality and controlling
variability of excipients
including their lsquofunctionalityrsquo has
long been recognized
bull Increasing complexity of drugs their delivery and failure modes
bull Patient (eg pediatric) relevant failure modes
bull Simple generics to complex generics amp biosimilars
Urgent need to address gaps in the FDArsquos Inactive Ingredient Database
3122015 Ajaz S Hussain PhD 23
Trends Lab amp Manufacturing
ldquoDeletion of Datardquo
ldquoTesting Into Compliancerdquo
ldquoBMR manipulation is a slippery sloperdquo
ldquoSuggestive of faulty manufacturing process or practices even if this is not the caserdquo
ldquoIt is top managementrsquos responsibility to ensure the training program is robust and effectiverdquo
Inspectional trends in data integrity (Bangalore Nov 13 2014 - Nov 14 2014)
Growing concern some
companies ldquodata looks too good
to be truerdquo
3122015 Ajaz S Hussain PhD 24
GMP Compliance amp Remediation
Jeff Medwid NIPTE-FDA Conference 13 June 2012
QbD amp QbR Clarity on Critical Functionality
FDArsquos New Pharma Quality
Office Will Take a Team
Approach Yu Explains
Carmelo Rosa MS PsyD November 2014
Urgent Need amp Opportunity
To align amp ensure sound scientific basis of these critical regulatory decisions
FDA CDER OPQ Plans for Surveillance of Pharmaceutical Quality
Teresa Mullin PhD December 2014
3122015 Ajaz S Hussain PhD 25
Need for a comprehensive (excipient) knowledge base
Teresa Mullin PhD December 2014
3122015 Ajaz S Hussain PhD 26
Why attention to (excipient) knowledge management is criticalSpecifically for physical attributes functionality performance
3122015 Ajaz S Hussain PhD 27
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Today there are several product categories (eg controlled release inhalation products DPIrsquos topical transdermal liposomal products etc) which requires an exquisite control of complex physical material and product attributes (functionality)
Many of our current measurement systems need improvement
We depend on these to ensure control of lot-lot variability
Measurement system capability must be confirmed to be able to assess process capability (calibration amp Gauge RampR)
Life-cycle approach to quality continued process verification (FDArsquos Process Validation 2011) is a safety net
Supplier amp Excipient Qualification amp Process Validation
Measurement System Analysis
bull From lsquocalibrationrsquo to lsquoGauge RampRrsquoParticularly for physical
attributes destructive analysis
bull Many (including regulators) have not yet understood its importance
Gauge RampR well established but not commonly practiced
bull Measurement system in a state of control effective CAPA quality metrics Culture of Quality
With the move towards Statistical Process Control
bull Demonstrate equivalent in vitro performance more exacting criteria
Development of complex generic products (ER
Injectable Inhalation etc)
3122015 Ajaz S Hussain PhD 29
Process Validation (2011) Statistical Confidence Continued Process Verificationhellip
3122015 Ajaz S Hussain PhD 30
httpwwwslideshareneta2zpharmsciperformance-testing-pharmaceutical-quality-2004(accessed 6 December 2014)
3122015 Ajaz S Hussain PhD 31
Supplier amp Excipient Qualification amp CAPA
Out of Specification events are difficult to resolve
Excipient functionality can be a significant contributing factor
Sometimes reluctantly have to settle with - ldquoRoot cause unknown
600 days
I have inserted the ldquo600 daysrsquo on the figure ndash this is based on cases I have seen while at FDA)
3122015 Ajaz S Hussain PhD 32
Prevention of OOS and Effective CAPA needs a focus on critical functional attributes
Out of Specification events are difficult to resolve
Excipient functionality can be a significant contributing factor
Sometimes reluctantly have to settle with - ldquoRoot cause unknown
Compendial standards and manufacturing
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Practice Control Process Maturity
Initial
bull Unpredictable
Managed
bull Characterized but reactive
Defined
bull Characterized proactive
Measured amp Controlled
bull In control
Optimizing
bull Focus on improvement
3122015 Ajaz S Hussain PhD 34
Capability Maturity Model Integration Carnegie Mellon University
A validated process
Maturity Level amp Assurance of Quality
Managed Characterized but reactive
High perceived risk of
lsquoCheating by Designrsquo
ldquoTrial Injectionsrdquo
ldquoTesting in to Compliancerdquo
Defined Characterized proactive
Lower level of assurance
Stopping amp Correcting
Batch Rejection
Measured amp
ControlledIn control
Quality by Design
Quality Assured
Improvement Opportunities
3122015 Ajaz S Hussain PhD 35
At the individual level in QC functionndash how often does this occur
attitude toward
performing the behavior
Process validation is
done so quality is good
test prone to error
ldquoBatch failure means I made
a mistakerdquo
subjective norm
documentation not critical
Compendial testing
sufficient
Indian regulators
collect amp test samples ndash no issue there
3122015 Ajaz S Hussain PhD 36
ldquoTesting into compliancerdquo
In general ndash low empowerment is a significant challenge (low perceived behavioral control) plus reasons to rationalizehellip
Excipient Functionality Can be critical for safety efficacy and quality
3122015 Ajaz S Hussain PhD 37
July 15 2005 FDA Public Health Advisory Safety Warnings Regarding Use of Fentanyl Transdermal (Skin) Patches
A pattern of failure Pharmaceutical Equivalence by Design (2004)
3122015 Ajaz S Hussain PhD 38
httpwwwnihsgojpdrugPhForumdocuments041122Hussain041122pdf
An attempt to correct
3122015 Ajaz S Hussain PhD 39
httpipecamericasorgsystemfilesKeyNoteEF13May11LawrenceYu(FDA)pdf
Recent challenges
3122015 Ajaz S Hussain PhD 40
Th
e V
oic
e o
f th
eA
mer
ican
P
sych
iatr
ic A
sso
ciat
ion
and
th
e P
sych
iatr
ic C
om
mu
nit
y
Physicians Question FDAs Confidence in Generic Drugs Safety Efficacy (OCTOBER 24 2014)
bull ldquomost patientsrdquo is not the same asldquo all patientsrdquo and whether the 24 to 36 normal subjects used in the agencys bioequivalency tests represents the full range of individual variation in the way drugs are absorbed across the pharmaceutical using population is uncertain
bull Individuals can sometimes be allergic and react differently to whatever substance goes into making up the capsule or the tablet
FDA Flags Generic Versions of ADHD Medication(NOVEMBER 14 2014)
bull FDA changed the therapeutic equivalence (TE) rating from AB to BXmdashmeaning that the products are still approved and can be prescribed but are no longer recommended as automatic substitutes
RLD Variability Can be a block-buster opportunityFocus on lsquocontrol strategyrsquo
bull Overcoming CP amp IP provide FDA a submission they need to address CP
bull Then begin with QTPP CQArsquos hellip skip lsquodesign spacersquo and focus on lsquocontrol strategy
bull The entire development team should read the complete package insert of RLD
bull Discuss to ensure a common understandingbull Failure modes amp intended use
bull Pharmaceutical Equivalence
bull Bioequivalence
bull Other studies
QbD Challenges
3122015 Ajaz S Hussain PhD 41
NewRegulators are not prepared to handle QbD applications
NewMisalignment of international regulatory authorities
New and Generics
RampD incentivized for lsquoshots on the goalrsquo not QbD
GenericsLack of belief in business case ndash lsquoGenerics are all about file first figure out laterrsquo
Biologics Lack of technology to execute
Ted Fuhr Mackinsey amp Company June 2010 FDA Advisory Committee
Summary
bull Excipient functionality can contribute in critical ways to product quality amp performance adequate control is necessary
bull Our databases tools and knowledge are lagging behind the rapidly increasing complexity and uncertainty
bull Risk to quality and to business is increasing and regulatory transitions pose additional difficulties
bull Effective knowledge management ndash IT and Human practices ndash is critical for organizational lsquobottom-linersquo
bull We all must come together collaboratively to address the urgent needs we owe it to the patients we serve
3122015 Ajaz S Hussain PhD 42
Knowledge Management amp Culture of Quality
Ajaz S Hussain PhD
Insight Advice amp Solutions LLCMaryland USA
Executive Director the National Institute for Pharmaceutical Technology amp Education
3122015 Ajaz S Hussain PhD 43
3122015 Ajaz S Hussain PhD 44
Life-cycle approach needed for knowledge management
Investigational ProductscGMPs
DevelopmentTechnology
TransferCommercial
ManufacturingDiscontinuation
Management Responsibility
Process Performance amp Product Quality Monitoring SystemCAPA Change Management Management Review
PQS Elements
Knowledge ManagementQuality Risk ManagementEnablers
ICH Q10 KM is a systematic approach to acquiring analyzing storing and disseminating information related to products manufacturing processes and components
Based on ICH Q10
ldquowe can be blind to the obvious and we are also blind to our blindnessrdquo
Daniel Kahneman Thinking Fast and Slow
3142015 Ajazajazhussaincom 45
httpwebmiteduperscipeopleadelsoncheckershadow_proofhtml
3122015 Ajaz S Hussain PhD 46
1938 The Federal Food Drug and Cosmetic (FDC)
bull 1937 Elixir of Sulfanilamide
1962 Kefauver-Harris Drug Amendments
bull 1962 Thalidomide
bull 1960 Color Additive Amendment
bull 1958 Food Additives Amendment GRAS
bull 1960 Color Additive Amendment
bull 1958 Food Additives Amendment GRAS
1992 Generic Drug Enforcement Act
bull1989 L-Tryptophan
bull 1989 Generic Drug Scandal
bull 1988 Food and Drug Administration Act
bull 1984 Fines Enhancement Laws Drug Price Competition and Patent Term Restoration Act
2012 Food and Drug Administration Safety and Innovation Act (FDASIA)
bull 2007 Heparin Disaster
2013 Pandemic and All-Hazards Preparedness Reauthorization Act (PAHPRA) Drug Quality and Security Act
bull 2012 The Deadly Meningitis Outbreak
Past 70 years 1937 ndash 2007 The diethylene glycol (DEG) narrative
3122015 Ajaz S Hussain PhD 47
0
5
10
15
20
25
30
35
Yea
rs
DEG Years since the previous incident
0
50
100
150
200
250
300
350
Number of Reported Deaths
1937
Eli
xir
of
Sulf
anil
amid
e
2007T
ootp
aste
conta
min
atio
n
0 70 years 0 70 years
Frequent reports
Mumbai Mumbai
Data from Excipient Fest Janeen Skutnik Chair ndashIPECAmericas 2009
Past 70+ years DEG contamination or economically motivated adulteration
3122015 Ajaz S Hussain PhD 48
Reported cases underestimate the real tragedy rapid intervention may not occur
Epidemic of Pediatric Deaths From Acute Renal Failure Caused by
Diethylene Glycol Poisoning JAMA 1998279(15)1175-1180
doi101001jama279151175
Month of hospital admission for children with
acute renal failure Haiti
October 1995-October 1996
Diethylene glycol poisoning in Gurgaon India 1998Bulletin of the World Health Organization 2001 79 88ndash95
We report a second episode of poisoning occurring in 1998 in
India as a result of children ingesting diethylene glycol at
least 33 children are known to have died
At the beginning of the investigation we never imagined that
contaminated medicine was causing acute renal failure in
children
A brand of cough expectorant manufactured by a local
pharmaceutical company was found by the Central Drugs
Laboratory Calcutta to contain 175 (vv) diethylene
glycol
The district and state drug controller had tested many
samples using thin layer chromatography before a sample of
medicine tested positive for diethylene glycol at the Central
Drugs Laboratory None of the earlier samples was found to
be contaminated
3122015 Ajaz S Hussain PhD 49
Guidance for Industry Testing of
Glycerin for Diethylene Glycol
CDER May 2007 Compliance
1 Manufacturers did not perform full
identity testing on the glycerin raw
material including tests to quantify
the amount of DEG
2 Relied on the certificate of analysis
(COA)
3 The origin of the glycerin was not
easily apparent from the COA
4 The COA was often a copy of a COA
on the letterhead of the distributor
5 The chain of custody or distribution
history of the glycerin was also not
readily known
USP Glycerin Monograph
Type of Posting Revision Bulletin
Posting Date 04ndashFebndash2009
Official Date 01ndashMayndash2009
Because of the serious hazards
associated withhellip and in response to
recommendations set forth in the
FDA Guidance for Industry Testing
of Glycerin for Diethylene Glycol
published in May 2007 USP has
revised the USP Glycerin monograph
Because diethylene glycol and
ethylene glycol are considered
unacceptable toxic substances the
testing of USP Glycerin should
demonstrate the absence of these
substances
April 2007 FDA request to
USP to revise the Glycerin
monographrsquos
IDENTIFICATION section
Revision includes adding ndash
Identification test B LIMIT OF
DIETHYLENE GLYCOL AND
ETHYLENE GLYCOL to detect
and quantify DEGEG in Glycerin
minus Is no longer part of the impurity
testing
ldquoLimit of DEG and Related
Compoundsrdquo minus Introduces a
capillary gas-chromatographic
(GC) method with flame ionization
detection (FID) minus Limit of NMT
010 each for diethylene glycol
and ethylene glycol is found
70+ years to get here how difficult will it be to change habits such as lsquoblind reliance of COArsquo
3122015 Ajaz S Hussain PhD 50
Personality and Habitual Frame Biases
Myers Brigs ENTJ (first tested at FDA)
S
TF
Expanded frame
future
possibilities
objective lsquocause
and effectrsquo
Expanded frame
future
possibilities
people and
relationships
Narrow frame
the present
individuals and
relationships
Narrow frame
the present
objective
cause and
effect
N
Based on Stanford Webinar - How to Overcome the Top 3 MegaBiases in Decision-Making
Stanford Universityrsquos Strategic Decision and Risk Management certificate program
From Mapping a Managers Brain on Incentives
Social
influences
Relative
thinking
UncertaintyComplexity
By Design Intention to act consciously
bull In the interest of patients and to continually improve this ability bull To provide a healing touch ndash one life at a time in what we do and how we
do it
1292014 Ajazajazhussaincom 51
Consciously
Scientific methodology
Engineering Design
Plan-Do-Check-Act
Subconsciously
Habits (work to get rid of bad ones)
Habits (work to cultivate good one)
Keystone habits (Safety Alcoa ALCOA of data integrity)
The Power of Habit Why We Do What We Do in Life and Business Charles Duhigg (2012)
httpwwwslideshareneta2zpharmscipharmaceutical-culture-of-quality
What does it take to come out of the cGMP crisis
Persuasive demonstration of
(1) Ability to face facts
(2) Legal amp regulatory requirements
3) Systems approach to quality
4) Changing behavior amp culture
What is often missed or is unconvincing is how you will strengthen culture of quality
ldquoLet one who wants to move and convince others first be convinced and moved themselvesrdquo Thomas Carlyle
Signals that question the competence motivation andor integrity of company personnel
Do not defend the plainly indefensible it adds further serious credibility costs
3142015 Ajazajazhussaincom 52
Quality is everyones responsibility
Lack of knowledge that is
the problem
If you do not know how to ask the
right question you discover nothing
If you cant describe what you
are doing as a process you dont know what youre
doing
Rational behavior requires theory
Reactive behavior requires only reflex
action
Whenever there is fear you will get wrong figures
3142015 Ajazajazhussaincom 53
Selected quotes W Edwards Deming
3142015 Ajazajazhussaincom 54
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
ldquoWE CANNOT CHANGE THE HUMAN CONDITION BUThellipWE CAN CHANGE THE CONDITIONS UNDER WHICH HUMANS WORKrdquo JAMES REASON
Disregard to Malice
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 55
ldquohelliprecords not completed
contemporaneouslyrdquo
ldquohellipobserved analyst back-date logbooksrdquo
ldquohelliptrial injectionshelliprdquo
ldquohellipresults failing specifications are
retested until acceptable results are obtainedhelliprdquo
ldquohellipover-writing electronic raw datahelliprdquo
ldquohellipOOS not investigates per XYZ SOPrdquo
ldquohellipappropriate controls not establishedhelliprdquo
Each additional observation adds
reasons to confirm that this is very likely a system
with intentional lsquoholesrsquo in its
defenses
Preconditions
Rationalization amp Attitude
Pressure amp Incentive
Opportunity ndashlsquoholes in the QMSrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 56
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 57
Attitude towards the behavior
Subjective norm
Perceived behavioral
control
IntentionFuture
Behavior
usually found to predict behavioral intentions with a high degree of accuracy
intentions in combination with perceived behavioral control can account for a considerable proportion of variance in behavior
PastBehavior
Ajen I The theory of planned behavior ORGANIZATIONAL BEHAVIOR AND HUMAN DECISION PROCESSES 50 179-211 (1991)
Heparin tragedy 2007 and 2008
FDA reports 149 deaths with allergic or hypersensitivity symptoms during that period
bull Contaminated heparin from China
QC Testing
bull Initial testing failed to detect the contaminant
Pharmacovigilence
bull Signals in the pharmacovigilence systems responded slowly and
Eventually the severity of reactions associated made it likely that the contamination would be detected
bull too late for those who died or were injured
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 58
Congressman Shimkus When the drug safety system fails people get sick Some die
bull Some of these people are already very vulnerable and proving the cause of harm from impurities adulteration and counterfeits can be elusive
It is hard to detect harm
bull Certainly the companies are obligated to ensure a culture of quality and maintain vigilance as well This reflects a systems approach to safety
FDA inspectors look for a culture of quality at
manufacturing facilities
bull FDA policies led to the failure to inspect the Chinese plantThis system approach wasnt at
play here
bull While it doesnt deny the counterfeit source tries to say that counterfeits didnt cause the reaction as if the adulteration itself was no big deal Is this an acceptable mindset helliphelliphellip
This brings me to China and its quality culture or lack thereof
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 59
ONE HUNDRED TENTH CONGRESS SECOND SESSION APRIL 29 2008 Serial No 110-109
21 CFR PART 211 SUBPARTS -Deviations signal gaps in CoQ
bullGENERAL PROVISIONSA
bullORGANIZATION AND PERSONNELB
bullBUILDINGS AND FACILITIESC
bullEQUIPMENTD
bullCONTROL OF COMPONENTS AND DRUG PRODUCT CONTAINERS AND CLOSURESE
bullPRODUCTION AND PROCESS CONTROLSF
bullPACKAGING AND LABELING CONTROLG
bullHOLDING AND DISTRIBUTIONH
bullLABORATORY CONTROLSI
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 60
For example the combinationhellip
The Power of Habit Why We Do What We Do in Life and Business Charles Duhigg (2012)
bull Scientific methodology
bull Engineering Design
bull Plan-Do-Check-ActConsciously
bull Habits (work to get rid of bad ones)
bull Habits (work to cultivate good one)
bull Keystone habits (Safety Alcoa ALCOA of data integrity)
Subconsciously
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 61
CoQ How
bull What are the predictors of CoQCoQ Manifests by Design -
lsquoquality by designrsquo the foundation
bull 1 2 3When do people change their behaviors
bull A B C D (any body can dance)What makes a QMS effective
bull X Y ZWhen proactive compliance occurs
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 62
Going beyond rules pays
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 63
Human behavior Connecting the Dots With the Right Connectors
GXPs ndash rational behaviors
How proactive compliance is achieved X Y Z
Quality Management System
What makes a QMS reliable A B C D
Culture of Quality
Why people change their behavior 1 2 3
Human Behaviors Beyond GXPs
Predictors of Culture of Quality
Why What and How of Culture of Quality
9192014 copy Ajaz S Hussain | INSIGHT ADVICE amp SOLUTIONS LLC 64
Predictors of CoQ Act consciously in the interest of patients ndash when no one is looking
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 65
Only four attributes
actually predict a culture of
quality
Leadership Emphasis
Message Credibility
Peer Involvement
Employee Empower-ment
People will change their
behavior if they see the new behavior as
Normal
(1)
Rewarding
(2)
Easy
(3)
Dr W Edwards Demingrsquos - ldquoOut of the crisisrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 66
The journey requires leadership
with Profound Knowledge as a
guide
bull As leaders responsible for system change top management is most in need of profound knowledge
bull Quality is often determined in the boardroom
bull Problems arise when management reacts to common cause or chance variation as if it were special cause variation
bull Prediction based in theory provides a foundation for planning a course of action Plan ndash Do ndash Check ndash Act
bull The leader serves the people with clear vision and guidance to empower them To be empowered is to share ownership in the identity
bull Giving people a certain degree of control over their work fulfills the need for freedom and provides opportunity for taking joy in work
Profound Knowledge as a guide
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 67
Appreciation for a System
Theory of Knowledge
Knowledge about
Variation
Human Behavior -Psychology of Change
A
B
C
D+
Systems Approach for ErrorDeviation Management
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 68
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
Human error models and management J Reason BMJ 320 768ndash770 (2000)
D+
Culture of Error Management परबधनbull Error strain
bull Covering upFear of Errors
bull Anticipation
bull Risk takingAwareness
bull Development QbDRFT
bull Error detection Communication
bull Analyzing errors Correction
Mastery orientation
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 69
Dots amp Connections
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 70
CoQ
1
2
3
QMS
A
B
C
D
GXP Behaviors
X
Y
Z
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 71
Culture of Quality
Normal
Rewarding
Easy
QMS
System
Knowledge
Variation
Behavior
Behavior -GXPs
Fear Removed
Mastery
Awareness
EnvironmentLeadership Emphasis
Message Credibility
Peer Involvement
Employee Empowerment
Connect to CoQ
Connect to GXPs
A Framework and a Tool (for gap analysis)
Acknowledgment
bull Thanks to Arihant Innochem Pvt Ltd for inviting me to speak and also for accepting my requests to (a) expand the program and include other speakers and (b) inviting faculty members from local schools of pharmacy
bull For me this is an opportunity to share my insights on excipients and more importantly learn something about excipient supplier ndash Pharma interactions in India
bull Arihant Innochem Pvt Ltd made the travel arrangements for my trip to Mumbai We have no other business or financial relationship They did not request to see nor did I provide an advance copy of my slides
3122015 Ajaz S Hussain PhD 2
Insights
bull Why attention to excipient knowledge management (specifically their functionality) is critical to mitigating risks (or to leverage opportunities) posed by the rapidly increasing complexity and uncertaintybull Note Knowledge management in
the context of lsquointellectual propertyrsquo is not the focus of this talk
bull In the second talk end of the day I plan to discuss how certain management practices can impact effectiveness of knowledge managementbull Note Knowledge management is
a combination of both IT and human aspects I intend to focus on lsquohuman factorsrsquo
3122015 Ajaz S Hussain PhD 3
Outline
bull Declaring my interests acknowledging experiences contributing to my current thinking
bull Current hot topics ndash lsquoexcipientsrsquo regulatory trends amp insights
bull Why attention to (excipient) knowledge management (specifically physical functionalityperformance) is critical
3122015 Ajaz S Hussain PhD 4
My interest in [lsquoexcipientsrsquo] KMacknowledging experiences contributing to my current thinking
bull Business decisions
bull Regulatory research policy amp enforcement
bull Academic research
3122015 Ajaz S Hussain PhD 5
Business decisions
bull Management responsibilitiesbull VP amp Global Head Biopharmaceutical Development Sandoz (2005-2009)
bull Developmentregulatory submission Omnitropereg Binocritreg Zarzioreg Generic Enoxaparin amp Glatiramer acetate
bull VP Next Generation Product Assessment amp CSO Philip Morris International (2009 -2012)
bull Developmentevidence qualityregulatory strategy Plant based vaccines amp assessment of products intended for tobacco harm reduction
bull President Biotechnology amp CSO Wockhardt (2012-2013)
bull Biosimilar and Complex Generic Strategy Improvement
bull AdvisoryConsulting (2013 ndash currently)
bull Mitigating risks in development of complex products Framework for effective compliance amp remediation Strengthening Culture of Quality
3122015 Ajaz S Hussain PhD 6
Regulatory research policy amp enforcement support US FDA (1995 ndash 2005)
bull Research to Policybull SUPAC BCS IVIVC hellipTopical Microbicideshellipseveral others
bull Policybull SUPAC-MR IVIVC BCS helliphellip PAT ICH FDA Lead (Quality) ndash
ldquodesired state for 21st Centuryrdquo ICH Q8 ndash 10
bull Enforcement Supportbull Expert witness for the prosecution (1995)
bull Facilitating resolution of difficult WLs linked to shortages
3122015 Ajaz S Hussain PhD 7
Knowledge to inform policy improvement
3122015 Ajaz S Hussain PhD 8
Physical Attributes Can be critical for safety efficacy and quality
3122015 Ajaz S Hussain PhD 9
July 15 2005 FDA Public Health Advisory Safety Warnings Regarding Use of Fentanyl Transdermal (Skin) Patches
Also relevant today Pattern Recognition
3122015 Ajaz S Hussain PhD 10
Preliminary illustration of a concept Going forward expect to see regulators utilize state-of ndashthe ndashart pattern recognition and modeling systems
Effective Regulatory System Importance of Process Understanding and Quality by DesignAjaz Hussain Pharmaceutical Quality Forum 3rd Symposium November 2004 Tokyo Japan
Academic research
University of Cincinnati (1989-1994)
bull Formulation designbull Several projects ndash oral topical and
transdermalbull Example Elaborating the utility of
Transcutolreg (Gattefosseacute)
bull Computer aided formulation designbull Artificial Neural Network based
lsquoexpert systemsrsquobull Example Prototype for lsquoTechnical
Service Supportrsquo (funding - Aqualon)
NIPTE (Currently)
bull NIPTErsquos Excipient Knowledge basebull Available since 2007 at
httppharmahuborg
bull The goal of this project is to share information and modeling tools to support pharmaceutical product
3122015 Ajaz S Hussain PhD 11
Prototype for lsquoTechnical Service Supportrsquo
3122015 Ajaz S Hussain PhD 12
From a lsquoDatabasersquo to a lsquoKnowledge basersquo
bull lsquoLook-up tablesrsquo to lsquoAbility to Predictrsquo
bull Ability to predict = generate hypotheses
bull Ability (simulate) ask questions - what if
NIPTE Knowledge Management
3122015 Ajaz S Hussain PhD 13
Contact Prof Hoag Univ Maryland shoagrxumarylandedu
3122015 Ajaz S Hussain PhD 14
NIPTE Knowledge Management
This study was funded by the FDA-sponsored contract ldquoDevelopment of Quality by Design (QbD) Guidance Elements on Design Specifications across Scales with Stability Considerationsrdquo (contract number HHSF223200819929C)
3122015 Ajaz S Hussain PhD 15
Current hot topics ndashrsquoexcipientsrsquo regulatory trends amp insights ExcipientFest on 28-29 April 2015 in Washington Organizational Changes CDERFDA and Inspectional Trendshellip(Complex Genericshellip Continuous Manufacturing)
3122015 Ajaz S Hussain PhD 16
Current experience with lsquoSupplier Qualificationrsquo
bull Recent observations are summarized in this report by ECA Academy (21012015) Areas of attention
bull Accuracy and completeness of administrative documentation
bull Evidence to justify excipient and supplier qualification
bull Risk-assessment and effective integration within in QMS
bull Quality agreements
bull Going forward I envision a need to emphasize a life-cycle approach (eg linking to CAPA change control)
3122015 Ajaz S Hussain PhD 17
FDArsquos Inactive Ingredient Database -statusbull Substance Registration System (SRS)
bull Generic listing vs Specific Grade listing for commonly used excipients ndashmax precedent levels
bull Listing of Mixtures
bull The UNII code confusing the National Library of Medicine yet to finalize standards for assigning UNII codes for polymers
bull Individual Grades vs Family Data
bull Legal status of the IID and FDA communications of changes to the IID
bull DMF Implications
bull Impact on ANDAs ndash lsquoDelaysrsquo amp lsquoRefuse to File Lettersrsquo
3122015 Ajaz S Hussain PhD 18
3122015 Ajaz S Hussain PhD 19
Inactive Ingredientsrsquo to lsquoExcipientsrsquo to lsquoFunctionalityrsquo Where are we in this journeylsquo
Status of lsquoSubstances In Regulatory Practicersquo
Clearly we need a global database with improved precision and accuracy of naming (and coding) to identify describe compare and link (to products and AERs)
INDs NDAs BLAs CFRrsquos Orphan Drug ApplicationsProducts that Contain Each Substance
Pharmacological ClassificationActive Moieties Related Moieties and Salts
LADMERMetabolites
Metabolic Enzymes Transporters and EffectsDrug target (therapeutic and other) type of interaction
Solubility and Permeability (BCS)Protein Binding
Impurities and Related Substance
ISO 11238 (ISO IDMP) some challenges
Both substances amp specified substances
Implementation in EU EMA Task force
Global Ingredients Archive System (GInAS)
3122015 Ajaz S Hussain PhD 20
The War Against Fake Medicines Update on FDASIA - Guidance and Impact on Excipient Suppliers and
Users QbD Sampling Guidelines The NSFIPECANSI 363 2014 GMP standardsexplained Good Supply Practices ndash Using Cross Industry Knowledge to Devise Pragmatic Solutions Impact
of Non-harmonized Standards and What is Needed to Achieve Harmonization Advancements in the Question Based Review approach and various other excipient specific related topics An Overview of the FDA OGD
IID EWG activities Effective Sourcing and Purchasing of Excipients
Industry Collaboration for Science Based Implementation of Elemental Impurities Challenges And Opportunities In Developing
And Modernizing Public Standards For NF Excipients Monographs For Regulated Drug
Products Marketed In The USA Future Pharma Manufacturing Efficiencies and the Role of Innovative Excipient Technologies
IPEC ExcipientFest 2015
Current Hot Topics ExcipientFest on 28-29 April 2015 in Washington
3122015 Ajaz S Hussain PhD 21
The War Against Fake Medicines Update on FDASIA - Guidance and Impact on Excipient
Suppliers and Users QbD Sampling Guidelines The NSFIPECANSI 363 2014 GMP standards explained Good Supply Practices ndash Using Cross Industry Knowledge to Devise
Pragmatic Solutions Impact of Non-harmonized Standards and What is Needed to Achieve
Harmonization Advancements in the Question Based Review approach and various other
excipient specific related topics An Overview of the FDA OGD IID EWG activities Effective
Sourcing and Purchasing of Excipients Industry Collaboration for Science Based Implementation of Elemental Impurities Challenges And
Opportunities In Developing And Modernizing Public Standards For NF ExcipientsMonographs For Regulated Drug Products Marketed In The USA Future Pharma Manufacturing Efficiencies and the Role of Innovative Excipient Technologies
IPEC ExcipientFest 2015
Inspectional trends in data integrity (Bangalore Nov
2014)
22(d)
192
100(a)
160(b)
110(a)
67(b)
68(a)
25(a)
67(a)
100(b)
Recurring 483 Observations Top 10
22(d) 192 100(a) 160(b)110(a) 67(b) 68(a) 25(a)67(a) 100(b)
Jeff Medwid NIPTE-FDA Conference 13 June 2012
International Society for Pharmaceutical Engineering (ISPE) in conjunction with McKinsey amp Co will release preliminary data and findings from its Quality Metrics Pilot Program at the ISPE Quality Metrics Summit on April 21ndash22 in Baltimore
FDA Launches New Drug Quality Office With Goal of Improving the Pharmaceutical IndustryPosted 13 January 2015By Alexander Gaffney RAC
FDArsquos New Pharma Quality
Office Will Take a Team Approach
Yu Explains
Regulatory Recon Investigations Find Major Quality Problems at Indian Pharma Companies (3 December 2014)Posted 03 December 2014By Alexander Gaffney RAC
Currently the environment is complex there is high uncertainty D
on
rsquot f
org
et
fun
ctio
na
lity
o
f e
xcip
ien
ts i
s im
po
rta
nt
3122015 Ajaz S Hussain PhD 22
Need for urgent progress lsquoInactive Ingredientsrsquo to lsquoExcipientsrsquo to lsquoFunctional Excipientsrsquo
Importance of assuring quality and controlling
variability of excipients
including their lsquofunctionalityrsquo has
long been recognized
bull Increasing complexity of drugs their delivery and failure modes
bull Patient (eg pediatric) relevant failure modes
bull Simple generics to complex generics amp biosimilars
Urgent need to address gaps in the FDArsquos Inactive Ingredient Database
3122015 Ajaz S Hussain PhD 23
Trends Lab amp Manufacturing
ldquoDeletion of Datardquo
ldquoTesting Into Compliancerdquo
ldquoBMR manipulation is a slippery sloperdquo
ldquoSuggestive of faulty manufacturing process or practices even if this is not the caserdquo
ldquoIt is top managementrsquos responsibility to ensure the training program is robust and effectiverdquo
Inspectional trends in data integrity (Bangalore Nov 13 2014 - Nov 14 2014)
Growing concern some
companies ldquodata looks too good
to be truerdquo
3122015 Ajaz S Hussain PhD 24
GMP Compliance amp Remediation
Jeff Medwid NIPTE-FDA Conference 13 June 2012
QbD amp QbR Clarity on Critical Functionality
FDArsquos New Pharma Quality
Office Will Take a Team
Approach Yu Explains
Carmelo Rosa MS PsyD November 2014
Urgent Need amp Opportunity
To align amp ensure sound scientific basis of these critical regulatory decisions
FDA CDER OPQ Plans for Surveillance of Pharmaceutical Quality
Teresa Mullin PhD December 2014
3122015 Ajaz S Hussain PhD 25
Need for a comprehensive (excipient) knowledge base
Teresa Mullin PhD December 2014
3122015 Ajaz S Hussain PhD 26
Why attention to (excipient) knowledge management is criticalSpecifically for physical attributes functionality performance
3122015 Ajaz S Hussain PhD 27
3122015 Ajaz S Hussain PhD 28
Today there are several product categories (eg controlled release inhalation products DPIrsquos topical transdermal liposomal products etc) which requires an exquisite control of complex physical material and product attributes (functionality)
Many of our current measurement systems need improvement
We depend on these to ensure control of lot-lot variability
Measurement system capability must be confirmed to be able to assess process capability (calibration amp Gauge RampR)
Life-cycle approach to quality continued process verification (FDArsquos Process Validation 2011) is a safety net
Supplier amp Excipient Qualification amp Process Validation
Measurement System Analysis
bull From lsquocalibrationrsquo to lsquoGauge RampRrsquoParticularly for physical
attributes destructive analysis
bull Many (including regulators) have not yet understood its importance
Gauge RampR well established but not commonly practiced
bull Measurement system in a state of control effective CAPA quality metrics Culture of Quality
With the move towards Statistical Process Control
bull Demonstrate equivalent in vitro performance more exacting criteria
Development of complex generic products (ER
Injectable Inhalation etc)
3122015 Ajaz S Hussain PhD 29
Process Validation (2011) Statistical Confidence Continued Process Verificationhellip
3122015 Ajaz S Hussain PhD 30
httpwwwslideshareneta2zpharmsciperformance-testing-pharmaceutical-quality-2004(accessed 6 December 2014)
3122015 Ajaz S Hussain PhD 31
Supplier amp Excipient Qualification amp CAPA
Out of Specification events are difficult to resolve
Excipient functionality can be a significant contributing factor
Sometimes reluctantly have to settle with - ldquoRoot cause unknown
600 days
I have inserted the ldquo600 daysrsquo on the figure ndash this is based on cases I have seen while at FDA)
3122015 Ajaz S Hussain PhD 32
Prevention of OOS and Effective CAPA needs a focus on critical functional attributes
Out of Specification events are difficult to resolve
Excipient functionality can be a significant contributing factor
Sometimes reluctantly have to settle with - ldquoRoot cause unknown
Compendial standards and manufacturing
3122015 Ajaz S Hussain PhD 33
Practice Control Process Maturity
Initial
bull Unpredictable
Managed
bull Characterized but reactive
Defined
bull Characterized proactive
Measured amp Controlled
bull In control
Optimizing
bull Focus on improvement
3122015 Ajaz S Hussain PhD 34
Capability Maturity Model Integration Carnegie Mellon University
A validated process
Maturity Level amp Assurance of Quality
Managed Characterized but reactive
High perceived risk of
lsquoCheating by Designrsquo
ldquoTrial Injectionsrdquo
ldquoTesting in to Compliancerdquo
Defined Characterized proactive
Lower level of assurance
Stopping amp Correcting
Batch Rejection
Measured amp
ControlledIn control
Quality by Design
Quality Assured
Improvement Opportunities
3122015 Ajaz S Hussain PhD 35
At the individual level in QC functionndash how often does this occur
attitude toward
performing the behavior
Process validation is
done so quality is good
test prone to error
ldquoBatch failure means I made
a mistakerdquo
subjective norm
documentation not critical
Compendial testing
sufficient
Indian regulators
collect amp test samples ndash no issue there
3122015 Ajaz S Hussain PhD 36
ldquoTesting into compliancerdquo
In general ndash low empowerment is a significant challenge (low perceived behavioral control) plus reasons to rationalizehellip
Excipient Functionality Can be critical for safety efficacy and quality
3122015 Ajaz S Hussain PhD 37
July 15 2005 FDA Public Health Advisory Safety Warnings Regarding Use of Fentanyl Transdermal (Skin) Patches
A pattern of failure Pharmaceutical Equivalence by Design (2004)
3122015 Ajaz S Hussain PhD 38
httpwwwnihsgojpdrugPhForumdocuments041122Hussain041122pdf
An attempt to correct
3122015 Ajaz S Hussain PhD 39
httpipecamericasorgsystemfilesKeyNoteEF13May11LawrenceYu(FDA)pdf
Recent challenges
3122015 Ajaz S Hussain PhD 40
Th
e V
oic
e o
f th
eA
mer
ican
P
sych
iatr
ic A
sso
ciat
ion
and
th
e P
sych
iatr
ic C
om
mu
nit
y
Physicians Question FDAs Confidence in Generic Drugs Safety Efficacy (OCTOBER 24 2014)
bull ldquomost patientsrdquo is not the same asldquo all patientsrdquo and whether the 24 to 36 normal subjects used in the agencys bioequivalency tests represents the full range of individual variation in the way drugs are absorbed across the pharmaceutical using population is uncertain
bull Individuals can sometimes be allergic and react differently to whatever substance goes into making up the capsule or the tablet
FDA Flags Generic Versions of ADHD Medication(NOVEMBER 14 2014)
bull FDA changed the therapeutic equivalence (TE) rating from AB to BXmdashmeaning that the products are still approved and can be prescribed but are no longer recommended as automatic substitutes
RLD Variability Can be a block-buster opportunityFocus on lsquocontrol strategyrsquo
bull Overcoming CP amp IP provide FDA a submission they need to address CP
bull Then begin with QTPP CQArsquos hellip skip lsquodesign spacersquo and focus on lsquocontrol strategy
bull The entire development team should read the complete package insert of RLD
bull Discuss to ensure a common understandingbull Failure modes amp intended use
bull Pharmaceutical Equivalence
bull Bioequivalence
bull Other studies
QbD Challenges
3122015 Ajaz S Hussain PhD 41
NewRegulators are not prepared to handle QbD applications
NewMisalignment of international regulatory authorities
New and Generics
RampD incentivized for lsquoshots on the goalrsquo not QbD
GenericsLack of belief in business case ndash lsquoGenerics are all about file first figure out laterrsquo
Biologics Lack of technology to execute
Ted Fuhr Mackinsey amp Company June 2010 FDA Advisory Committee
Summary
bull Excipient functionality can contribute in critical ways to product quality amp performance adequate control is necessary
bull Our databases tools and knowledge are lagging behind the rapidly increasing complexity and uncertainty
bull Risk to quality and to business is increasing and regulatory transitions pose additional difficulties
bull Effective knowledge management ndash IT and Human practices ndash is critical for organizational lsquobottom-linersquo
bull We all must come together collaboratively to address the urgent needs we owe it to the patients we serve
3122015 Ajaz S Hussain PhD 42
Knowledge Management amp Culture of Quality
Ajaz S Hussain PhD
Insight Advice amp Solutions LLCMaryland USA
Executive Director the National Institute for Pharmaceutical Technology amp Education
3122015 Ajaz S Hussain PhD 43
3122015 Ajaz S Hussain PhD 44
Life-cycle approach needed for knowledge management
Investigational ProductscGMPs
DevelopmentTechnology
TransferCommercial
ManufacturingDiscontinuation
Management Responsibility
Process Performance amp Product Quality Monitoring SystemCAPA Change Management Management Review
PQS Elements
Knowledge ManagementQuality Risk ManagementEnablers
ICH Q10 KM is a systematic approach to acquiring analyzing storing and disseminating information related to products manufacturing processes and components
Based on ICH Q10
ldquowe can be blind to the obvious and we are also blind to our blindnessrdquo
Daniel Kahneman Thinking Fast and Slow
3142015 Ajazajazhussaincom 45
httpwebmiteduperscipeopleadelsoncheckershadow_proofhtml
3122015 Ajaz S Hussain PhD 46
1938 The Federal Food Drug and Cosmetic (FDC)
bull 1937 Elixir of Sulfanilamide
1962 Kefauver-Harris Drug Amendments
bull 1962 Thalidomide
bull 1960 Color Additive Amendment
bull 1958 Food Additives Amendment GRAS
bull 1960 Color Additive Amendment
bull 1958 Food Additives Amendment GRAS
1992 Generic Drug Enforcement Act
bull1989 L-Tryptophan
bull 1989 Generic Drug Scandal
bull 1988 Food and Drug Administration Act
bull 1984 Fines Enhancement Laws Drug Price Competition and Patent Term Restoration Act
2012 Food and Drug Administration Safety and Innovation Act (FDASIA)
bull 2007 Heparin Disaster
2013 Pandemic and All-Hazards Preparedness Reauthorization Act (PAHPRA) Drug Quality and Security Act
bull 2012 The Deadly Meningitis Outbreak
Past 70 years 1937 ndash 2007 The diethylene glycol (DEG) narrative
3122015 Ajaz S Hussain PhD 47
0
5
10
15
20
25
30
35
Yea
rs
DEG Years since the previous incident
0
50
100
150
200
250
300
350
Number of Reported Deaths
1937
Eli
xir
of
Sulf
anil
amid
e
2007T
ootp
aste
conta
min
atio
n
0 70 years 0 70 years
Frequent reports
Mumbai Mumbai
Data from Excipient Fest Janeen Skutnik Chair ndashIPECAmericas 2009
Past 70+ years DEG contamination or economically motivated adulteration
3122015 Ajaz S Hussain PhD 48
Reported cases underestimate the real tragedy rapid intervention may not occur
Epidemic of Pediatric Deaths From Acute Renal Failure Caused by
Diethylene Glycol Poisoning JAMA 1998279(15)1175-1180
doi101001jama279151175
Month of hospital admission for children with
acute renal failure Haiti
October 1995-October 1996
Diethylene glycol poisoning in Gurgaon India 1998Bulletin of the World Health Organization 2001 79 88ndash95
We report a second episode of poisoning occurring in 1998 in
India as a result of children ingesting diethylene glycol at
least 33 children are known to have died
At the beginning of the investigation we never imagined that
contaminated medicine was causing acute renal failure in
children
A brand of cough expectorant manufactured by a local
pharmaceutical company was found by the Central Drugs
Laboratory Calcutta to contain 175 (vv) diethylene
glycol
The district and state drug controller had tested many
samples using thin layer chromatography before a sample of
medicine tested positive for diethylene glycol at the Central
Drugs Laboratory None of the earlier samples was found to
be contaminated
3122015 Ajaz S Hussain PhD 49
Guidance for Industry Testing of
Glycerin for Diethylene Glycol
CDER May 2007 Compliance
1 Manufacturers did not perform full
identity testing on the glycerin raw
material including tests to quantify
the amount of DEG
2 Relied on the certificate of analysis
(COA)
3 The origin of the glycerin was not
easily apparent from the COA
4 The COA was often a copy of a COA
on the letterhead of the distributor
5 The chain of custody or distribution
history of the glycerin was also not
readily known
USP Glycerin Monograph
Type of Posting Revision Bulletin
Posting Date 04ndashFebndash2009
Official Date 01ndashMayndash2009
Because of the serious hazards
associated withhellip and in response to
recommendations set forth in the
FDA Guidance for Industry Testing
of Glycerin for Diethylene Glycol
published in May 2007 USP has
revised the USP Glycerin monograph
Because diethylene glycol and
ethylene glycol are considered
unacceptable toxic substances the
testing of USP Glycerin should
demonstrate the absence of these
substances
April 2007 FDA request to
USP to revise the Glycerin
monographrsquos
IDENTIFICATION section
Revision includes adding ndash
Identification test B LIMIT OF
DIETHYLENE GLYCOL AND
ETHYLENE GLYCOL to detect
and quantify DEGEG in Glycerin
minus Is no longer part of the impurity
testing
ldquoLimit of DEG and Related
Compoundsrdquo minus Introduces a
capillary gas-chromatographic
(GC) method with flame ionization
detection (FID) minus Limit of NMT
010 each for diethylene glycol
and ethylene glycol is found
70+ years to get here how difficult will it be to change habits such as lsquoblind reliance of COArsquo
3122015 Ajaz S Hussain PhD 50
Personality and Habitual Frame Biases
Myers Brigs ENTJ (first tested at FDA)
S
TF
Expanded frame
future
possibilities
objective lsquocause
and effectrsquo
Expanded frame
future
possibilities
people and
relationships
Narrow frame
the present
individuals and
relationships
Narrow frame
the present
objective
cause and
effect
N
Based on Stanford Webinar - How to Overcome the Top 3 MegaBiases in Decision-Making
Stanford Universityrsquos Strategic Decision and Risk Management certificate program
From Mapping a Managers Brain on Incentives
Social
influences
Relative
thinking
UncertaintyComplexity
By Design Intention to act consciously
bull In the interest of patients and to continually improve this ability bull To provide a healing touch ndash one life at a time in what we do and how we
do it
1292014 Ajazajazhussaincom 51
Consciously
Scientific methodology
Engineering Design
Plan-Do-Check-Act
Subconsciously
Habits (work to get rid of bad ones)
Habits (work to cultivate good one)
Keystone habits (Safety Alcoa ALCOA of data integrity)
The Power of Habit Why We Do What We Do in Life and Business Charles Duhigg (2012)
httpwwwslideshareneta2zpharmscipharmaceutical-culture-of-quality
What does it take to come out of the cGMP crisis
Persuasive demonstration of
(1) Ability to face facts
(2) Legal amp regulatory requirements
3) Systems approach to quality
4) Changing behavior amp culture
What is often missed or is unconvincing is how you will strengthen culture of quality
ldquoLet one who wants to move and convince others first be convinced and moved themselvesrdquo Thomas Carlyle
Signals that question the competence motivation andor integrity of company personnel
Do not defend the plainly indefensible it adds further serious credibility costs
3142015 Ajazajazhussaincom 52
Quality is everyones responsibility
Lack of knowledge that is
the problem
If you do not know how to ask the
right question you discover nothing
If you cant describe what you
are doing as a process you dont know what youre
doing
Rational behavior requires theory
Reactive behavior requires only reflex
action
Whenever there is fear you will get wrong figures
3142015 Ajazajazhussaincom 53
Selected quotes W Edwards Deming
3142015 Ajazajazhussaincom 54
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
ldquoWE CANNOT CHANGE THE HUMAN CONDITION BUThellipWE CAN CHANGE THE CONDITIONS UNDER WHICH HUMANS WORKrdquo JAMES REASON
Disregard to Malice
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 55
ldquohelliprecords not completed
contemporaneouslyrdquo
ldquohellipobserved analyst back-date logbooksrdquo
ldquohelliptrial injectionshelliprdquo
ldquohellipresults failing specifications are
retested until acceptable results are obtainedhelliprdquo
ldquohellipover-writing electronic raw datahelliprdquo
ldquohellipOOS not investigates per XYZ SOPrdquo
ldquohellipappropriate controls not establishedhelliprdquo
Each additional observation adds
reasons to confirm that this is very likely a system
with intentional lsquoholesrsquo in its
defenses
Preconditions
Rationalization amp Attitude
Pressure amp Incentive
Opportunity ndashlsquoholes in the QMSrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 56
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 57
Attitude towards the behavior
Subjective norm
Perceived behavioral
control
IntentionFuture
Behavior
usually found to predict behavioral intentions with a high degree of accuracy
intentions in combination with perceived behavioral control can account for a considerable proportion of variance in behavior
PastBehavior
Ajen I The theory of planned behavior ORGANIZATIONAL BEHAVIOR AND HUMAN DECISION PROCESSES 50 179-211 (1991)
Heparin tragedy 2007 and 2008
FDA reports 149 deaths with allergic or hypersensitivity symptoms during that period
bull Contaminated heparin from China
QC Testing
bull Initial testing failed to detect the contaminant
Pharmacovigilence
bull Signals in the pharmacovigilence systems responded slowly and
Eventually the severity of reactions associated made it likely that the contamination would be detected
bull too late for those who died or were injured
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 58
Congressman Shimkus When the drug safety system fails people get sick Some die
bull Some of these people are already very vulnerable and proving the cause of harm from impurities adulteration and counterfeits can be elusive
It is hard to detect harm
bull Certainly the companies are obligated to ensure a culture of quality and maintain vigilance as well This reflects a systems approach to safety
FDA inspectors look for a culture of quality at
manufacturing facilities
bull FDA policies led to the failure to inspect the Chinese plantThis system approach wasnt at
play here
bull While it doesnt deny the counterfeit source tries to say that counterfeits didnt cause the reaction as if the adulteration itself was no big deal Is this an acceptable mindset helliphelliphellip
This brings me to China and its quality culture or lack thereof
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 59
ONE HUNDRED TENTH CONGRESS SECOND SESSION APRIL 29 2008 Serial No 110-109
21 CFR PART 211 SUBPARTS -Deviations signal gaps in CoQ
bullGENERAL PROVISIONSA
bullORGANIZATION AND PERSONNELB
bullBUILDINGS AND FACILITIESC
bullEQUIPMENTD
bullCONTROL OF COMPONENTS AND DRUG PRODUCT CONTAINERS AND CLOSURESE
bullPRODUCTION AND PROCESS CONTROLSF
bullPACKAGING AND LABELING CONTROLG
bullHOLDING AND DISTRIBUTIONH
bullLABORATORY CONTROLSI
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 60
For example the combinationhellip
The Power of Habit Why We Do What We Do in Life and Business Charles Duhigg (2012)
bull Scientific methodology
bull Engineering Design
bull Plan-Do-Check-ActConsciously
bull Habits (work to get rid of bad ones)
bull Habits (work to cultivate good one)
bull Keystone habits (Safety Alcoa ALCOA of data integrity)
Subconsciously
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 61
CoQ How
bull What are the predictors of CoQCoQ Manifests by Design -
lsquoquality by designrsquo the foundation
bull 1 2 3When do people change their behaviors
bull A B C D (any body can dance)What makes a QMS effective
bull X Y ZWhen proactive compliance occurs
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 62
Going beyond rules pays
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 63
Human behavior Connecting the Dots With the Right Connectors
GXPs ndash rational behaviors
How proactive compliance is achieved X Y Z
Quality Management System
What makes a QMS reliable A B C D
Culture of Quality
Why people change their behavior 1 2 3
Human Behaviors Beyond GXPs
Predictors of Culture of Quality
Why What and How of Culture of Quality
9192014 copy Ajaz S Hussain | INSIGHT ADVICE amp SOLUTIONS LLC 64
Predictors of CoQ Act consciously in the interest of patients ndash when no one is looking
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 65
Only four attributes
actually predict a culture of
quality
Leadership Emphasis
Message Credibility
Peer Involvement
Employee Empower-ment
People will change their
behavior if they see the new behavior as
Normal
(1)
Rewarding
(2)
Easy
(3)
Dr W Edwards Demingrsquos - ldquoOut of the crisisrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 66
The journey requires leadership
with Profound Knowledge as a
guide
bull As leaders responsible for system change top management is most in need of profound knowledge
bull Quality is often determined in the boardroom
bull Problems arise when management reacts to common cause or chance variation as if it were special cause variation
bull Prediction based in theory provides a foundation for planning a course of action Plan ndash Do ndash Check ndash Act
bull The leader serves the people with clear vision and guidance to empower them To be empowered is to share ownership in the identity
bull Giving people a certain degree of control over their work fulfills the need for freedom and provides opportunity for taking joy in work
Profound Knowledge as a guide
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 67
Appreciation for a System
Theory of Knowledge
Knowledge about
Variation
Human Behavior -Psychology of Change
A
B
C
D+
Systems Approach for ErrorDeviation Management
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 68
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
Human error models and management J Reason BMJ 320 768ndash770 (2000)
D+
Culture of Error Management परबधनbull Error strain
bull Covering upFear of Errors
bull Anticipation
bull Risk takingAwareness
bull Development QbDRFT
bull Error detection Communication
bull Analyzing errors Correction
Mastery orientation
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 69
Dots amp Connections
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 70
CoQ
1
2
3
QMS
A
B
C
D
GXP Behaviors
X
Y
Z
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 71
Culture of Quality
Normal
Rewarding
Easy
QMS
System
Knowledge
Variation
Behavior
Behavior -GXPs
Fear Removed
Mastery
Awareness
EnvironmentLeadership Emphasis
Message Credibility
Peer Involvement
Employee Empowerment
Connect to CoQ
Connect to GXPs
A Framework and a Tool (for gap analysis)
Insights
bull Why attention to excipient knowledge management (specifically their functionality) is critical to mitigating risks (or to leverage opportunities) posed by the rapidly increasing complexity and uncertaintybull Note Knowledge management in
the context of lsquointellectual propertyrsquo is not the focus of this talk
bull In the second talk end of the day I plan to discuss how certain management practices can impact effectiveness of knowledge managementbull Note Knowledge management is
a combination of both IT and human aspects I intend to focus on lsquohuman factorsrsquo
3122015 Ajaz S Hussain PhD 3
Outline
bull Declaring my interests acknowledging experiences contributing to my current thinking
bull Current hot topics ndash lsquoexcipientsrsquo regulatory trends amp insights
bull Why attention to (excipient) knowledge management (specifically physical functionalityperformance) is critical
3122015 Ajaz S Hussain PhD 4
My interest in [lsquoexcipientsrsquo] KMacknowledging experiences contributing to my current thinking
bull Business decisions
bull Regulatory research policy amp enforcement
bull Academic research
3122015 Ajaz S Hussain PhD 5
Business decisions
bull Management responsibilitiesbull VP amp Global Head Biopharmaceutical Development Sandoz (2005-2009)
bull Developmentregulatory submission Omnitropereg Binocritreg Zarzioreg Generic Enoxaparin amp Glatiramer acetate
bull VP Next Generation Product Assessment amp CSO Philip Morris International (2009 -2012)
bull Developmentevidence qualityregulatory strategy Plant based vaccines amp assessment of products intended for tobacco harm reduction
bull President Biotechnology amp CSO Wockhardt (2012-2013)
bull Biosimilar and Complex Generic Strategy Improvement
bull AdvisoryConsulting (2013 ndash currently)
bull Mitigating risks in development of complex products Framework for effective compliance amp remediation Strengthening Culture of Quality
3122015 Ajaz S Hussain PhD 6
Regulatory research policy amp enforcement support US FDA (1995 ndash 2005)
bull Research to Policybull SUPAC BCS IVIVC hellipTopical Microbicideshellipseveral others
bull Policybull SUPAC-MR IVIVC BCS helliphellip PAT ICH FDA Lead (Quality) ndash
ldquodesired state for 21st Centuryrdquo ICH Q8 ndash 10
bull Enforcement Supportbull Expert witness for the prosecution (1995)
bull Facilitating resolution of difficult WLs linked to shortages
3122015 Ajaz S Hussain PhD 7
Knowledge to inform policy improvement
3122015 Ajaz S Hussain PhD 8
Physical Attributes Can be critical for safety efficacy and quality
3122015 Ajaz S Hussain PhD 9
July 15 2005 FDA Public Health Advisory Safety Warnings Regarding Use of Fentanyl Transdermal (Skin) Patches
Also relevant today Pattern Recognition
3122015 Ajaz S Hussain PhD 10
Preliminary illustration of a concept Going forward expect to see regulators utilize state-of ndashthe ndashart pattern recognition and modeling systems
Effective Regulatory System Importance of Process Understanding and Quality by DesignAjaz Hussain Pharmaceutical Quality Forum 3rd Symposium November 2004 Tokyo Japan
Academic research
University of Cincinnati (1989-1994)
bull Formulation designbull Several projects ndash oral topical and
transdermalbull Example Elaborating the utility of
Transcutolreg (Gattefosseacute)
bull Computer aided formulation designbull Artificial Neural Network based
lsquoexpert systemsrsquobull Example Prototype for lsquoTechnical
Service Supportrsquo (funding - Aqualon)
NIPTE (Currently)
bull NIPTErsquos Excipient Knowledge basebull Available since 2007 at
httppharmahuborg
bull The goal of this project is to share information and modeling tools to support pharmaceutical product
3122015 Ajaz S Hussain PhD 11
Prototype for lsquoTechnical Service Supportrsquo
3122015 Ajaz S Hussain PhD 12
From a lsquoDatabasersquo to a lsquoKnowledge basersquo
bull lsquoLook-up tablesrsquo to lsquoAbility to Predictrsquo
bull Ability to predict = generate hypotheses
bull Ability (simulate) ask questions - what if
NIPTE Knowledge Management
3122015 Ajaz S Hussain PhD 13
Contact Prof Hoag Univ Maryland shoagrxumarylandedu
3122015 Ajaz S Hussain PhD 14
NIPTE Knowledge Management
This study was funded by the FDA-sponsored contract ldquoDevelopment of Quality by Design (QbD) Guidance Elements on Design Specifications across Scales with Stability Considerationsrdquo (contract number HHSF223200819929C)
3122015 Ajaz S Hussain PhD 15
Current hot topics ndashrsquoexcipientsrsquo regulatory trends amp insights ExcipientFest on 28-29 April 2015 in Washington Organizational Changes CDERFDA and Inspectional Trendshellip(Complex Genericshellip Continuous Manufacturing)
3122015 Ajaz S Hussain PhD 16
Current experience with lsquoSupplier Qualificationrsquo
bull Recent observations are summarized in this report by ECA Academy (21012015) Areas of attention
bull Accuracy and completeness of administrative documentation
bull Evidence to justify excipient and supplier qualification
bull Risk-assessment and effective integration within in QMS
bull Quality agreements
bull Going forward I envision a need to emphasize a life-cycle approach (eg linking to CAPA change control)
3122015 Ajaz S Hussain PhD 17
FDArsquos Inactive Ingredient Database -statusbull Substance Registration System (SRS)
bull Generic listing vs Specific Grade listing for commonly used excipients ndashmax precedent levels
bull Listing of Mixtures
bull The UNII code confusing the National Library of Medicine yet to finalize standards for assigning UNII codes for polymers
bull Individual Grades vs Family Data
bull Legal status of the IID and FDA communications of changes to the IID
bull DMF Implications
bull Impact on ANDAs ndash lsquoDelaysrsquo amp lsquoRefuse to File Lettersrsquo
3122015 Ajaz S Hussain PhD 18
3122015 Ajaz S Hussain PhD 19
Inactive Ingredientsrsquo to lsquoExcipientsrsquo to lsquoFunctionalityrsquo Where are we in this journeylsquo
Status of lsquoSubstances In Regulatory Practicersquo
Clearly we need a global database with improved precision and accuracy of naming (and coding) to identify describe compare and link (to products and AERs)
INDs NDAs BLAs CFRrsquos Orphan Drug ApplicationsProducts that Contain Each Substance
Pharmacological ClassificationActive Moieties Related Moieties and Salts
LADMERMetabolites
Metabolic Enzymes Transporters and EffectsDrug target (therapeutic and other) type of interaction
Solubility and Permeability (BCS)Protein Binding
Impurities and Related Substance
ISO 11238 (ISO IDMP) some challenges
Both substances amp specified substances
Implementation in EU EMA Task force
Global Ingredients Archive System (GInAS)
3122015 Ajaz S Hussain PhD 20
The War Against Fake Medicines Update on FDASIA - Guidance and Impact on Excipient Suppliers and
Users QbD Sampling Guidelines The NSFIPECANSI 363 2014 GMP standardsexplained Good Supply Practices ndash Using Cross Industry Knowledge to Devise Pragmatic Solutions Impact
of Non-harmonized Standards and What is Needed to Achieve Harmonization Advancements in the Question Based Review approach and various other excipient specific related topics An Overview of the FDA OGD
IID EWG activities Effective Sourcing and Purchasing of Excipients
Industry Collaboration for Science Based Implementation of Elemental Impurities Challenges And Opportunities In Developing
And Modernizing Public Standards For NF Excipients Monographs For Regulated Drug
Products Marketed In The USA Future Pharma Manufacturing Efficiencies and the Role of Innovative Excipient Technologies
IPEC ExcipientFest 2015
Current Hot Topics ExcipientFest on 28-29 April 2015 in Washington
3122015 Ajaz S Hussain PhD 21
The War Against Fake Medicines Update on FDASIA - Guidance and Impact on Excipient
Suppliers and Users QbD Sampling Guidelines The NSFIPECANSI 363 2014 GMP standards explained Good Supply Practices ndash Using Cross Industry Knowledge to Devise
Pragmatic Solutions Impact of Non-harmonized Standards and What is Needed to Achieve
Harmonization Advancements in the Question Based Review approach and various other
excipient specific related topics An Overview of the FDA OGD IID EWG activities Effective
Sourcing and Purchasing of Excipients Industry Collaboration for Science Based Implementation of Elemental Impurities Challenges And
Opportunities In Developing And Modernizing Public Standards For NF ExcipientsMonographs For Regulated Drug Products Marketed In The USA Future Pharma Manufacturing Efficiencies and the Role of Innovative Excipient Technologies
IPEC ExcipientFest 2015
Inspectional trends in data integrity (Bangalore Nov
2014)
22(d)
192
100(a)
160(b)
110(a)
67(b)
68(a)
25(a)
67(a)
100(b)
Recurring 483 Observations Top 10
22(d) 192 100(a) 160(b)110(a) 67(b) 68(a) 25(a)67(a) 100(b)
Jeff Medwid NIPTE-FDA Conference 13 June 2012
International Society for Pharmaceutical Engineering (ISPE) in conjunction with McKinsey amp Co will release preliminary data and findings from its Quality Metrics Pilot Program at the ISPE Quality Metrics Summit on April 21ndash22 in Baltimore
FDA Launches New Drug Quality Office With Goal of Improving the Pharmaceutical IndustryPosted 13 January 2015By Alexander Gaffney RAC
FDArsquos New Pharma Quality
Office Will Take a Team Approach
Yu Explains
Regulatory Recon Investigations Find Major Quality Problems at Indian Pharma Companies (3 December 2014)Posted 03 December 2014By Alexander Gaffney RAC
Currently the environment is complex there is high uncertainty D
on
rsquot f
org
et
fun
ctio
na
lity
o
f e
xcip
ien
ts i
s im
po
rta
nt
3122015 Ajaz S Hussain PhD 22
Need for urgent progress lsquoInactive Ingredientsrsquo to lsquoExcipientsrsquo to lsquoFunctional Excipientsrsquo
Importance of assuring quality and controlling
variability of excipients
including their lsquofunctionalityrsquo has
long been recognized
bull Increasing complexity of drugs their delivery and failure modes
bull Patient (eg pediatric) relevant failure modes
bull Simple generics to complex generics amp biosimilars
Urgent need to address gaps in the FDArsquos Inactive Ingredient Database
3122015 Ajaz S Hussain PhD 23
Trends Lab amp Manufacturing
ldquoDeletion of Datardquo
ldquoTesting Into Compliancerdquo
ldquoBMR manipulation is a slippery sloperdquo
ldquoSuggestive of faulty manufacturing process or practices even if this is not the caserdquo
ldquoIt is top managementrsquos responsibility to ensure the training program is robust and effectiverdquo
Inspectional trends in data integrity (Bangalore Nov 13 2014 - Nov 14 2014)
Growing concern some
companies ldquodata looks too good
to be truerdquo
3122015 Ajaz S Hussain PhD 24
GMP Compliance amp Remediation
Jeff Medwid NIPTE-FDA Conference 13 June 2012
QbD amp QbR Clarity on Critical Functionality
FDArsquos New Pharma Quality
Office Will Take a Team
Approach Yu Explains
Carmelo Rosa MS PsyD November 2014
Urgent Need amp Opportunity
To align amp ensure sound scientific basis of these critical regulatory decisions
FDA CDER OPQ Plans for Surveillance of Pharmaceutical Quality
Teresa Mullin PhD December 2014
3122015 Ajaz S Hussain PhD 25
Need for a comprehensive (excipient) knowledge base
Teresa Mullin PhD December 2014
3122015 Ajaz S Hussain PhD 26
Why attention to (excipient) knowledge management is criticalSpecifically for physical attributes functionality performance
3122015 Ajaz S Hussain PhD 27
3122015 Ajaz S Hussain PhD 28
Today there are several product categories (eg controlled release inhalation products DPIrsquos topical transdermal liposomal products etc) which requires an exquisite control of complex physical material and product attributes (functionality)
Many of our current measurement systems need improvement
We depend on these to ensure control of lot-lot variability
Measurement system capability must be confirmed to be able to assess process capability (calibration amp Gauge RampR)
Life-cycle approach to quality continued process verification (FDArsquos Process Validation 2011) is a safety net
Supplier amp Excipient Qualification amp Process Validation
Measurement System Analysis
bull From lsquocalibrationrsquo to lsquoGauge RampRrsquoParticularly for physical
attributes destructive analysis
bull Many (including regulators) have not yet understood its importance
Gauge RampR well established but not commonly practiced
bull Measurement system in a state of control effective CAPA quality metrics Culture of Quality
With the move towards Statistical Process Control
bull Demonstrate equivalent in vitro performance more exacting criteria
Development of complex generic products (ER
Injectable Inhalation etc)
3122015 Ajaz S Hussain PhD 29
Process Validation (2011) Statistical Confidence Continued Process Verificationhellip
3122015 Ajaz S Hussain PhD 30
httpwwwslideshareneta2zpharmsciperformance-testing-pharmaceutical-quality-2004(accessed 6 December 2014)
3122015 Ajaz S Hussain PhD 31
Supplier amp Excipient Qualification amp CAPA
Out of Specification events are difficult to resolve
Excipient functionality can be a significant contributing factor
Sometimes reluctantly have to settle with - ldquoRoot cause unknown
600 days
I have inserted the ldquo600 daysrsquo on the figure ndash this is based on cases I have seen while at FDA)
3122015 Ajaz S Hussain PhD 32
Prevention of OOS and Effective CAPA needs a focus on critical functional attributes
Out of Specification events are difficult to resolve
Excipient functionality can be a significant contributing factor
Sometimes reluctantly have to settle with - ldquoRoot cause unknown
Compendial standards and manufacturing
3122015 Ajaz S Hussain PhD 33
Practice Control Process Maturity
Initial
bull Unpredictable
Managed
bull Characterized but reactive
Defined
bull Characterized proactive
Measured amp Controlled
bull In control
Optimizing
bull Focus on improvement
3122015 Ajaz S Hussain PhD 34
Capability Maturity Model Integration Carnegie Mellon University
A validated process
Maturity Level amp Assurance of Quality
Managed Characterized but reactive
High perceived risk of
lsquoCheating by Designrsquo
ldquoTrial Injectionsrdquo
ldquoTesting in to Compliancerdquo
Defined Characterized proactive
Lower level of assurance
Stopping amp Correcting
Batch Rejection
Measured amp
ControlledIn control
Quality by Design
Quality Assured
Improvement Opportunities
3122015 Ajaz S Hussain PhD 35
At the individual level in QC functionndash how often does this occur
attitude toward
performing the behavior
Process validation is
done so quality is good
test prone to error
ldquoBatch failure means I made
a mistakerdquo
subjective norm
documentation not critical
Compendial testing
sufficient
Indian regulators
collect amp test samples ndash no issue there
3122015 Ajaz S Hussain PhD 36
ldquoTesting into compliancerdquo
In general ndash low empowerment is a significant challenge (low perceived behavioral control) plus reasons to rationalizehellip
Excipient Functionality Can be critical for safety efficacy and quality
3122015 Ajaz S Hussain PhD 37
July 15 2005 FDA Public Health Advisory Safety Warnings Regarding Use of Fentanyl Transdermal (Skin) Patches
A pattern of failure Pharmaceutical Equivalence by Design (2004)
3122015 Ajaz S Hussain PhD 38
httpwwwnihsgojpdrugPhForumdocuments041122Hussain041122pdf
An attempt to correct
3122015 Ajaz S Hussain PhD 39
httpipecamericasorgsystemfilesKeyNoteEF13May11LawrenceYu(FDA)pdf
Recent challenges
3122015 Ajaz S Hussain PhD 40
Th
e V
oic
e o
f th
eA
mer
ican
P
sych
iatr
ic A
sso
ciat
ion
and
th
e P
sych
iatr
ic C
om
mu
nit
y
Physicians Question FDAs Confidence in Generic Drugs Safety Efficacy (OCTOBER 24 2014)
bull ldquomost patientsrdquo is not the same asldquo all patientsrdquo and whether the 24 to 36 normal subjects used in the agencys bioequivalency tests represents the full range of individual variation in the way drugs are absorbed across the pharmaceutical using population is uncertain
bull Individuals can sometimes be allergic and react differently to whatever substance goes into making up the capsule or the tablet
FDA Flags Generic Versions of ADHD Medication(NOVEMBER 14 2014)
bull FDA changed the therapeutic equivalence (TE) rating from AB to BXmdashmeaning that the products are still approved and can be prescribed but are no longer recommended as automatic substitutes
RLD Variability Can be a block-buster opportunityFocus on lsquocontrol strategyrsquo
bull Overcoming CP amp IP provide FDA a submission they need to address CP
bull Then begin with QTPP CQArsquos hellip skip lsquodesign spacersquo and focus on lsquocontrol strategy
bull The entire development team should read the complete package insert of RLD
bull Discuss to ensure a common understandingbull Failure modes amp intended use
bull Pharmaceutical Equivalence
bull Bioequivalence
bull Other studies
QbD Challenges
3122015 Ajaz S Hussain PhD 41
NewRegulators are not prepared to handle QbD applications
NewMisalignment of international regulatory authorities
New and Generics
RampD incentivized for lsquoshots on the goalrsquo not QbD
GenericsLack of belief in business case ndash lsquoGenerics are all about file first figure out laterrsquo
Biologics Lack of technology to execute
Ted Fuhr Mackinsey amp Company June 2010 FDA Advisory Committee
Summary
bull Excipient functionality can contribute in critical ways to product quality amp performance adequate control is necessary
bull Our databases tools and knowledge are lagging behind the rapidly increasing complexity and uncertainty
bull Risk to quality and to business is increasing and regulatory transitions pose additional difficulties
bull Effective knowledge management ndash IT and Human practices ndash is critical for organizational lsquobottom-linersquo
bull We all must come together collaboratively to address the urgent needs we owe it to the patients we serve
3122015 Ajaz S Hussain PhD 42
Knowledge Management amp Culture of Quality
Ajaz S Hussain PhD
Insight Advice amp Solutions LLCMaryland USA
Executive Director the National Institute for Pharmaceutical Technology amp Education
3122015 Ajaz S Hussain PhD 43
3122015 Ajaz S Hussain PhD 44
Life-cycle approach needed for knowledge management
Investigational ProductscGMPs
DevelopmentTechnology
TransferCommercial
ManufacturingDiscontinuation
Management Responsibility
Process Performance amp Product Quality Monitoring SystemCAPA Change Management Management Review
PQS Elements
Knowledge ManagementQuality Risk ManagementEnablers
ICH Q10 KM is a systematic approach to acquiring analyzing storing and disseminating information related to products manufacturing processes and components
Based on ICH Q10
ldquowe can be blind to the obvious and we are also blind to our blindnessrdquo
Daniel Kahneman Thinking Fast and Slow
3142015 Ajazajazhussaincom 45
httpwebmiteduperscipeopleadelsoncheckershadow_proofhtml
3122015 Ajaz S Hussain PhD 46
1938 The Federal Food Drug and Cosmetic (FDC)
bull 1937 Elixir of Sulfanilamide
1962 Kefauver-Harris Drug Amendments
bull 1962 Thalidomide
bull 1960 Color Additive Amendment
bull 1958 Food Additives Amendment GRAS
bull 1960 Color Additive Amendment
bull 1958 Food Additives Amendment GRAS
1992 Generic Drug Enforcement Act
bull1989 L-Tryptophan
bull 1989 Generic Drug Scandal
bull 1988 Food and Drug Administration Act
bull 1984 Fines Enhancement Laws Drug Price Competition and Patent Term Restoration Act
2012 Food and Drug Administration Safety and Innovation Act (FDASIA)
bull 2007 Heparin Disaster
2013 Pandemic and All-Hazards Preparedness Reauthorization Act (PAHPRA) Drug Quality and Security Act
bull 2012 The Deadly Meningitis Outbreak
Past 70 years 1937 ndash 2007 The diethylene glycol (DEG) narrative
3122015 Ajaz S Hussain PhD 47
0
5
10
15
20
25
30
35
Yea
rs
DEG Years since the previous incident
0
50
100
150
200
250
300
350
Number of Reported Deaths
1937
Eli
xir
of
Sulf
anil
amid
e
2007T
ootp
aste
conta
min
atio
n
0 70 years 0 70 years
Frequent reports
Mumbai Mumbai
Data from Excipient Fest Janeen Skutnik Chair ndashIPECAmericas 2009
Past 70+ years DEG contamination or economically motivated adulteration
3122015 Ajaz S Hussain PhD 48
Reported cases underestimate the real tragedy rapid intervention may not occur
Epidemic of Pediatric Deaths From Acute Renal Failure Caused by
Diethylene Glycol Poisoning JAMA 1998279(15)1175-1180
doi101001jama279151175
Month of hospital admission for children with
acute renal failure Haiti
October 1995-October 1996
Diethylene glycol poisoning in Gurgaon India 1998Bulletin of the World Health Organization 2001 79 88ndash95
We report a second episode of poisoning occurring in 1998 in
India as a result of children ingesting diethylene glycol at
least 33 children are known to have died
At the beginning of the investigation we never imagined that
contaminated medicine was causing acute renal failure in
children
A brand of cough expectorant manufactured by a local
pharmaceutical company was found by the Central Drugs
Laboratory Calcutta to contain 175 (vv) diethylene
glycol
The district and state drug controller had tested many
samples using thin layer chromatography before a sample of
medicine tested positive for diethylene glycol at the Central
Drugs Laboratory None of the earlier samples was found to
be contaminated
3122015 Ajaz S Hussain PhD 49
Guidance for Industry Testing of
Glycerin for Diethylene Glycol
CDER May 2007 Compliance
1 Manufacturers did not perform full
identity testing on the glycerin raw
material including tests to quantify
the amount of DEG
2 Relied on the certificate of analysis
(COA)
3 The origin of the glycerin was not
easily apparent from the COA
4 The COA was often a copy of a COA
on the letterhead of the distributor
5 The chain of custody or distribution
history of the glycerin was also not
readily known
USP Glycerin Monograph
Type of Posting Revision Bulletin
Posting Date 04ndashFebndash2009
Official Date 01ndashMayndash2009
Because of the serious hazards
associated withhellip and in response to
recommendations set forth in the
FDA Guidance for Industry Testing
of Glycerin for Diethylene Glycol
published in May 2007 USP has
revised the USP Glycerin monograph
Because diethylene glycol and
ethylene glycol are considered
unacceptable toxic substances the
testing of USP Glycerin should
demonstrate the absence of these
substances
April 2007 FDA request to
USP to revise the Glycerin
monographrsquos
IDENTIFICATION section
Revision includes adding ndash
Identification test B LIMIT OF
DIETHYLENE GLYCOL AND
ETHYLENE GLYCOL to detect
and quantify DEGEG in Glycerin
minus Is no longer part of the impurity
testing
ldquoLimit of DEG and Related
Compoundsrdquo minus Introduces a
capillary gas-chromatographic
(GC) method with flame ionization
detection (FID) minus Limit of NMT
010 each for diethylene glycol
and ethylene glycol is found
70+ years to get here how difficult will it be to change habits such as lsquoblind reliance of COArsquo
3122015 Ajaz S Hussain PhD 50
Personality and Habitual Frame Biases
Myers Brigs ENTJ (first tested at FDA)
S
TF
Expanded frame
future
possibilities
objective lsquocause
and effectrsquo
Expanded frame
future
possibilities
people and
relationships
Narrow frame
the present
individuals and
relationships
Narrow frame
the present
objective
cause and
effect
N
Based on Stanford Webinar - How to Overcome the Top 3 MegaBiases in Decision-Making
Stanford Universityrsquos Strategic Decision and Risk Management certificate program
From Mapping a Managers Brain on Incentives
Social
influences
Relative
thinking
UncertaintyComplexity
By Design Intention to act consciously
bull In the interest of patients and to continually improve this ability bull To provide a healing touch ndash one life at a time in what we do and how we
do it
1292014 Ajazajazhussaincom 51
Consciously
Scientific methodology
Engineering Design
Plan-Do-Check-Act
Subconsciously
Habits (work to get rid of bad ones)
Habits (work to cultivate good one)
Keystone habits (Safety Alcoa ALCOA of data integrity)
The Power of Habit Why We Do What We Do in Life and Business Charles Duhigg (2012)
httpwwwslideshareneta2zpharmscipharmaceutical-culture-of-quality
What does it take to come out of the cGMP crisis
Persuasive demonstration of
(1) Ability to face facts
(2) Legal amp regulatory requirements
3) Systems approach to quality
4) Changing behavior amp culture
What is often missed or is unconvincing is how you will strengthen culture of quality
ldquoLet one who wants to move and convince others first be convinced and moved themselvesrdquo Thomas Carlyle
Signals that question the competence motivation andor integrity of company personnel
Do not defend the plainly indefensible it adds further serious credibility costs
3142015 Ajazajazhussaincom 52
Quality is everyones responsibility
Lack of knowledge that is
the problem
If you do not know how to ask the
right question you discover nothing
If you cant describe what you
are doing as a process you dont know what youre
doing
Rational behavior requires theory
Reactive behavior requires only reflex
action
Whenever there is fear you will get wrong figures
3142015 Ajazajazhussaincom 53
Selected quotes W Edwards Deming
3142015 Ajazajazhussaincom 54
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
ldquoWE CANNOT CHANGE THE HUMAN CONDITION BUThellipWE CAN CHANGE THE CONDITIONS UNDER WHICH HUMANS WORKrdquo JAMES REASON
Disregard to Malice
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 55
ldquohelliprecords not completed
contemporaneouslyrdquo
ldquohellipobserved analyst back-date logbooksrdquo
ldquohelliptrial injectionshelliprdquo
ldquohellipresults failing specifications are
retested until acceptable results are obtainedhelliprdquo
ldquohellipover-writing electronic raw datahelliprdquo
ldquohellipOOS not investigates per XYZ SOPrdquo
ldquohellipappropriate controls not establishedhelliprdquo
Each additional observation adds
reasons to confirm that this is very likely a system
with intentional lsquoholesrsquo in its
defenses
Preconditions
Rationalization amp Attitude
Pressure amp Incentive
Opportunity ndashlsquoholes in the QMSrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 56
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 57
Attitude towards the behavior
Subjective norm
Perceived behavioral
control
IntentionFuture
Behavior
usually found to predict behavioral intentions with a high degree of accuracy
intentions in combination with perceived behavioral control can account for a considerable proportion of variance in behavior
PastBehavior
Ajen I The theory of planned behavior ORGANIZATIONAL BEHAVIOR AND HUMAN DECISION PROCESSES 50 179-211 (1991)
Heparin tragedy 2007 and 2008
FDA reports 149 deaths with allergic or hypersensitivity symptoms during that period
bull Contaminated heparin from China
QC Testing
bull Initial testing failed to detect the contaminant
Pharmacovigilence
bull Signals in the pharmacovigilence systems responded slowly and
Eventually the severity of reactions associated made it likely that the contamination would be detected
bull too late for those who died or were injured
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 58
Congressman Shimkus When the drug safety system fails people get sick Some die
bull Some of these people are already very vulnerable and proving the cause of harm from impurities adulteration and counterfeits can be elusive
It is hard to detect harm
bull Certainly the companies are obligated to ensure a culture of quality and maintain vigilance as well This reflects a systems approach to safety
FDA inspectors look for a culture of quality at
manufacturing facilities
bull FDA policies led to the failure to inspect the Chinese plantThis system approach wasnt at
play here
bull While it doesnt deny the counterfeit source tries to say that counterfeits didnt cause the reaction as if the adulteration itself was no big deal Is this an acceptable mindset helliphelliphellip
This brings me to China and its quality culture or lack thereof
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 59
ONE HUNDRED TENTH CONGRESS SECOND SESSION APRIL 29 2008 Serial No 110-109
21 CFR PART 211 SUBPARTS -Deviations signal gaps in CoQ
bullGENERAL PROVISIONSA
bullORGANIZATION AND PERSONNELB
bullBUILDINGS AND FACILITIESC
bullEQUIPMENTD
bullCONTROL OF COMPONENTS AND DRUG PRODUCT CONTAINERS AND CLOSURESE
bullPRODUCTION AND PROCESS CONTROLSF
bullPACKAGING AND LABELING CONTROLG
bullHOLDING AND DISTRIBUTIONH
bullLABORATORY CONTROLSI
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 60
For example the combinationhellip
The Power of Habit Why We Do What We Do in Life and Business Charles Duhigg (2012)
bull Scientific methodology
bull Engineering Design
bull Plan-Do-Check-ActConsciously
bull Habits (work to get rid of bad ones)
bull Habits (work to cultivate good one)
bull Keystone habits (Safety Alcoa ALCOA of data integrity)
Subconsciously
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 61
CoQ How
bull What are the predictors of CoQCoQ Manifests by Design -
lsquoquality by designrsquo the foundation
bull 1 2 3When do people change their behaviors
bull A B C D (any body can dance)What makes a QMS effective
bull X Y ZWhen proactive compliance occurs
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 62
Going beyond rules pays
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 63
Human behavior Connecting the Dots With the Right Connectors
GXPs ndash rational behaviors
How proactive compliance is achieved X Y Z
Quality Management System
What makes a QMS reliable A B C D
Culture of Quality
Why people change their behavior 1 2 3
Human Behaviors Beyond GXPs
Predictors of Culture of Quality
Why What and How of Culture of Quality
9192014 copy Ajaz S Hussain | INSIGHT ADVICE amp SOLUTIONS LLC 64
Predictors of CoQ Act consciously in the interest of patients ndash when no one is looking
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 65
Only four attributes
actually predict a culture of
quality
Leadership Emphasis
Message Credibility
Peer Involvement
Employee Empower-ment
People will change their
behavior if they see the new behavior as
Normal
(1)
Rewarding
(2)
Easy
(3)
Dr W Edwards Demingrsquos - ldquoOut of the crisisrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 66
The journey requires leadership
with Profound Knowledge as a
guide
bull As leaders responsible for system change top management is most in need of profound knowledge
bull Quality is often determined in the boardroom
bull Problems arise when management reacts to common cause or chance variation as if it were special cause variation
bull Prediction based in theory provides a foundation for planning a course of action Plan ndash Do ndash Check ndash Act
bull The leader serves the people with clear vision and guidance to empower them To be empowered is to share ownership in the identity
bull Giving people a certain degree of control over their work fulfills the need for freedom and provides opportunity for taking joy in work
Profound Knowledge as a guide
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 67
Appreciation for a System
Theory of Knowledge
Knowledge about
Variation
Human Behavior -Psychology of Change
A
B
C
D+
Systems Approach for ErrorDeviation Management
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 68
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
Human error models and management J Reason BMJ 320 768ndash770 (2000)
D+
Culture of Error Management परबधनbull Error strain
bull Covering upFear of Errors
bull Anticipation
bull Risk takingAwareness
bull Development QbDRFT
bull Error detection Communication
bull Analyzing errors Correction
Mastery orientation
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 69
Dots amp Connections
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 70
CoQ
1
2
3
QMS
A
B
C
D
GXP Behaviors
X
Y
Z
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 71
Culture of Quality
Normal
Rewarding
Easy
QMS
System
Knowledge
Variation
Behavior
Behavior -GXPs
Fear Removed
Mastery
Awareness
EnvironmentLeadership Emphasis
Message Credibility
Peer Involvement
Employee Empowerment
Connect to CoQ
Connect to GXPs
A Framework and a Tool (for gap analysis)
Outline
bull Declaring my interests acknowledging experiences contributing to my current thinking
bull Current hot topics ndash lsquoexcipientsrsquo regulatory trends amp insights
bull Why attention to (excipient) knowledge management (specifically physical functionalityperformance) is critical
3122015 Ajaz S Hussain PhD 4
My interest in [lsquoexcipientsrsquo] KMacknowledging experiences contributing to my current thinking
bull Business decisions
bull Regulatory research policy amp enforcement
bull Academic research
3122015 Ajaz S Hussain PhD 5
Business decisions
bull Management responsibilitiesbull VP amp Global Head Biopharmaceutical Development Sandoz (2005-2009)
bull Developmentregulatory submission Omnitropereg Binocritreg Zarzioreg Generic Enoxaparin amp Glatiramer acetate
bull VP Next Generation Product Assessment amp CSO Philip Morris International (2009 -2012)
bull Developmentevidence qualityregulatory strategy Plant based vaccines amp assessment of products intended for tobacco harm reduction
bull President Biotechnology amp CSO Wockhardt (2012-2013)
bull Biosimilar and Complex Generic Strategy Improvement
bull AdvisoryConsulting (2013 ndash currently)
bull Mitigating risks in development of complex products Framework for effective compliance amp remediation Strengthening Culture of Quality
3122015 Ajaz S Hussain PhD 6
Regulatory research policy amp enforcement support US FDA (1995 ndash 2005)
bull Research to Policybull SUPAC BCS IVIVC hellipTopical Microbicideshellipseveral others
bull Policybull SUPAC-MR IVIVC BCS helliphellip PAT ICH FDA Lead (Quality) ndash
ldquodesired state for 21st Centuryrdquo ICH Q8 ndash 10
bull Enforcement Supportbull Expert witness for the prosecution (1995)
bull Facilitating resolution of difficult WLs linked to shortages
3122015 Ajaz S Hussain PhD 7
Knowledge to inform policy improvement
3122015 Ajaz S Hussain PhD 8
Physical Attributes Can be critical for safety efficacy and quality
3122015 Ajaz S Hussain PhD 9
July 15 2005 FDA Public Health Advisory Safety Warnings Regarding Use of Fentanyl Transdermal (Skin) Patches
Also relevant today Pattern Recognition
3122015 Ajaz S Hussain PhD 10
Preliminary illustration of a concept Going forward expect to see regulators utilize state-of ndashthe ndashart pattern recognition and modeling systems
Effective Regulatory System Importance of Process Understanding and Quality by DesignAjaz Hussain Pharmaceutical Quality Forum 3rd Symposium November 2004 Tokyo Japan
Academic research
University of Cincinnati (1989-1994)
bull Formulation designbull Several projects ndash oral topical and
transdermalbull Example Elaborating the utility of
Transcutolreg (Gattefosseacute)
bull Computer aided formulation designbull Artificial Neural Network based
lsquoexpert systemsrsquobull Example Prototype for lsquoTechnical
Service Supportrsquo (funding - Aqualon)
NIPTE (Currently)
bull NIPTErsquos Excipient Knowledge basebull Available since 2007 at
httppharmahuborg
bull The goal of this project is to share information and modeling tools to support pharmaceutical product
3122015 Ajaz S Hussain PhD 11
Prototype for lsquoTechnical Service Supportrsquo
3122015 Ajaz S Hussain PhD 12
From a lsquoDatabasersquo to a lsquoKnowledge basersquo
bull lsquoLook-up tablesrsquo to lsquoAbility to Predictrsquo
bull Ability to predict = generate hypotheses
bull Ability (simulate) ask questions - what if
NIPTE Knowledge Management
3122015 Ajaz S Hussain PhD 13
Contact Prof Hoag Univ Maryland shoagrxumarylandedu
3122015 Ajaz S Hussain PhD 14
NIPTE Knowledge Management
This study was funded by the FDA-sponsored contract ldquoDevelopment of Quality by Design (QbD) Guidance Elements on Design Specifications across Scales with Stability Considerationsrdquo (contract number HHSF223200819929C)
3122015 Ajaz S Hussain PhD 15
Current hot topics ndashrsquoexcipientsrsquo regulatory trends amp insights ExcipientFest on 28-29 April 2015 in Washington Organizational Changes CDERFDA and Inspectional Trendshellip(Complex Genericshellip Continuous Manufacturing)
3122015 Ajaz S Hussain PhD 16
Current experience with lsquoSupplier Qualificationrsquo
bull Recent observations are summarized in this report by ECA Academy (21012015) Areas of attention
bull Accuracy and completeness of administrative documentation
bull Evidence to justify excipient and supplier qualification
bull Risk-assessment and effective integration within in QMS
bull Quality agreements
bull Going forward I envision a need to emphasize a life-cycle approach (eg linking to CAPA change control)
3122015 Ajaz S Hussain PhD 17
FDArsquos Inactive Ingredient Database -statusbull Substance Registration System (SRS)
bull Generic listing vs Specific Grade listing for commonly used excipients ndashmax precedent levels
bull Listing of Mixtures
bull The UNII code confusing the National Library of Medicine yet to finalize standards for assigning UNII codes for polymers
bull Individual Grades vs Family Data
bull Legal status of the IID and FDA communications of changes to the IID
bull DMF Implications
bull Impact on ANDAs ndash lsquoDelaysrsquo amp lsquoRefuse to File Lettersrsquo
3122015 Ajaz S Hussain PhD 18
3122015 Ajaz S Hussain PhD 19
Inactive Ingredientsrsquo to lsquoExcipientsrsquo to lsquoFunctionalityrsquo Where are we in this journeylsquo
Status of lsquoSubstances In Regulatory Practicersquo
Clearly we need a global database with improved precision and accuracy of naming (and coding) to identify describe compare and link (to products and AERs)
INDs NDAs BLAs CFRrsquos Orphan Drug ApplicationsProducts that Contain Each Substance
Pharmacological ClassificationActive Moieties Related Moieties and Salts
LADMERMetabolites
Metabolic Enzymes Transporters and EffectsDrug target (therapeutic and other) type of interaction
Solubility and Permeability (BCS)Protein Binding
Impurities and Related Substance
ISO 11238 (ISO IDMP) some challenges
Both substances amp specified substances
Implementation in EU EMA Task force
Global Ingredients Archive System (GInAS)
3122015 Ajaz S Hussain PhD 20
The War Against Fake Medicines Update on FDASIA - Guidance and Impact on Excipient Suppliers and
Users QbD Sampling Guidelines The NSFIPECANSI 363 2014 GMP standardsexplained Good Supply Practices ndash Using Cross Industry Knowledge to Devise Pragmatic Solutions Impact
of Non-harmonized Standards and What is Needed to Achieve Harmonization Advancements in the Question Based Review approach and various other excipient specific related topics An Overview of the FDA OGD
IID EWG activities Effective Sourcing and Purchasing of Excipients
Industry Collaboration for Science Based Implementation of Elemental Impurities Challenges And Opportunities In Developing
And Modernizing Public Standards For NF Excipients Monographs For Regulated Drug
Products Marketed In The USA Future Pharma Manufacturing Efficiencies and the Role of Innovative Excipient Technologies
IPEC ExcipientFest 2015
Current Hot Topics ExcipientFest on 28-29 April 2015 in Washington
3122015 Ajaz S Hussain PhD 21
The War Against Fake Medicines Update on FDASIA - Guidance and Impact on Excipient
Suppliers and Users QbD Sampling Guidelines The NSFIPECANSI 363 2014 GMP standards explained Good Supply Practices ndash Using Cross Industry Knowledge to Devise
Pragmatic Solutions Impact of Non-harmonized Standards and What is Needed to Achieve
Harmonization Advancements in the Question Based Review approach and various other
excipient specific related topics An Overview of the FDA OGD IID EWG activities Effective
Sourcing and Purchasing of Excipients Industry Collaboration for Science Based Implementation of Elemental Impurities Challenges And
Opportunities In Developing And Modernizing Public Standards For NF ExcipientsMonographs For Regulated Drug Products Marketed In The USA Future Pharma Manufacturing Efficiencies and the Role of Innovative Excipient Technologies
IPEC ExcipientFest 2015
Inspectional trends in data integrity (Bangalore Nov
2014)
22(d)
192
100(a)
160(b)
110(a)
67(b)
68(a)
25(a)
67(a)
100(b)
Recurring 483 Observations Top 10
22(d) 192 100(a) 160(b)110(a) 67(b) 68(a) 25(a)67(a) 100(b)
Jeff Medwid NIPTE-FDA Conference 13 June 2012
International Society for Pharmaceutical Engineering (ISPE) in conjunction with McKinsey amp Co will release preliminary data and findings from its Quality Metrics Pilot Program at the ISPE Quality Metrics Summit on April 21ndash22 in Baltimore
FDA Launches New Drug Quality Office With Goal of Improving the Pharmaceutical IndustryPosted 13 January 2015By Alexander Gaffney RAC
FDArsquos New Pharma Quality
Office Will Take a Team Approach
Yu Explains
Regulatory Recon Investigations Find Major Quality Problems at Indian Pharma Companies (3 December 2014)Posted 03 December 2014By Alexander Gaffney RAC
Currently the environment is complex there is high uncertainty D
on
rsquot f
org
et
fun
ctio
na
lity
o
f e
xcip
ien
ts i
s im
po
rta
nt
3122015 Ajaz S Hussain PhD 22
Need for urgent progress lsquoInactive Ingredientsrsquo to lsquoExcipientsrsquo to lsquoFunctional Excipientsrsquo
Importance of assuring quality and controlling
variability of excipients
including their lsquofunctionalityrsquo has
long been recognized
bull Increasing complexity of drugs their delivery and failure modes
bull Patient (eg pediatric) relevant failure modes
bull Simple generics to complex generics amp biosimilars
Urgent need to address gaps in the FDArsquos Inactive Ingredient Database
3122015 Ajaz S Hussain PhD 23
Trends Lab amp Manufacturing
ldquoDeletion of Datardquo
ldquoTesting Into Compliancerdquo
ldquoBMR manipulation is a slippery sloperdquo
ldquoSuggestive of faulty manufacturing process or practices even if this is not the caserdquo
ldquoIt is top managementrsquos responsibility to ensure the training program is robust and effectiverdquo
Inspectional trends in data integrity (Bangalore Nov 13 2014 - Nov 14 2014)
Growing concern some
companies ldquodata looks too good
to be truerdquo
3122015 Ajaz S Hussain PhD 24
GMP Compliance amp Remediation
Jeff Medwid NIPTE-FDA Conference 13 June 2012
QbD amp QbR Clarity on Critical Functionality
FDArsquos New Pharma Quality
Office Will Take a Team
Approach Yu Explains
Carmelo Rosa MS PsyD November 2014
Urgent Need amp Opportunity
To align amp ensure sound scientific basis of these critical regulatory decisions
FDA CDER OPQ Plans for Surveillance of Pharmaceutical Quality
Teresa Mullin PhD December 2014
3122015 Ajaz S Hussain PhD 25
Need for a comprehensive (excipient) knowledge base
Teresa Mullin PhD December 2014
3122015 Ajaz S Hussain PhD 26
Why attention to (excipient) knowledge management is criticalSpecifically for physical attributes functionality performance
3122015 Ajaz S Hussain PhD 27
3122015 Ajaz S Hussain PhD 28
Today there are several product categories (eg controlled release inhalation products DPIrsquos topical transdermal liposomal products etc) which requires an exquisite control of complex physical material and product attributes (functionality)
Many of our current measurement systems need improvement
We depend on these to ensure control of lot-lot variability
Measurement system capability must be confirmed to be able to assess process capability (calibration amp Gauge RampR)
Life-cycle approach to quality continued process verification (FDArsquos Process Validation 2011) is a safety net
Supplier amp Excipient Qualification amp Process Validation
Measurement System Analysis
bull From lsquocalibrationrsquo to lsquoGauge RampRrsquoParticularly for physical
attributes destructive analysis
bull Many (including regulators) have not yet understood its importance
Gauge RampR well established but not commonly practiced
bull Measurement system in a state of control effective CAPA quality metrics Culture of Quality
With the move towards Statistical Process Control
bull Demonstrate equivalent in vitro performance more exacting criteria
Development of complex generic products (ER
Injectable Inhalation etc)
3122015 Ajaz S Hussain PhD 29
Process Validation (2011) Statistical Confidence Continued Process Verificationhellip
3122015 Ajaz S Hussain PhD 30
httpwwwslideshareneta2zpharmsciperformance-testing-pharmaceutical-quality-2004(accessed 6 December 2014)
3122015 Ajaz S Hussain PhD 31
Supplier amp Excipient Qualification amp CAPA
Out of Specification events are difficult to resolve
Excipient functionality can be a significant contributing factor
Sometimes reluctantly have to settle with - ldquoRoot cause unknown
600 days
I have inserted the ldquo600 daysrsquo on the figure ndash this is based on cases I have seen while at FDA)
3122015 Ajaz S Hussain PhD 32
Prevention of OOS and Effective CAPA needs a focus on critical functional attributes
Out of Specification events are difficult to resolve
Excipient functionality can be a significant contributing factor
Sometimes reluctantly have to settle with - ldquoRoot cause unknown
Compendial standards and manufacturing
3122015 Ajaz S Hussain PhD 33
Practice Control Process Maturity
Initial
bull Unpredictable
Managed
bull Characterized but reactive
Defined
bull Characterized proactive
Measured amp Controlled
bull In control
Optimizing
bull Focus on improvement
3122015 Ajaz S Hussain PhD 34
Capability Maturity Model Integration Carnegie Mellon University
A validated process
Maturity Level amp Assurance of Quality
Managed Characterized but reactive
High perceived risk of
lsquoCheating by Designrsquo
ldquoTrial Injectionsrdquo
ldquoTesting in to Compliancerdquo
Defined Characterized proactive
Lower level of assurance
Stopping amp Correcting
Batch Rejection
Measured amp
ControlledIn control
Quality by Design
Quality Assured
Improvement Opportunities
3122015 Ajaz S Hussain PhD 35
At the individual level in QC functionndash how often does this occur
attitude toward
performing the behavior
Process validation is
done so quality is good
test prone to error
ldquoBatch failure means I made
a mistakerdquo
subjective norm
documentation not critical
Compendial testing
sufficient
Indian regulators
collect amp test samples ndash no issue there
3122015 Ajaz S Hussain PhD 36
ldquoTesting into compliancerdquo
In general ndash low empowerment is a significant challenge (low perceived behavioral control) plus reasons to rationalizehellip
Excipient Functionality Can be critical for safety efficacy and quality
3122015 Ajaz S Hussain PhD 37
July 15 2005 FDA Public Health Advisory Safety Warnings Regarding Use of Fentanyl Transdermal (Skin) Patches
A pattern of failure Pharmaceutical Equivalence by Design (2004)
3122015 Ajaz S Hussain PhD 38
httpwwwnihsgojpdrugPhForumdocuments041122Hussain041122pdf
An attempt to correct
3122015 Ajaz S Hussain PhD 39
httpipecamericasorgsystemfilesKeyNoteEF13May11LawrenceYu(FDA)pdf
Recent challenges
3122015 Ajaz S Hussain PhD 40
Th
e V
oic
e o
f th
eA
mer
ican
P
sych
iatr
ic A
sso
ciat
ion
and
th
e P
sych
iatr
ic C
om
mu
nit
y
Physicians Question FDAs Confidence in Generic Drugs Safety Efficacy (OCTOBER 24 2014)
bull ldquomost patientsrdquo is not the same asldquo all patientsrdquo and whether the 24 to 36 normal subjects used in the agencys bioequivalency tests represents the full range of individual variation in the way drugs are absorbed across the pharmaceutical using population is uncertain
bull Individuals can sometimes be allergic and react differently to whatever substance goes into making up the capsule or the tablet
FDA Flags Generic Versions of ADHD Medication(NOVEMBER 14 2014)
bull FDA changed the therapeutic equivalence (TE) rating from AB to BXmdashmeaning that the products are still approved and can be prescribed but are no longer recommended as automatic substitutes
RLD Variability Can be a block-buster opportunityFocus on lsquocontrol strategyrsquo
bull Overcoming CP amp IP provide FDA a submission they need to address CP
bull Then begin with QTPP CQArsquos hellip skip lsquodesign spacersquo and focus on lsquocontrol strategy
bull The entire development team should read the complete package insert of RLD
bull Discuss to ensure a common understandingbull Failure modes amp intended use
bull Pharmaceutical Equivalence
bull Bioequivalence
bull Other studies
QbD Challenges
3122015 Ajaz S Hussain PhD 41
NewRegulators are not prepared to handle QbD applications
NewMisalignment of international regulatory authorities
New and Generics
RampD incentivized for lsquoshots on the goalrsquo not QbD
GenericsLack of belief in business case ndash lsquoGenerics are all about file first figure out laterrsquo
Biologics Lack of technology to execute
Ted Fuhr Mackinsey amp Company June 2010 FDA Advisory Committee
Summary
bull Excipient functionality can contribute in critical ways to product quality amp performance adequate control is necessary
bull Our databases tools and knowledge are lagging behind the rapidly increasing complexity and uncertainty
bull Risk to quality and to business is increasing and regulatory transitions pose additional difficulties
bull Effective knowledge management ndash IT and Human practices ndash is critical for organizational lsquobottom-linersquo
bull We all must come together collaboratively to address the urgent needs we owe it to the patients we serve
3122015 Ajaz S Hussain PhD 42
Knowledge Management amp Culture of Quality
Ajaz S Hussain PhD
Insight Advice amp Solutions LLCMaryland USA
Executive Director the National Institute for Pharmaceutical Technology amp Education
3122015 Ajaz S Hussain PhD 43
3122015 Ajaz S Hussain PhD 44
Life-cycle approach needed for knowledge management
Investigational ProductscGMPs
DevelopmentTechnology
TransferCommercial
ManufacturingDiscontinuation
Management Responsibility
Process Performance amp Product Quality Monitoring SystemCAPA Change Management Management Review
PQS Elements
Knowledge ManagementQuality Risk ManagementEnablers
ICH Q10 KM is a systematic approach to acquiring analyzing storing and disseminating information related to products manufacturing processes and components
Based on ICH Q10
ldquowe can be blind to the obvious and we are also blind to our blindnessrdquo
Daniel Kahneman Thinking Fast and Slow
3142015 Ajazajazhussaincom 45
httpwebmiteduperscipeopleadelsoncheckershadow_proofhtml
3122015 Ajaz S Hussain PhD 46
1938 The Federal Food Drug and Cosmetic (FDC)
bull 1937 Elixir of Sulfanilamide
1962 Kefauver-Harris Drug Amendments
bull 1962 Thalidomide
bull 1960 Color Additive Amendment
bull 1958 Food Additives Amendment GRAS
bull 1960 Color Additive Amendment
bull 1958 Food Additives Amendment GRAS
1992 Generic Drug Enforcement Act
bull1989 L-Tryptophan
bull 1989 Generic Drug Scandal
bull 1988 Food and Drug Administration Act
bull 1984 Fines Enhancement Laws Drug Price Competition and Patent Term Restoration Act
2012 Food and Drug Administration Safety and Innovation Act (FDASIA)
bull 2007 Heparin Disaster
2013 Pandemic and All-Hazards Preparedness Reauthorization Act (PAHPRA) Drug Quality and Security Act
bull 2012 The Deadly Meningitis Outbreak
Past 70 years 1937 ndash 2007 The diethylene glycol (DEG) narrative
3122015 Ajaz S Hussain PhD 47
0
5
10
15
20
25
30
35
Yea
rs
DEG Years since the previous incident
0
50
100
150
200
250
300
350
Number of Reported Deaths
1937
Eli
xir
of
Sulf
anil
amid
e
2007T
ootp
aste
conta
min
atio
n
0 70 years 0 70 years
Frequent reports
Mumbai Mumbai
Data from Excipient Fest Janeen Skutnik Chair ndashIPECAmericas 2009
Past 70+ years DEG contamination or economically motivated adulteration
3122015 Ajaz S Hussain PhD 48
Reported cases underestimate the real tragedy rapid intervention may not occur
Epidemic of Pediatric Deaths From Acute Renal Failure Caused by
Diethylene Glycol Poisoning JAMA 1998279(15)1175-1180
doi101001jama279151175
Month of hospital admission for children with
acute renal failure Haiti
October 1995-October 1996
Diethylene glycol poisoning in Gurgaon India 1998Bulletin of the World Health Organization 2001 79 88ndash95
We report a second episode of poisoning occurring in 1998 in
India as a result of children ingesting diethylene glycol at
least 33 children are known to have died
At the beginning of the investigation we never imagined that
contaminated medicine was causing acute renal failure in
children
A brand of cough expectorant manufactured by a local
pharmaceutical company was found by the Central Drugs
Laboratory Calcutta to contain 175 (vv) diethylene
glycol
The district and state drug controller had tested many
samples using thin layer chromatography before a sample of
medicine tested positive for diethylene glycol at the Central
Drugs Laboratory None of the earlier samples was found to
be contaminated
3122015 Ajaz S Hussain PhD 49
Guidance for Industry Testing of
Glycerin for Diethylene Glycol
CDER May 2007 Compliance
1 Manufacturers did not perform full
identity testing on the glycerin raw
material including tests to quantify
the amount of DEG
2 Relied on the certificate of analysis
(COA)
3 The origin of the glycerin was not
easily apparent from the COA
4 The COA was often a copy of a COA
on the letterhead of the distributor
5 The chain of custody or distribution
history of the glycerin was also not
readily known
USP Glycerin Monograph
Type of Posting Revision Bulletin
Posting Date 04ndashFebndash2009
Official Date 01ndashMayndash2009
Because of the serious hazards
associated withhellip and in response to
recommendations set forth in the
FDA Guidance for Industry Testing
of Glycerin for Diethylene Glycol
published in May 2007 USP has
revised the USP Glycerin monograph
Because diethylene glycol and
ethylene glycol are considered
unacceptable toxic substances the
testing of USP Glycerin should
demonstrate the absence of these
substances
April 2007 FDA request to
USP to revise the Glycerin
monographrsquos
IDENTIFICATION section
Revision includes adding ndash
Identification test B LIMIT OF
DIETHYLENE GLYCOL AND
ETHYLENE GLYCOL to detect
and quantify DEGEG in Glycerin
minus Is no longer part of the impurity
testing
ldquoLimit of DEG and Related
Compoundsrdquo minus Introduces a
capillary gas-chromatographic
(GC) method with flame ionization
detection (FID) minus Limit of NMT
010 each for diethylene glycol
and ethylene glycol is found
70+ years to get here how difficult will it be to change habits such as lsquoblind reliance of COArsquo
3122015 Ajaz S Hussain PhD 50
Personality and Habitual Frame Biases
Myers Brigs ENTJ (first tested at FDA)
S
TF
Expanded frame
future
possibilities
objective lsquocause
and effectrsquo
Expanded frame
future
possibilities
people and
relationships
Narrow frame
the present
individuals and
relationships
Narrow frame
the present
objective
cause and
effect
N
Based on Stanford Webinar - How to Overcome the Top 3 MegaBiases in Decision-Making
Stanford Universityrsquos Strategic Decision and Risk Management certificate program
From Mapping a Managers Brain on Incentives
Social
influences
Relative
thinking
UncertaintyComplexity
By Design Intention to act consciously
bull In the interest of patients and to continually improve this ability bull To provide a healing touch ndash one life at a time in what we do and how we
do it
1292014 Ajazajazhussaincom 51
Consciously
Scientific methodology
Engineering Design
Plan-Do-Check-Act
Subconsciously
Habits (work to get rid of bad ones)
Habits (work to cultivate good one)
Keystone habits (Safety Alcoa ALCOA of data integrity)
The Power of Habit Why We Do What We Do in Life and Business Charles Duhigg (2012)
httpwwwslideshareneta2zpharmscipharmaceutical-culture-of-quality
What does it take to come out of the cGMP crisis
Persuasive demonstration of
(1) Ability to face facts
(2) Legal amp regulatory requirements
3) Systems approach to quality
4) Changing behavior amp culture
What is often missed or is unconvincing is how you will strengthen culture of quality
ldquoLet one who wants to move and convince others first be convinced and moved themselvesrdquo Thomas Carlyle
Signals that question the competence motivation andor integrity of company personnel
Do not defend the plainly indefensible it adds further serious credibility costs
3142015 Ajazajazhussaincom 52
Quality is everyones responsibility
Lack of knowledge that is
the problem
If you do not know how to ask the
right question you discover nothing
If you cant describe what you
are doing as a process you dont know what youre
doing
Rational behavior requires theory
Reactive behavior requires only reflex
action
Whenever there is fear you will get wrong figures
3142015 Ajazajazhussaincom 53
Selected quotes W Edwards Deming
3142015 Ajazajazhussaincom 54
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
ldquoWE CANNOT CHANGE THE HUMAN CONDITION BUThellipWE CAN CHANGE THE CONDITIONS UNDER WHICH HUMANS WORKrdquo JAMES REASON
Disregard to Malice
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 55
ldquohelliprecords not completed
contemporaneouslyrdquo
ldquohellipobserved analyst back-date logbooksrdquo
ldquohelliptrial injectionshelliprdquo
ldquohellipresults failing specifications are
retested until acceptable results are obtainedhelliprdquo
ldquohellipover-writing electronic raw datahelliprdquo
ldquohellipOOS not investigates per XYZ SOPrdquo
ldquohellipappropriate controls not establishedhelliprdquo
Each additional observation adds
reasons to confirm that this is very likely a system
with intentional lsquoholesrsquo in its
defenses
Preconditions
Rationalization amp Attitude
Pressure amp Incentive
Opportunity ndashlsquoholes in the QMSrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 56
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 57
Attitude towards the behavior
Subjective norm
Perceived behavioral
control
IntentionFuture
Behavior
usually found to predict behavioral intentions with a high degree of accuracy
intentions in combination with perceived behavioral control can account for a considerable proportion of variance in behavior
PastBehavior
Ajen I The theory of planned behavior ORGANIZATIONAL BEHAVIOR AND HUMAN DECISION PROCESSES 50 179-211 (1991)
Heparin tragedy 2007 and 2008
FDA reports 149 deaths with allergic or hypersensitivity symptoms during that period
bull Contaminated heparin from China
QC Testing
bull Initial testing failed to detect the contaminant
Pharmacovigilence
bull Signals in the pharmacovigilence systems responded slowly and
Eventually the severity of reactions associated made it likely that the contamination would be detected
bull too late for those who died or were injured
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 58
Congressman Shimkus When the drug safety system fails people get sick Some die
bull Some of these people are already very vulnerable and proving the cause of harm from impurities adulteration and counterfeits can be elusive
It is hard to detect harm
bull Certainly the companies are obligated to ensure a culture of quality and maintain vigilance as well This reflects a systems approach to safety
FDA inspectors look for a culture of quality at
manufacturing facilities
bull FDA policies led to the failure to inspect the Chinese plantThis system approach wasnt at
play here
bull While it doesnt deny the counterfeit source tries to say that counterfeits didnt cause the reaction as if the adulteration itself was no big deal Is this an acceptable mindset helliphelliphellip
This brings me to China and its quality culture or lack thereof
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 59
ONE HUNDRED TENTH CONGRESS SECOND SESSION APRIL 29 2008 Serial No 110-109
21 CFR PART 211 SUBPARTS -Deviations signal gaps in CoQ
bullGENERAL PROVISIONSA
bullORGANIZATION AND PERSONNELB
bullBUILDINGS AND FACILITIESC
bullEQUIPMENTD
bullCONTROL OF COMPONENTS AND DRUG PRODUCT CONTAINERS AND CLOSURESE
bullPRODUCTION AND PROCESS CONTROLSF
bullPACKAGING AND LABELING CONTROLG
bullHOLDING AND DISTRIBUTIONH
bullLABORATORY CONTROLSI
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 60
For example the combinationhellip
The Power of Habit Why We Do What We Do in Life and Business Charles Duhigg (2012)
bull Scientific methodology
bull Engineering Design
bull Plan-Do-Check-ActConsciously
bull Habits (work to get rid of bad ones)
bull Habits (work to cultivate good one)
bull Keystone habits (Safety Alcoa ALCOA of data integrity)
Subconsciously
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 61
CoQ How
bull What are the predictors of CoQCoQ Manifests by Design -
lsquoquality by designrsquo the foundation
bull 1 2 3When do people change their behaviors
bull A B C D (any body can dance)What makes a QMS effective
bull X Y ZWhen proactive compliance occurs
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 62
Going beyond rules pays
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 63
Human behavior Connecting the Dots With the Right Connectors
GXPs ndash rational behaviors
How proactive compliance is achieved X Y Z
Quality Management System
What makes a QMS reliable A B C D
Culture of Quality
Why people change their behavior 1 2 3
Human Behaviors Beyond GXPs
Predictors of Culture of Quality
Why What and How of Culture of Quality
9192014 copy Ajaz S Hussain | INSIGHT ADVICE amp SOLUTIONS LLC 64
Predictors of CoQ Act consciously in the interest of patients ndash when no one is looking
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 65
Only four attributes
actually predict a culture of
quality
Leadership Emphasis
Message Credibility
Peer Involvement
Employee Empower-ment
People will change their
behavior if they see the new behavior as
Normal
(1)
Rewarding
(2)
Easy
(3)
Dr W Edwards Demingrsquos - ldquoOut of the crisisrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 66
The journey requires leadership
with Profound Knowledge as a
guide
bull As leaders responsible for system change top management is most in need of profound knowledge
bull Quality is often determined in the boardroom
bull Problems arise when management reacts to common cause or chance variation as if it were special cause variation
bull Prediction based in theory provides a foundation for planning a course of action Plan ndash Do ndash Check ndash Act
bull The leader serves the people with clear vision and guidance to empower them To be empowered is to share ownership in the identity
bull Giving people a certain degree of control over their work fulfills the need for freedom and provides opportunity for taking joy in work
Profound Knowledge as a guide
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 67
Appreciation for a System
Theory of Knowledge
Knowledge about
Variation
Human Behavior -Psychology of Change
A
B
C
D+
Systems Approach for ErrorDeviation Management
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 68
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
Human error models and management J Reason BMJ 320 768ndash770 (2000)
D+
Culture of Error Management परबधनbull Error strain
bull Covering upFear of Errors
bull Anticipation
bull Risk takingAwareness
bull Development QbDRFT
bull Error detection Communication
bull Analyzing errors Correction
Mastery orientation
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 69
Dots amp Connections
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 70
CoQ
1
2
3
QMS
A
B
C
D
GXP Behaviors
X
Y
Z
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 71
Culture of Quality
Normal
Rewarding
Easy
QMS
System
Knowledge
Variation
Behavior
Behavior -GXPs
Fear Removed
Mastery
Awareness
EnvironmentLeadership Emphasis
Message Credibility
Peer Involvement
Employee Empowerment
Connect to CoQ
Connect to GXPs
A Framework and a Tool (for gap analysis)
My interest in [lsquoexcipientsrsquo] KMacknowledging experiences contributing to my current thinking
bull Business decisions
bull Regulatory research policy amp enforcement
bull Academic research
3122015 Ajaz S Hussain PhD 5
Business decisions
bull Management responsibilitiesbull VP amp Global Head Biopharmaceutical Development Sandoz (2005-2009)
bull Developmentregulatory submission Omnitropereg Binocritreg Zarzioreg Generic Enoxaparin amp Glatiramer acetate
bull VP Next Generation Product Assessment amp CSO Philip Morris International (2009 -2012)
bull Developmentevidence qualityregulatory strategy Plant based vaccines amp assessment of products intended for tobacco harm reduction
bull President Biotechnology amp CSO Wockhardt (2012-2013)
bull Biosimilar and Complex Generic Strategy Improvement
bull AdvisoryConsulting (2013 ndash currently)
bull Mitigating risks in development of complex products Framework for effective compliance amp remediation Strengthening Culture of Quality
3122015 Ajaz S Hussain PhD 6
Regulatory research policy amp enforcement support US FDA (1995 ndash 2005)
bull Research to Policybull SUPAC BCS IVIVC hellipTopical Microbicideshellipseveral others
bull Policybull SUPAC-MR IVIVC BCS helliphellip PAT ICH FDA Lead (Quality) ndash
ldquodesired state for 21st Centuryrdquo ICH Q8 ndash 10
bull Enforcement Supportbull Expert witness for the prosecution (1995)
bull Facilitating resolution of difficult WLs linked to shortages
3122015 Ajaz S Hussain PhD 7
Knowledge to inform policy improvement
3122015 Ajaz S Hussain PhD 8
Physical Attributes Can be critical for safety efficacy and quality
3122015 Ajaz S Hussain PhD 9
July 15 2005 FDA Public Health Advisory Safety Warnings Regarding Use of Fentanyl Transdermal (Skin) Patches
Also relevant today Pattern Recognition
3122015 Ajaz S Hussain PhD 10
Preliminary illustration of a concept Going forward expect to see regulators utilize state-of ndashthe ndashart pattern recognition and modeling systems
Effective Regulatory System Importance of Process Understanding and Quality by DesignAjaz Hussain Pharmaceutical Quality Forum 3rd Symposium November 2004 Tokyo Japan
Academic research
University of Cincinnati (1989-1994)
bull Formulation designbull Several projects ndash oral topical and
transdermalbull Example Elaborating the utility of
Transcutolreg (Gattefosseacute)
bull Computer aided formulation designbull Artificial Neural Network based
lsquoexpert systemsrsquobull Example Prototype for lsquoTechnical
Service Supportrsquo (funding - Aqualon)
NIPTE (Currently)
bull NIPTErsquos Excipient Knowledge basebull Available since 2007 at
httppharmahuborg
bull The goal of this project is to share information and modeling tools to support pharmaceutical product
3122015 Ajaz S Hussain PhD 11
Prototype for lsquoTechnical Service Supportrsquo
3122015 Ajaz S Hussain PhD 12
From a lsquoDatabasersquo to a lsquoKnowledge basersquo
bull lsquoLook-up tablesrsquo to lsquoAbility to Predictrsquo
bull Ability to predict = generate hypotheses
bull Ability (simulate) ask questions - what if
NIPTE Knowledge Management
3122015 Ajaz S Hussain PhD 13
Contact Prof Hoag Univ Maryland shoagrxumarylandedu
3122015 Ajaz S Hussain PhD 14
NIPTE Knowledge Management
This study was funded by the FDA-sponsored contract ldquoDevelopment of Quality by Design (QbD) Guidance Elements on Design Specifications across Scales with Stability Considerationsrdquo (contract number HHSF223200819929C)
3122015 Ajaz S Hussain PhD 15
Current hot topics ndashrsquoexcipientsrsquo regulatory trends amp insights ExcipientFest on 28-29 April 2015 in Washington Organizational Changes CDERFDA and Inspectional Trendshellip(Complex Genericshellip Continuous Manufacturing)
3122015 Ajaz S Hussain PhD 16
Current experience with lsquoSupplier Qualificationrsquo
bull Recent observations are summarized in this report by ECA Academy (21012015) Areas of attention
bull Accuracy and completeness of administrative documentation
bull Evidence to justify excipient and supplier qualification
bull Risk-assessment and effective integration within in QMS
bull Quality agreements
bull Going forward I envision a need to emphasize a life-cycle approach (eg linking to CAPA change control)
3122015 Ajaz S Hussain PhD 17
FDArsquos Inactive Ingredient Database -statusbull Substance Registration System (SRS)
bull Generic listing vs Specific Grade listing for commonly used excipients ndashmax precedent levels
bull Listing of Mixtures
bull The UNII code confusing the National Library of Medicine yet to finalize standards for assigning UNII codes for polymers
bull Individual Grades vs Family Data
bull Legal status of the IID and FDA communications of changes to the IID
bull DMF Implications
bull Impact on ANDAs ndash lsquoDelaysrsquo amp lsquoRefuse to File Lettersrsquo
3122015 Ajaz S Hussain PhD 18
3122015 Ajaz S Hussain PhD 19
Inactive Ingredientsrsquo to lsquoExcipientsrsquo to lsquoFunctionalityrsquo Where are we in this journeylsquo
Status of lsquoSubstances In Regulatory Practicersquo
Clearly we need a global database with improved precision and accuracy of naming (and coding) to identify describe compare and link (to products and AERs)
INDs NDAs BLAs CFRrsquos Orphan Drug ApplicationsProducts that Contain Each Substance
Pharmacological ClassificationActive Moieties Related Moieties and Salts
LADMERMetabolites
Metabolic Enzymes Transporters and EffectsDrug target (therapeutic and other) type of interaction
Solubility and Permeability (BCS)Protein Binding
Impurities and Related Substance
ISO 11238 (ISO IDMP) some challenges
Both substances amp specified substances
Implementation in EU EMA Task force
Global Ingredients Archive System (GInAS)
3122015 Ajaz S Hussain PhD 20
The War Against Fake Medicines Update on FDASIA - Guidance and Impact on Excipient Suppliers and
Users QbD Sampling Guidelines The NSFIPECANSI 363 2014 GMP standardsexplained Good Supply Practices ndash Using Cross Industry Knowledge to Devise Pragmatic Solutions Impact
of Non-harmonized Standards and What is Needed to Achieve Harmonization Advancements in the Question Based Review approach and various other excipient specific related topics An Overview of the FDA OGD
IID EWG activities Effective Sourcing and Purchasing of Excipients
Industry Collaboration for Science Based Implementation of Elemental Impurities Challenges And Opportunities In Developing
And Modernizing Public Standards For NF Excipients Monographs For Regulated Drug
Products Marketed In The USA Future Pharma Manufacturing Efficiencies and the Role of Innovative Excipient Technologies
IPEC ExcipientFest 2015
Current Hot Topics ExcipientFest on 28-29 April 2015 in Washington
3122015 Ajaz S Hussain PhD 21
The War Against Fake Medicines Update on FDASIA - Guidance and Impact on Excipient
Suppliers and Users QbD Sampling Guidelines The NSFIPECANSI 363 2014 GMP standards explained Good Supply Practices ndash Using Cross Industry Knowledge to Devise
Pragmatic Solutions Impact of Non-harmonized Standards and What is Needed to Achieve
Harmonization Advancements in the Question Based Review approach and various other
excipient specific related topics An Overview of the FDA OGD IID EWG activities Effective
Sourcing and Purchasing of Excipients Industry Collaboration for Science Based Implementation of Elemental Impurities Challenges And
Opportunities In Developing And Modernizing Public Standards For NF ExcipientsMonographs For Regulated Drug Products Marketed In The USA Future Pharma Manufacturing Efficiencies and the Role of Innovative Excipient Technologies
IPEC ExcipientFest 2015
Inspectional trends in data integrity (Bangalore Nov
2014)
22(d)
192
100(a)
160(b)
110(a)
67(b)
68(a)
25(a)
67(a)
100(b)
Recurring 483 Observations Top 10
22(d) 192 100(a) 160(b)110(a) 67(b) 68(a) 25(a)67(a) 100(b)
Jeff Medwid NIPTE-FDA Conference 13 June 2012
International Society for Pharmaceutical Engineering (ISPE) in conjunction with McKinsey amp Co will release preliminary data and findings from its Quality Metrics Pilot Program at the ISPE Quality Metrics Summit on April 21ndash22 in Baltimore
FDA Launches New Drug Quality Office With Goal of Improving the Pharmaceutical IndustryPosted 13 January 2015By Alexander Gaffney RAC
FDArsquos New Pharma Quality
Office Will Take a Team Approach
Yu Explains
Regulatory Recon Investigations Find Major Quality Problems at Indian Pharma Companies (3 December 2014)Posted 03 December 2014By Alexander Gaffney RAC
Currently the environment is complex there is high uncertainty D
on
rsquot f
org
et
fun
ctio
na
lity
o
f e
xcip
ien
ts i
s im
po
rta
nt
3122015 Ajaz S Hussain PhD 22
Need for urgent progress lsquoInactive Ingredientsrsquo to lsquoExcipientsrsquo to lsquoFunctional Excipientsrsquo
Importance of assuring quality and controlling
variability of excipients
including their lsquofunctionalityrsquo has
long been recognized
bull Increasing complexity of drugs their delivery and failure modes
bull Patient (eg pediatric) relevant failure modes
bull Simple generics to complex generics amp biosimilars
Urgent need to address gaps in the FDArsquos Inactive Ingredient Database
3122015 Ajaz S Hussain PhD 23
Trends Lab amp Manufacturing
ldquoDeletion of Datardquo
ldquoTesting Into Compliancerdquo
ldquoBMR manipulation is a slippery sloperdquo
ldquoSuggestive of faulty manufacturing process or practices even if this is not the caserdquo
ldquoIt is top managementrsquos responsibility to ensure the training program is robust and effectiverdquo
Inspectional trends in data integrity (Bangalore Nov 13 2014 - Nov 14 2014)
Growing concern some
companies ldquodata looks too good
to be truerdquo
3122015 Ajaz S Hussain PhD 24
GMP Compliance amp Remediation
Jeff Medwid NIPTE-FDA Conference 13 June 2012
QbD amp QbR Clarity on Critical Functionality
FDArsquos New Pharma Quality
Office Will Take a Team
Approach Yu Explains
Carmelo Rosa MS PsyD November 2014
Urgent Need amp Opportunity
To align amp ensure sound scientific basis of these critical regulatory decisions
FDA CDER OPQ Plans for Surveillance of Pharmaceutical Quality
Teresa Mullin PhD December 2014
3122015 Ajaz S Hussain PhD 25
Need for a comprehensive (excipient) knowledge base
Teresa Mullin PhD December 2014
3122015 Ajaz S Hussain PhD 26
Why attention to (excipient) knowledge management is criticalSpecifically for physical attributes functionality performance
3122015 Ajaz S Hussain PhD 27
3122015 Ajaz S Hussain PhD 28
Today there are several product categories (eg controlled release inhalation products DPIrsquos topical transdermal liposomal products etc) which requires an exquisite control of complex physical material and product attributes (functionality)
Many of our current measurement systems need improvement
We depend on these to ensure control of lot-lot variability
Measurement system capability must be confirmed to be able to assess process capability (calibration amp Gauge RampR)
Life-cycle approach to quality continued process verification (FDArsquos Process Validation 2011) is a safety net
Supplier amp Excipient Qualification amp Process Validation
Measurement System Analysis
bull From lsquocalibrationrsquo to lsquoGauge RampRrsquoParticularly for physical
attributes destructive analysis
bull Many (including regulators) have not yet understood its importance
Gauge RampR well established but not commonly practiced
bull Measurement system in a state of control effective CAPA quality metrics Culture of Quality
With the move towards Statistical Process Control
bull Demonstrate equivalent in vitro performance more exacting criteria
Development of complex generic products (ER
Injectable Inhalation etc)
3122015 Ajaz S Hussain PhD 29
Process Validation (2011) Statistical Confidence Continued Process Verificationhellip
3122015 Ajaz S Hussain PhD 30
httpwwwslideshareneta2zpharmsciperformance-testing-pharmaceutical-quality-2004(accessed 6 December 2014)
3122015 Ajaz S Hussain PhD 31
Supplier amp Excipient Qualification amp CAPA
Out of Specification events are difficult to resolve
Excipient functionality can be a significant contributing factor
Sometimes reluctantly have to settle with - ldquoRoot cause unknown
600 days
I have inserted the ldquo600 daysrsquo on the figure ndash this is based on cases I have seen while at FDA)
3122015 Ajaz S Hussain PhD 32
Prevention of OOS and Effective CAPA needs a focus on critical functional attributes
Out of Specification events are difficult to resolve
Excipient functionality can be a significant contributing factor
Sometimes reluctantly have to settle with - ldquoRoot cause unknown
Compendial standards and manufacturing
3122015 Ajaz S Hussain PhD 33
Practice Control Process Maturity
Initial
bull Unpredictable
Managed
bull Characterized but reactive
Defined
bull Characterized proactive
Measured amp Controlled
bull In control
Optimizing
bull Focus on improvement
3122015 Ajaz S Hussain PhD 34
Capability Maturity Model Integration Carnegie Mellon University
A validated process
Maturity Level amp Assurance of Quality
Managed Characterized but reactive
High perceived risk of
lsquoCheating by Designrsquo
ldquoTrial Injectionsrdquo
ldquoTesting in to Compliancerdquo
Defined Characterized proactive
Lower level of assurance
Stopping amp Correcting
Batch Rejection
Measured amp
ControlledIn control
Quality by Design
Quality Assured
Improvement Opportunities
3122015 Ajaz S Hussain PhD 35
At the individual level in QC functionndash how often does this occur
attitude toward
performing the behavior
Process validation is
done so quality is good
test prone to error
ldquoBatch failure means I made
a mistakerdquo
subjective norm
documentation not critical
Compendial testing
sufficient
Indian regulators
collect amp test samples ndash no issue there
3122015 Ajaz S Hussain PhD 36
ldquoTesting into compliancerdquo
In general ndash low empowerment is a significant challenge (low perceived behavioral control) plus reasons to rationalizehellip
Excipient Functionality Can be critical for safety efficacy and quality
3122015 Ajaz S Hussain PhD 37
July 15 2005 FDA Public Health Advisory Safety Warnings Regarding Use of Fentanyl Transdermal (Skin) Patches
A pattern of failure Pharmaceutical Equivalence by Design (2004)
3122015 Ajaz S Hussain PhD 38
httpwwwnihsgojpdrugPhForumdocuments041122Hussain041122pdf
An attempt to correct
3122015 Ajaz S Hussain PhD 39
httpipecamericasorgsystemfilesKeyNoteEF13May11LawrenceYu(FDA)pdf
Recent challenges
3122015 Ajaz S Hussain PhD 40
Th
e V
oic
e o
f th
eA
mer
ican
P
sych
iatr
ic A
sso
ciat
ion
and
th
e P
sych
iatr
ic C
om
mu
nit
y
Physicians Question FDAs Confidence in Generic Drugs Safety Efficacy (OCTOBER 24 2014)
bull ldquomost patientsrdquo is not the same asldquo all patientsrdquo and whether the 24 to 36 normal subjects used in the agencys bioequivalency tests represents the full range of individual variation in the way drugs are absorbed across the pharmaceutical using population is uncertain
bull Individuals can sometimes be allergic and react differently to whatever substance goes into making up the capsule or the tablet
FDA Flags Generic Versions of ADHD Medication(NOVEMBER 14 2014)
bull FDA changed the therapeutic equivalence (TE) rating from AB to BXmdashmeaning that the products are still approved and can be prescribed but are no longer recommended as automatic substitutes
RLD Variability Can be a block-buster opportunityFocus on lsquocontrol strategyrsquo
bull Overcoming CP amp IP provide FDA a submission they need to address CP
bull Then begin with QTPP CQArsquos hellip skip lsquodesign spacersquo and focus on lsquocontrol strategy
bull The entire development team should read the complete package insert of RLD
bull Discuss to ensure a common understandingbull Failure modes amp intended use
bull Pharmaceutical Equivalence
bull Bioequivalence
bull Other studies
QbD Challenges
3122015 Ajaz S Hussain PhD 41
NewRegulators are not prepared to handle QbD applications
NewMisalignment of international regulatory authorities
New and Generics
RampD incentivized for lsquoshots on the goalrsquo not QbD
GenericsLack of belief in business case ndash lsquoGenerics are all about file first figure out laterrsquo
Biologics Lack of technology to execute
Ted Fuhr Mackinsey amp Company June 2010 FDA Advisory Committee
Summary
bull Excipient functionality can contribute in critical ways to product quality amp performance adequate control is necessary
bull Our databases tools and knowledge are lagging behind the rapidly increasing complexity and uncertainty
bull Risk to quality and to business is increasing and regulatory transitions pose additional difficulties
bull Effective knowledge management ndash IT and Human practices ndash is critical for organizational lsquobottom-linersquo
bull We all must come together collaboratively to address the urgent needs we owe it to the patients we serve
3122015 Ajaz S Hussain PhD 42
Knowledge Management amp Culture of Quality
Ajaz S Hussain PhD
Insight Advice amp Solutions LLCMaryland USA
Executive Director the National Institute for Pharmaceutical Technology amp Education
3122015 Ajaz S Hussain PhD 43
3122015 Ajaz S Hussain PhD 44
Life-cycle approach needed for knowledge management
Investigational ProductscGMPs
DevelopmentTechnology
TransferCommercial
ManufacturingDiscontinuation
Management Responsibility
Process Performance amp Product Quality Monitoring SystemCAPA Change Management Management Review
PQS Elements
Knowledge ManagementQuality Risk ManagementEnablers
ICH Q10 KM is a systematic approach to acquiring analyzing storing and disseminating information related to products manufacturing processes and components
Based on ICH Q10
ldquowe can be blind to the obvious and we are also blind to our blindnessrdquo
Daniel Kahneman Thinking Fast and Slow
3142015 Ajazajazhussaincom 45
httpwebmiteduperscipeopleadelsoncheckershadow_proofhtml
3122015 Ajaz S Hussain PhD 46
1938 The Federal Food Drug and Cosmetic (FDC)
bull 1937 Elixir of Sulfanilamide
1962 Kefauver-Harris Drug Amendments
bull 1962 Thalidomide
bull 1960 Color Additive Amendment
bull 1958 Food Additives Amendment GRAS
bull 1960 Color Additive Amendment
bull 1958 Food Additives Amendment GRAS
1992 Generic Drug Enforcement Act
bull1989 L-Tryptophan
bull 1989 Generic Drug Scandal
bull 1988 Food and Drug Administration Act
bull 1984 Fines Enhancement Laws Drug Price Competition and Patent Term Restoration Act
2012 Food and Drug Administration Safety and Innovation Act (FDASIA)
bull 2007 Heparin Disaster
2013 Pandemic and All-Hazards Preparedness Reauthorization Act (PAHPRA) Drug Quality and Security Act
bull 2012 The Deadly Meningitis Outbreak
Past 70 years 1937 ndash 2007 The diethylene glycol (DEG) narrative
3122015 Ajaz S Hussain PhD 47
0
5
10
15
20
25
30
35
Yea
rs
DEG Years since the previous incident
0
50
100
150
200
250
300
350
Number of Reported Deaths
1937
Eli
xir
of
Sulf
anil
amid
e
2007T
ootp
aste
conta
min
atio
n
0 70 years 0 70 years
Frequent reports
Mumbai Mumbai
Data from Excipient Fest Janeen Skutnik Chair ndashIPECAmericas 2009
Past 70+ years DEG contamination or economically motivated adulteration
3122015 Ajaz S Hussain PhD 48
Reported cases underestimate the real tragedy rapid intervention may not occur
Epidemic of Pediatric Deaths From Acute Renal Failure Caused by
Diethylene Glycol Poisoning JAMA 1998279(15)1175-1180
doi101001jama279151175
Month of hospital admission for children with
acute renal failure Haiti
October 1995-October 1996
Diethylene glycol poisoning in Gurgaon India 1998Bulletin of the World Health Organization 2001 79 88ndash95
We report a second episode of poisoning occurring in 1998 in
India as a result of children ingesting diethylene glycol at
least 33 children are known to have died
At the beginning of the investigation we never imagined that
contaminated medicine was causing acute renal failure in
children
A brand of cough expectorant manufactured by a local
pharmaceutical company was found by the Central Drugs
Laboratory Calcutta to contain 175 (vv) diethylene
glycol
The district and state drug controller had tested many
samples using thin layer chromatography before a sample of
medicine tested positive for diethylene glycol at the Central
Drugs Laboratory None of the earlier samples was found to
be contaminated
3122015 Ajaz S Hussain PhD 49
Guidance for Industry Testing of
Glycerin for Diethylene Glycol
CDER May 2007 Compliance
1 Manufacturers did not perform full
identity testing on the glycerin raw
material including tests to quantify
the amount of DEG
2 Relied on the certificate of analysis
(COA)
3 The origin of the glycerin was not
easily apparent from the COA
4 The COA was often a copy of a COA
on the letterhead of the distributor
5 The chain of custody or distribution
history of the glycerin was also not
readily known
USP Glycerin Monograph
Type of Posting Revision Bulletin
Posting Date 04ndashFebndash2009
Official Date 01ndashMayndash2009
Because of the serious hazards
associated withhellip and in response to
recommendations set forth in the
FDA Guidance for Industry Testing
of Glycerin for Diethylene Glycol
published in May 2007 USP has
revised the USP Glycerin monograph
Because diethylene glycol and
ethylene glycol are considered
unacceptable toxic substances the
testing of USP Glycerin should
demonstrate the absence of these
substances
April 2007 FDA request to
USP to revise the Glycerin
monographrsquos
IDENTIFICATION section
Revision includes adding ndash
Identification test B LIMIT OF
DIETHYLENE GLYCOL AND
ETHYLENE GLYCOL to detect
and quantify DEGEG in Glycerin
minus Is no longer part of the impurity
testing
ldquoLimit of DEG and Related
Compoundsrdquo minus Introduces a
capillary gas-chromatographic
(GC) method with flame ionization
detection (FID) minus Limit of NMT
010 each for diethylene glycol
and ethylene glycol is found
70+ years to get here how difficult will it be to change habits such as lsquoblind reliance of COArsquo
3122015 Ajaz S Hussain PhD 50
Personality and Habitual Frame Biases
Myers Brigs ENTJ (first tested at FDA)
S
TF
Expanded frame
future
possibilities
objective lsquocause
and effectrsquo
Expanded frame
future
possibilities
people and
relationships
Narrow frame
the present
individuals and
relationships
Narrow frame
the present
objective
cause and
effect
N
Based on Stanford Webinar - How to Overcome the Top 3 MegaBiases in Decision-Making
Stanford Universityrsquos Strategic Decision and Risk Management certificate program
From Mapping a Managers Brain on Incentives
Social
influences
Relative
thinking
UncertaintyComplexity
By Design Intention to act consciously
bull In the interest of patients and to continually improve this ability bull To provide a healing touch ndash one life at a time in what we do and how we
do it
1292014 Ajazajazhussaincom 51
Consciously
Scientific methodology
Engineering Design
Plan-Do-Check-Act
Subconsciously
Habits (work to get rid of bad ones)
Habits (work to cultivate good one)
Keystone habits (Safety Alcoa ALCOA of data integrity)
The Power of Habit Why We Do What We Do in Life and Business Charles Duhigg (2012)
httpwwwslideshareneta2zpharmscipharmaceutical-culture-of-quality
What does it take to come out of the cGMP crisis
Persuasive demonstration of
(1) Ability to face facts
(2) Legal amp regulatory requirements
3) Systems approach to quality
4) Changing behavior amp culture
What is often missed or is unconvincing is how you will strengthen culture of quality
ldquoLet one who wants to move and convince others first be convinced and moved themselvesrdquo Thomas Carlyle
Signals that question the competence motivation andor integrity of company personnel
Do not defend the plainly indefensible it adds further serious credibility costs
3142015 Ajazajazhussaincom 52
Quality is everyones responsibility
Lack of knowledge that is
the problem
If you do not know how to ask the
right question you discover nothing
If you cant describe what you
are doing as a process you dont know what youre
doing
Rational behavior requires theory
Reactive behavior requires only reflex
action
Whenever there is fear you will get wrong figures
3142015 Ajazajazhussaincom 53
Selected quotes W Edwards Deming
3142015 Ajazajazhussaincom 54
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
ldquoWE CANNOT CHANGE THE HUMAN CONDITION BUThellipWE CAN CHANGE THE CONDITIONS UNDER WHICH HUMANS WORKrdquo JAMES REASON
Disregard to Malice
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 55
ldquohelliprecords not completed
contemporaneouslyrdquo
ldquohellipobserved analyst back-date logbooksrdquo
ldquohelliptrial injectionshelliprdquo
ldquohellipresults failing specifications are
retested until acceptable results are obtainedhelliprdquo
ldquohellipover-writing electronic raw datahelliprdquo
ldquohellipOOS not investigates per XYZ SOPrdquo
ldquohellipappropriate controls not establishedhelliprdquo
Each additional observation adds
reasons to confirm that this is very likely a system
with intentional lsquoholesrsquo in its
defenses
Preconditions
Rationalization amp Attitude
Pressure amp Incentive
Opportunity ndashlsquoholes in the QMSrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 56
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 57
Attitude towards the behavior
Subjective norm
Perceived behavioral
control
IntentionFuture
Behavior
usually found to predict behavioral intentions with a high degree of accuracy
intentions in combination with perceived behavioral control can account for a considerable proportion of variance in behavior
PastBehavior
Ajen I The theory of planned behavior ORGANIZATIONAL BEHAVIOR AND HUMAN DECISION PROCESSES 50 179-211 (1991)
Heparin tragedy 2007 and 2008
FDA reports 149 deaths with allergic or hypersensitivity symptoms during that period
bull Contaminated heparin from China
QC Testing
bull Initial testing failed to detect the contaminant
Pharmacovigilence
bull Signals in the pharmacovigilence systems responded slowly and
Eventually the severity of reactions associated made it likely that the contamination would be detected
bull too late for those who died or were injured
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 58
Congressman Shimkus When the drug safety system fails people get sick Some die
bull Some of these people are already very vulnerable and proving the cause of harm from impurities adulteration and counterfeits can be elusive
It is hard to detect harm
bull Certainly the companies are obligated to ensure a culture of quality and maintain vigilance as well This reflects a systems approach to safety
FDA inspectors look for a culture of quality at
manufacturing facilities
bull FDA policies led to the failure to inspect the Chinese plantThis system approach wasnt at
play here
bull While it doesnt deny the counterfeit source tries to say that counterfeits didnt cause the reaction as if the adulteration itself was no big deal Is this an acceptable mindset helliphelliphellip
This brings me to China and its quality culture or lack thereof
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 59
ONE HUNDRED TENTH CONGRESS SECOND SESSION APRIL 29 2008 Serial No 110-109
21 CFR PART 211 SUBPARTS -Deviations signal gaps in CoQ
bullGENERAL PROVISIONSA
bullORGANIZATION AND PERSONNELB
bullBUILDINGS AND FACILITIESC
bullEQUIPMENTD
bullCONTROL OF COMPONENTS AND DRUG PRODUCT CONTAINERS AND CLOSURESE
bullPRODUCTION AND PROCESS CONTROLSF
bullPACKAGING AND LABELING CONTROLG
bullHOLDING AND DISTRIBUTIONH
bullLABORATORY CONTROLSI
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 60
For example the combinationhellip
The Power of Habit Why We Do What We Do in Life and Business Charles Duhigg (2012)
bull Scientific methodology
bull Engineering Design
bull Plan-Do-Check-ActConsciously
bull Habits (work to get rid of bad ones)
bull Habits (work to cultivate good one)
bull Keystone habits (Safety Alcoa ALCOA of data integrity)
Subconsciously
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 61
CoQ How
bull What are the predictors of CoQCoQ Manifests by Design -
lsquoquality by designrsquo the foundation
bull 1 2 3When do people change their behaviors
bull A B C D (any body can dance)What makes a QMS effective
bull X Y ZWhen proactive compliance occurs
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 62
Going beyond rules pays
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 63
Human behavior Connecting the Dots With the Right Connectors
GXPs ndash rational behaviors
How proactive compliance is achieved X Y Z
Quality Management System
What makes a QMS reliable A B C D
Culture of Quality
Why people change their behavior 1 2 3
Human Behaviors Beyond GXPs
Predictors of Culture of Quality
Why What and How of Culture of Quality
9192014 copy Ajaz S Hussain | INSIGHT ADVICE amp SOLUTIONS LLC 64
Predictors of CoQ Act consciously in the interest of patients ndash when no one is looking
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 65
Only four attributes
actually predict a culture of
quality
Leadership Emphasis
Message Credibility
Peer Involvement
Employee Empower-ment
People will change their
behavior if they see the new behavior as
Normal
(1)
Rewarding
(2)
Easy
(3)
Dr W Edwards Demingrsquos - ldquoOut of the crisisrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 66
The journey requires leadership
with Profound Knowledge as a
guide
bull As leaders responsible for system change top management is most in need of profound knowledge
bull Quality is often determined in the boardroom
bull Problems arise when management reacts to common cause or chance variation as if it were special cause variation
bull Prediction based in theory provides a foundation for planning a course of action Plan ndash Do ndash Check ndash Act
bull The leader serves the people with clear vision and guidance to empower them To be empowered is to share ownership in the identity
bull Giving people a certain degree of control over their work fulfills the need for freedom and provides opportunity for taking joy in work
Profound Knowledge as a guide
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 67
Appreciation for a System
Theory of Knowledge
Knowledge about
Variation
Human Behavior -Psychology of Change
A
B
C
D+
Systems Approach for ErrorDeviation Management
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 68
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
Human error models and management J Reason BMJ 320 768ndash770 (2000)
D+
Culture of Error Management परबधनbull Error strain
bull Covering upFear of Errors
bull Anticipation
bull Risk takingAwareness
bull Development QbDRFT
bull Error detection Communication
bull Analyzing errors Correction
Mastery orientation
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 69
Dots amp Connections
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 70
CoQ
1
2
3
QMS
A
B
C
D
GXP Behaviors
X
Y
Z
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 71
Culture of Quality
Normal
Rewarding
Easy
QMS
System
Knowledge
Variation
Behavior
Behavior -GXPs
Fear Removed
Mastery
Awareness
EnvironmentLeadership Emphasis
Message Credibility
Peer Involvement
Employee Empowerment
Connect to CoQ
Connect to GXPs
A Framework and a Tool (for gap analysis)
Business decisions
bull Management responsibilitiesbull VP amp Global Head Biopharmaceutical Development Sandoz (2005-2009)
bull Developmentregulatory submission Omnitropereg Binocritreg Zarzioreg Generic Enoxaparin amp Glatiramer acetate
bull VP Next Generation Product Assessment amp CSO Philip Morris International (2009 -2012)
bull Developmentevidence qualityregulatory strategy Plant based vaccines amp assessment of products intended for tobacco harm reduction
bull President Biotechnology amp CSO Wockhardt (2012-2013)
bull Biosimilar and Complex Generic Strategy Improvement
bull AdvisoryConsulting (2013 ndash currently)
bull Mitigating risks in development of complex products Framework for effective compliance amp remediation Strengthening Culture of Quality
3122015 Ajaz S Hussain PhD 6
Regulatory research policy amp enforcement support US FDA (1995 ndash 2005)
bull Research to Policybull SUPAC BCS IVIVC hellipTopical Microbicideshellipseveral others
bull Policybull SUPAC-MR IVIVC BCS helliphellip PAT ICH FDA Lead (Quality) ndash
ldquodesired state for 21st Centuryrdquo ICH Q8 ndash 10
bull Enforcement Supportbull Expert witness for the prosecution (1995)
bull Facilitating resolution of difficult WLs linked to shortages
3122015 Ajaz S Hussain PhD 7
Knowledge to inform policy improvement
3122015 Ajaz S Hussain PhD 8
Physical Attributes Can be critical for safety efficacy and quality
3122015 Ajaz S Hussain PhD 9
July 15 2005 FDA Public Health Advisory Safety Warnings Regarding Use of Fentanyl Transdermal (Skin) Patches
Also relevant today Pattern Recognition
3122015 Ajaz S Hussain PhD 10
Preliminary illustration of a concept Going forward expect to see regulators utilize state-of ndashthe ndashart pattern recognition and modeling systems
Effective Regulatory System Importance of Process Understanding and Quality by DesignAjaz Hussain Pharmaceutical Quality Forum 3rd Symposium November 2004 Tokyo Japan
Academic research
University of Cincinnati (1989-1994)
bull Formulation designbull Several projects ndash oral topical and
transdermalbull Example Elaborating the utility of
Transcutolreg (Gattefosseacute)
bull Computer aided formulation designbull Artificial Neural Network based
lsquoexpert systemsrsquobull Example Prototype for lsquoTechnical
Service Supportrsquo (funding - Aqualon)
NIPTE (Currently)
bull NIPTErsquos Excipient Knowledge basebull Available since 2007 at
httppharmahuborg
bull The goal of this project is to share information and modeling tools to support pharmaceutical product
3122015 Ajaz S Hussain PhD 11
Prototype for lsquoTechnical Service Supportrsquo
3122015 Ajaz S Hussain PhD 12
From a lsquoDatabasersquo to a lsquoKnowledge basersquo
bull lsquoLook-up tablesrsquo to lsquoAbility to Predictrsquo
bull Ability to predict = generate hypotheses
bull Ability (simulate) ask questions - what if
NIPTE Knowledge Management
3122015 Ajaz S Hussain PhD 13
Contact Prof Hoag Univ Maryland shoagrxumarylandedu
3122015 Ajaz S Hussain PhD 14
NIPTE Knowledge Management
This study was funded by the FDA-sponsored contract ldquoDevelopment of Quality by Design (QbD) Guidance Elements on Design Specifications across Scales with Stability Considerationsrdquo (contract number HHSF223200819929C)
3122015 Ajaz S Hussain PhD 15
Current hot topics ndashrsquoexcipientsrsquo regulatory trends amp insights ExcipientFest on 28-29 April 2015 in Washington Organizational Changes CDERFDA and Inspectional Trendshellip(Complex Genericshellip Continuous Manufacturing)
3122015 Ajaz S Hussain PhD 16
Current experience with lsquoSupplier Qualificationrsquo
bull Recent observations are summarized in this report by ECA Academy (21012015) Areas of attention
bull Accuracy and completeness of administrative documentation
bull Evidence to justify excipient and supplier qualification
bull Risk-assessment and effective integration within in QMS
bull Quality agreements
bull Going forward I envision a need to emphasize a life-cycle approach (eg linking to CAPA change control)
3122015 Ajaz S Hussain PhD 17
FDArsquos Inactive Ingredient Database -statusbull Substance Registration System (SRS)
bull Generic listing vs Specific Grade listing for commonly used excipients ndashmax precedent levels
bull Listing of Mixtures
bull The UNII code confusing the National Library of Medicine yet to finalize standards for assigning UNII codes for polymers
bull Individual Grades vs Family Data
bull Legal status of the IID and FDA communications of changes to the IID
bull DMF Implications
bull Impact on ANDAs ndash lsquoDelaysrsquo amp lsquoRefuse to File Lettersrsquo
3122015 Ajaz S Hussain PhD 18
3122015 Ajaz S Hussain PhD 19
Inactive Ingredientsrsquo to lsquoExcipientsrsquo to lsquoFunctionalityrsquo Where are we in this journeylsquo
Status of lsquoSubstances In Regulatory Practicersquo
Clearly we need a global database with improved precision and accuracy of naming (and coding) to identify describe compare and link (to products and AERs)
INDs NDAs BLAs CFRrsquos Orphan Drug ApplicationsProducts that Contain Each Substance
Pharmacological ClassificationActive Moieties Related Moieties and Salts
LADMERMetabolites
Metabolic Enzymes Transporters and EffectsDrug target (therapeutic and other) type of interaction
Solubility and Permeability (BCS)Protein Binding
Impurities and Related Substance
ISO 11238 (ISO IDMP) some challenges
Both substances amp specified substances
Implementation in EU EMA Task force
Global Ingredients Archive System (GInAS)
3122015 Ajaz S Hussain PhD 20
The War Against Fake Medicines Update on FDASIA - Guidance and Impact on Excipient Suppliers and
Users QbD Sampling Guidelines The NSFIPECANSI 363 2014 GMP standardsexplained Good Supply Practices ndash Using Cross Industry Knowledge to Devise Pragmatic Solutions Impact
of Non-harmonized Standards and What is Needed to Achieve Harmonization Advancements in the Question Based Review approach and various other excipient specific related topics An Overview of the FDA OGD
IID EWG activities Effective Sourcing and Purchasing of Excipients
Industry Collaboration for Science Based Implementation of Elemental Impurities Challenges And Opportunities In Developing
And Modernizing Public Standards For NF Excipients Monographs For Regulated Drug
Products Marketed In The USA Future Pharma Manufacturing Efficiencies and the Role of Innovative Excipient Technologies
IPEC ExcipientFest 2015
Current Hot Topics ExcipientFest on 28-29 April 2015 in Washington
3122015 Ajaz S Hussain PhD 21
The War Against Fake Medicines Update on FDASIA - Guidance and Impact on Excipient
Suppliers and Users QbD Sampling Guidelines The NSFIPECANSI 363 2014 GMP standards explained Good Supply Practices ndash Using Cross Industry Knowledge to Devise
Pragmatic Solutions Impact of Non-harmonized Standards and What is Needed to Achieve
Harmonization Advancements in the Question Based Review approach and various other
excipient specific related topics An Overview of the FDA OGD IID EWG activities Effective
Sourcing and Purchasing of Excipients Industry Collaboration for Science Based Implementation of Elemental Impurities Challenges And
Opportunities In Developing And Modernizing Public Standards For NF ExcipientsMonographs For Regulated Drug Products Marketed In The USA Future Pharma Manufacturing Efficiencies and the Role of Innovative Excipient Technologies
IPEC ExcipientFest 2015
Inspectional trends in data integrity (Bangalore Nov
2014)
22(d)
192
100(a)
160(b)
110(a)
67(b)
68(a)
25(a)
67(a)
100(b)
Recurring 483 Observations Top 10
22(d) 192 100(a) 160(b)110(a) 67(b) 68(a) 25(a)67(a) 100(b)
Jeff Medwid NIPTE-FDA Conference 13 June 2012
International Society for Pharmaceutical Engineering (ISPE) in conjunction with McKinsey amp Co will release preliminary data and findings from its Quality Metrics Pilot Program at the ISPE Quality Metrics Summit on April 21ndash22 in Baltimore
FDA Launches New Drug Quality Office With Goal of Improving the Pharmaceutical IndustryPosted 13 January 2015By Alexander Gaffney RAC
FDArsquos New Pharma Quality
Office Will Take a Team Approach
Yu Explains
Regulatory Recon Investigations Find Major Quality Problems at Indian Pharma Companies (3 December 2014)Posted 03 December 2014By Alexander Gaffney RAC
Currently the environment is complex there is high uncertainty D
on
rsquot f
org
et
fun
ctio
na
lity
o
f e
xcip
ien
ts i
s im
po
rta
nt
3122015 Ajaz S Hussain PhD 22
Need for urgent progress lsquoInactive Ingredientsrsquo to lsquoExcipientsrsquo to lsquoFunctional Excipientsrsquo
Importance of assuring quality and controlling
variability of excipients
including their lsquofunctionalityrsquo has
long been recognized
bull Increasing complexity of drugs their delivery and failure modes
bull Patient (eg pediatric) relevant failure modes
bull Simple generics to complex generics amp biosimilars
Urgent need to address gaps in the FDArsquos Inactive Ingredient Database
3122015 Ajaz S Hussain PhD 23
Trends Lab amp Manufacturing
ldquoDeletion of Datardquo
ldquoTesting Into Compliancerdquo
ldquoBMR manipulation is a slippery sloperdquo
ldquoSuggestive of faulty manufacturing process or practices even if this is not the caserdquo
ldquoIt is top managementrsquos responsibility to ensure the training program is robust and effectiverdquo
Inspectional trends in data integrity (Bangalore Nov 13 2014 - Nov 14 2014)
Growing concern some
companies ldquodata looks too good
to be truerdquo
3122015 Ajaz S Hussain PhD 24
GMP Compliance amp Remediation
Jeff Medwid NIPTE-FDA Conference 13 June 2012
QbD amp QbR Clarity on Critical Functionality
FDArsquos New Pharma Quality
Office Will Take a Team
Approach Yu Explains
Carmelo Rosa MS PsyD November 2014
Urgent Need amp Opportunity
To align amp ensure sound scientific basis of these critical regulatory decisions
FDA CDER OPQ Plans for Surveillance of Pharmaceutical Quality
Teresa Mullin PhD December 2014
3122015 Ajaz S Hussain PhD 25
Need for a comprehensive (excipient) knowledge base
Teresa Mullin PhD December 2014
3122015 Ajaz S Hussain PhD 26
Why attention to (excipient) knowledge management is criticalSpecifically for physical attributes functionality performance
3122015 Ajaz S Hussain PhD 27
3122015 Ajaz S Hussain PhD 28
Today there are several product categories (eg controlled release inhalation products DPIrsquos topical transdermal liposomal products etc) which requires an exquisite control of complex physical material and product attributes (functionality)
Many of our current measurement systems need improvement
We depend on these to ensure control of lot-lot variability
Measurement system capability must be confirmed to be able to assess process capability (calibration amp Gauge RampR)
Life-cycle approach to quality continued process verification (FDArsquos Process Validation 2011) is a safety net
Supplier amp Excipient Qualification amp Process Validation
Measurement System Analysis
bull From lsquocalibrationrsquo to lsquoGauge RampRrsquoParticularly for physical
attributes destructive analysis
bull Many (including regulators) have not yet understood its importance
Gauge RampR well established but not commonly practiced
bull Measurement system in a state of control effective CAPA quality metrics Culture of Quality
With the move towards Statistical Process Control
bull Demonstrate equivalent in vitro performance more exacting criteria
Development of complex generic products (ER
Injectable Inhalation etc)
3122015 Ajaz S Hussain PhD 29
Process Validation (2011) Statistical Confidence Continued Process Verificationhellip
3122015 Ajaz S Hussain PhD 30
httpwwwslideshareneta2zpharmsciperformance-testing-pharmaceutical-quality-2004(accessed 6 December 2014)
3122015 Ajaz S Hussain PhD 31
Supplier amp Excipient Qualification amp CAPA
Out of Specification events are difficult to resolve
Excipient functionality can be a significant contributing factor
Sometimes reluctantly have to settle with - ldquoRoot cause unknown
600 days
I have inserted the ldquo600 daysrsquo on the figure ndash this is based on cases I have seen while at FDA)
3122015 Ajaz S Hussain PhD 32
Prevention of OOS and Effective CAPA needs a focus on critical functional attributes
Out of Specification events are difficult to resolve
Excipient functionality can be a significant contributing factor
Sometimes reluctantly have to settle with - ldquoRoot cause unknown
Compendial standards and manufacturing
3122015 Ajaz S Hussain PhD 33
Practice Control Process Maturity
Initial
bull Unpredictable
Managed
bull Characterized but reactive
Defined
bull Characterized proactive
Measured amp Controlled
bull In control
Optimizing
bull Focus on improvement
3122015 Ajaz S Hussain PhD 34
Capability Maturity Model Integration Carnegie Mellon University
A validated process
Maturity Level amp Assurance of Quality
Managed Characterized but reactive
High perceived risk of
lsquoCheating by Designrsquo
ldquoTrial Injectionsrdquo
ldquoTesting in to Compliancerdquo
Defined Characterized proactive
Lower level of assurance
Stopping amp Correcting
Batch Rejection
Measured amp
ControlledIn control
Quality by Design
Quality Assured
Improvement Opportunities
3122015 Ajaz S Hussain PhD 35
At the individual level in QC functionndash how often does this occur
attitude toward
performing the behavior
Process validation is
done so quality is good
test prone to error
ldquoBatch failure means I made
a mistakerdquo
subjective norm
documentation not critical
Compendial testing
sufficient
Indian regulators
collect amp test samples ndash no issue there
3122015 Ajaz S Hussain PhD 36
ldquoTesting into compliancerdquo
In general ndash low empowerment is a significant challenge (low perceived behavioral control) plus reasons to rationalizehellip
Excipient Functionality Can be critical for safety efficacy and quality
3122015 Ajaz S Hussain PhD 37
July 15 2005 FDA Public Health Advisory Safety Warnings Regarding Use of Fentanyl Transdermal (Skin) Patches
A pattern of failure Pharmaceutical Equivalence by Design (2004)
3122015 Ajaz S Hussain PhD 38
httpwwwnihsgojpdrugPhForumdocuments041122Hussain041122pdf
An attempt to correct
3122015 Ajaz S Hussain PhD 39
httpipecamericasorgsystemfilesKeyNoteEF13May11LawrenceYu(FDA)pdf
Recent challenges
3122015 Ajaz S Hussain PhD 40
Th
e V
oic
e o
f th
eA
mer
ican
P
sych
iatr
ic A
sso
ciat
ion
and
th
e P
sych
iatr
ic C
om
mu
nit
y
Physicians Question FDAs Confidence in Generic Drugs Safety Efficacy (OCTOBER 24 2014)
bull ldquomost patientsrdquo is not the same asldquo all patientsrdquo and whether the 24 to 36 normal subjects used in the agencys bioequivalency tests represents the full range of individual variation in the way drugs are absorbed across the pharmaceutical using population is uncertain
bull Individuals can sometimes be allergic and react differently to whatever substance goes into making up the capsule or the tablet
FDA Flags Generic Versions of ADHD Medication(NOVEMBER 14 2014)
bull FDA changed the therapeutic equivalence (TE) rating from AB to BXmdashmeaning that the products are still approved and can be prescribed but are no longer recommended as automatic substitutes
RLD Variability Can be a block-buster opportunityFocus on lsquocontrol strategyrsquo
bull Overcoming CP amp IP provide FDA a submission they need to address CP
bull Then begin with QTPP CQArsquos hellip skip lsquodesign spacersquo and focus on lsquocontrol strategy
bull The entire development team should read the complete package insert of RLD
bull Discuss to ensure a common understandingbull Failure modes amp intended use
bull Pharmaceutical Equivalence
bull Bioequivalence
bull Other studies
QbD Challenges
3122015 Ajaz S Hussain PhD 41
NewRegulators are not prepared to handle QbD applications
NewMisalignment of international regulatory authorities
New and Generics
RampD incentivized for lsquoshots on the goalrsquo not QbD
GenericsLack of belief in business case ndash lsquoGenerics are all about file first figure out laterrsquo
Biologics Lack of technology to execute
Ted Fuhr Mackinsey amp Company June 2010 FDA Advisory Committee
Summary
bull Excipient functionality can contribute in critical ways to product quality amp performance adequate control is necessary
bull Our databases tools and knowledge are lagging behind the rapidly increasing complexity and uncertainty
bull Risk to quality and to business is increasing and regulatory transitions pose additional difficulties
bull Effective knowledge management ndash IT and Human practices ndash is critical for organizational lsquobottom-linersquo
bull We all must come together collaboratively to address the urgent needs we owe it to the patients we serve
3122015 Ajaz S Hussain PhD 42
Knowledge Management amp Culture of Quality
Ajaz S Hussain PhD
Insight Advice amp Solutions LLCMaryland USA
Executive Director the National Institute for Pharmaceutical Technology amp Education
3122015 Ajaz S Hussain PhD 43
3122015 Ajaz S Hussain PhD 44
Life-cycle approach needed for knowledge management
Investigational ProductscGMPs
DevelopmentTechnology
TransferCommercial
ManufacturingDiscontinuation
Management Responsibility
Process Performance amp Product Quality Monitoring SystemCAPA Change Management Management Review
PQS Elements
Knowledge ManagementQuality Risk ManagementEnablers
ICH Q10 KM is a systematic approach to acquiring analyzing storing and disseminating information related to products manufacturing processes and components
Based on ICH Q10
ldquowe can be blind to the obvious and we are also blind to our blindnessrdquo
Daniel Kahneman Thinking Fast and Slow
3142015 Ajazajazhussaincom 45
httpwebmiteduperscipeopleadelsoncheckershadow_proofhtml
3122015 Ajaz S Hussain PhD 46
1938 The Federal Food Drug and Cosmetic (FDC)
bull 1937 Elixir of Sulfanilamide
1962 Kefauver-Harris Drug Amendments
bull 1962 Thalidomide
bull 1960 Color Additive Amendment
bull 1958 Food Additives Amendment GRAS
bull 1960 Color Additive Amendment
bull 1958 Food Additives Amendment GRAS
1992 Generic Drug Enforcement Act
bull1989 L-Tryptophan
bull 1989 Generic Drug Scandal
bull 1988 Food and Drug Administration Act
bull 1984 Fines Enhancement Laws Drug Price Competition and Patent Term Restoration Act
2012 Food and Drug Administration Safety and Innovation Act (FDASIA)
bull 2007 Heparin Disaster
2013 Pandemic and All-Hazards Preparedness Reauthorization Act (PAHPRA) Drug Quality and Security Act
bull 2012 The Deadly Meningitis Outbreak
Past 70 years 1937 ndash 2007 The diethylene glycol (DEG) narrative
3122015 Ajaz S Hussain PhD 47
0
5
10
15
20
25
30
35
Yea
rs
DEG Years since the previous incident
0
50
100
150
200
250
300
350
Number of Reported Deaths
1937
Eli
xir
of
Sulf
anil
amid
e
2007T
ootp
aste
conta
min
atio
n
0 70 years 0 70 years
Frequent reports
Mumbai Mumbai
Data from Excipient Fest Janeen Skutnik Chair ndashIPECAmericas 2009
Past 70+ years DEG contamination or economically motivated adulteration
3122015 Ajaz S Hussain PhD 48
Reported cases underestimate the real tragedy rapid intervention may not occur
Epidemic of Pediatric Deaths From Acute Renal Failure Caused by
Diethylene Glycol Poisoning JAMA 1998279(15)1175-1180
doi101001jama279151175
Month of hospital admission for children with
acute renal failure Haiti
October 1995-October 1996
Diethylene glycol poisoning in Gurgaon India 1998Bulletin of the World Health Organization 2001 79 88ndash95
We report a second episode of poisoning occurring in 1998 in
India as a result of children ingesting diethylene glycol at
least 33 children are known to have died
At the beginning of the investigation we never imagined that
contaminated medicine was causing acute renal failure in
children
A brand of cough expectorant manufactured by a local
pharmaceutical company was found by the Central Drugs
Laboratory Calcutta to contain 175 (vv) diethylene
glycol
The district and state drug controller had tested many
samples using thin layer chromatography before a sample of
medicine tested positive for diethylene glycol at the Central
Drugs Laboratory None of the earlier samples was found to
be contaminated
3122015 Ajaz S Hussain PhD 49
Guidance for Industry Testing of
Glycerin for Diethylene Glycol
CDER May 2007 Compliance
1 Manufacturers did not perform full
identity testing on the glycerin raw
material including tests to quantify
the amount of DEG
2 Relied on the certificate of analysis
(COA)
3 The origin of the glycerin was not
easily apparent from the COA
4 The COA was often a copy of a COA
on the letterhead of the distributor
5 The chain of custody or distribution
history of the glycerin was also not
readily known
USP Glycerin Monograph
Type of Posting Revision Bulletin
Posting Date 04ndashFebndash2009
Official Date 01ndashMayndash2009
Because of the serious hazards
associated withhellip and in response to
recommendations set forth in the
FDA Guidance for Industry Testing
of Glycerin for Diethylene Glycol
published in May 2007 USP has
revised the USP Glycerin monograph
Because diethylene glycol and
ethylene glycol are considered
unacceptable toxic substances the
testing of USP Glycerin should
demonstrate the absence of these
substances
April 2007 FDA request to
USP to revise the Glycerin
monographrsquos
IDENTIFICATION section
Revision includes adding ndash
Identification test B LIMIT OF
DIETHYLENE GLYCOL AND
ETHYLENE GLYCOL to detect
and quantify DEGEG in Glycerin
minus Is no longer part of the impurity
testing
ldquoLimit of DEG and Related
Compoundsrdquo minus Introduces a
capillary gas-chromatographic
(GC) method with flame ionization
detection (FID) minus Limit of NMT
010 each for diethylene glycol
and ethylene glycol is found
70+ years to get here how difficult will it be to change habits such as lsquoblind reliance of COArsquo
3122015 Ajaz S Hussain PhD 50
Personality and Habitual Frame Biases
Myers Brigs ENTJ (first tested at FDA)
S
TF
Expanded frame
future
possibilities
objective lsquocause
and effectrsquo
Expanded frame
future
possibilities
people and
relationships
Narrow frame
the present
individuals and
relationships
Narrow frame
the present
objective
cause and
effect
N
Based on Stanford Webinar - How to Overcome the Top 3 MegaBiases in Decision-Making
Stanford Universityrsquos Strategic Decision and Risk Management certificate program
From Mapping a Managers Brain on Incentives
Social
influences
Relative
thinking
UncertaintyComplexity
By Design Intention to act consciously
bull In the interest of patients and to continually improve this ability bull To provide a healing touch ndash one life at a time in what we do and how we
do it
1292014 Ajazajazhussaincom 51
Consciously
Scientific methodology
Engineering Design
Plan-Do-Check-Act
Subconsciously
Habits (work to get rid of bad ones)
Habits (work to cultivate good one)
Keystone habits (Safety Alcoa ALCOA of data integrity)
The Power of Habit Why We Do What We Do in Life and Business Charles Duhigg (2012)
httpwwwslideshareneta2zpharmscipharmaceutical-culture-of-quality
What does it take to come out of the cGMP crisis
Persuasive demonstration of
(1) Ability to face facts
(2) Legal amp regulatory requirements
3) Systems approach to quality
4) Changing behavior amp culture
What is often missed or is unconvincing is how you will strengthen culture of quality
ldquoLet one who wants to move and convince others first be convinced and moved themselvesrdquo Thomas Carlyle
Signals that question the competence motivation andor integrity of company personnel
Do not defend the plainly indefensible it adds further serious credibility costs
3142015 Ajazajazhussaincom 52
Quality is everyones responsibility
Lack of knowledge that is
the problem
If you do not know how to ask the
right question you discover nothing
If you cant describe what you
are doing as a process you dont know what youre
doing
Rational behavior requires theory
Reactive behavior requires only reflex
action
Whenever there is fear you will get wrong figures
3142015 Ajazajazhussaincom 53
Selected quotes W Edwards Deming
3142015 Ajazajazhussaincom 54
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
ldquoWE CANNOT CHANGE THE HUMAN CONDITION BUThellipWE CAN CHANGE THE CONDITIONS UNDER WHICH HUMANS WORKrdquo JAMES REASON
Disregard to Malice
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 55
ldquohelliprecords not completed
contemporaneouslyrdquo
ldquohellipobserved analyst back-date logbooksrdquo
ldquohelliptrial injectionshelliprdquo
ldquohellipresults failing specifications are
retested until acceptable results are obtainedhelliprdquo
ldquohellipover-writing electronic raw datahelliprdquo
ldquohellipOOS not investigates per XYZ SOPrdquo
ldquohellipappropriate controls not establishedhelliprdquo
Each additional observation adds
reasons to confirm that this is very likely a system
with intentional lsquoholesrsquo in its
defenses
Preconditions
Rationalization amp Attitude
Pressure amp Incentive
Opportunity ndashlsquoholes in the QMSrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 56
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 57
Attitude towards the behavior
Subjective norm
Perceived behavioral
control
IntentionFuture
Behavior
usually found to predict behavioral intentions with a high degree of accuracy
intentions in combination with perceived behavioral control can account for a considerable proportion of variance in behavior
PastBehavior
Ajen I The theory of planned behavior ORGANIZATIONAL BEHAVIOR AND HUMAN DECISION PROCESSES 50 179-211 (1991)
Heparin tragedy 2007 and 2008
FDA reports 149 deaths with allergic or hypersensitivity symptoms during that period
bull Contaminated heparin from China
QC Testing
bull Initial testing failed to detect the contaminant
Pharmacovigilence
bull Signals in the pharmacovigilence systems responded slowly and
Eventually the severity of reactions associated made it likely that the contamination would be detected
bull too late for those who died or were injured
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 58
Congressman Shimkus When the drug safety system fails people get sick Some die
bull Some of these people are already very vulnerable and proving the cause of harm from impurities adulteration and counterfeits can be elusive
It is hard to detect harm
bull Certainly the companies are obligated to ensure a culture of quality and maintain vigilance as well This reflects a systems approach to safety
FDA inspectors look for a culture of quality at
manufacturing facilities
bull FDA policies led to the failure to inspect the Chinese plantThis system approach wasnt at
play here
bull While it doesnt deny the counterfeit source tries to say that counterfeits didnt cause the reaction as if the adulteration itself was no big deal Is this an acceptable mindset helliphelliphellip
This brings me to China and its quality culture or lack thereof
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 59
ONE HUNDRED TENTH CONGRESS SECOND SESSION APRIL 29 2008 Serial No 110-109
21 CFR PART 211 SUBPARTS -Deviations signal gaps in CoQ
bullGENERAL PROVISIONSA
bullORGANIZATION AND PERSONNELB
bullBUILDINGS AND FACILITIESC
bullEQUIPMENTD
bullCONTROL OF COMPONENTS AND DRUG PRODUCT CONTAINERS AND CLOSURESE
bullPRODUCTION AND PROCESS CONTROLSF
bullPACKAGING AND LABELING CONTROLG
bullHOLDING AND DISTRIBUTIONH
bullLABORATORY CONTROLSI
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 60
For example the combinationhellip
The Power of Habit Why We Do What We Do in Life and Business Charles Duhigg (2012)
bull Scientific methodology
bull Engineering Design
bull Plan-Do-Check-ActConsciously
bull Habits (work to get rid of bad ones)
bull Habits (work to cultivate good one)
bull Keystone habits (Safety Alcoa ALCOA of data integrity)
Subconsciously
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 61
CoQ How
bull What are the predictors of CoQCoQ Manifests by Design -
lsquoquality by designrsquo the foundation
bull 1 2 3When do people change their behaviors
bull A B C D (any body can dance)What makes a QMS effective
bull X Y ZWhen proactive compliance occurs
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 62
Going beyond rules pays
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 63
Human behavior Connecting the Dots With the Right Connectors
GXPs ndash rational behaviors
How proactive compliance is achieved X Y Z
Quality Management System
What makes a QMS reliable A B C D
Culture of Quality
Why people change their behavior 1 2 3
Human Behaviors Beyond GXPs
Predictors of Culture of Quality
Why What and How of Culture of Quality
9192014 copy Ajaz S Hussain | INSIGHT ADVICE amp SOLUTIONS LLC 64
Predictors of CoQ Act consciously in the interest of patients ndash when no one is looking
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 65
Only four attributes
actually predict a culture of
quality
Leadership Emphasis
Message Credibility
Peer Involvement
Employee Empower-ment
People will change their
behavior if they see the new behavior as
Normal
(1)
Rewarding
(2)
Easy
(3)
Dr W Edwards Demingrsquos - ldquoOut of the crisisrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 66
The journey requires leadership
with Profound Knowledge as a
guide
bull As leaders responsible for system change top management is most in need of profound knowledge
bull Quality is often determined in the boardroom
bull Problems arise when management reacts to common cause or chance variation as if it were special cause variation
bull Prediction based in theory provides a foundation for planning a course of action Plan ndash Do ndash Check ndash Act
bull The leader serves the people with clear vision and guidance to empower them To be empowered is to share ownership in the identity
bull Giving people a certain degree of control over their work fulfills the need for freedom and provides opportunity for taking joy in work
Profound Knowledge as a guide
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 67
Appreciation for a System
Theory of Knowledge
Knowledge about
Variation
Human Behavior -Psychology of Change
A
B
C
D+
Systems Approach for ErrorDeviation Management
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 68
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
Human error models and management J Reason BMJ 320 768ndash770 (2000)
D+
Culture of Error Management परबधनbull Error strain
bull Covering upFear of Errors
bull Anticipation
bull Risk takingAwareness
bull Development QbDRFT
bull Error detection Communication
bull Analyzing errors Correction
Mastery orientation
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 69
Dots amp Connections
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 70
CoQ
1
2
3
QMS
A
B
C
D
GXP Behaviors
X
Y
Z
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 71
Culture of Quality
Normal
Rewarding
Easy
QMS
System
Knowledge
Variation
Behavior
Behavior -GXPs
Fear Removed
Mastery
Awareness
EnvironmentLeadership Emphasis
Message Credibility
Peer Involvement
Employee Empowerment
Connect to CoQ
Connect to GXPs
A Framework and a Tool (for gap analysis)
Regulatory research policy amp enforcement support US FDA (1995 ndash 2005)
bull Research to Policybull SUPAC BCS IVIVC hellipTopical Microbicideshellipseveral others
bull Policybull SUPAC-MR IVIVC BCS helliphellip PAT ICH FDA Lead (Quality) ndash
ldquodesired state for 21st Centuryrdquo ICH Q8 ndash 10
bull Enforcement Supportbull Expert witness for the prosecution (1995)
bull Facilitating resolution of difficult WLs linked to shortages
3122015 Ajaz S Hussain PhD 7
Knowledge to inform policy improvement
3122015 Ajaz S Hussain PhD 8
Physical Attributes Can be critical for safety efficacy and quality
3122015 Ajaz S Hussain PhD 9
July 15 2005 FDA Public Health Advisory Safety Warnings Regarding Use of Fentanyl Transdermal (Skin) Patches
Also relevant today Pattern Recognition
3122015 Ajaz S Hussain PhD 10
Preliminary illustration of a concept Going forward expect to see regulators utilize state-of ndashthe ndashart pattern recognition and modeling systems
Effective Regulatory System Importance of Process Understanding and Quality by DesignAjaz Hussain Pharmaceutical Quality Forum 3rd Symposium November 2004 Tokyo Japan
Academic research
University of Cincinnati (1989-1994)
bull Formulation designbull Several projects ndash oral topical and
transdermalbull Example Elaborating the utility of
Transcutolreg (Gattefosseacute)
bull Computer aided formulation designbull Artificial Neural Network based
lsquoexpert systemsrsquobull Example Prototype for lsquoTechnical
Service Supportrsquo (funding - Aqualon)
NIPTE (Currently)
bull NIPTErsquos Excipient Knowledge basebull Available since 2007 at
httppharmahuborg
bull The goal of this project is to share information and modeling tools to support pharmaceutical product
3122015 Ajaz S Hussain PhD 11
Prototype for lsquoTechnical Service Supportrsquo
3122015 Ajaz S Hussain PhD 12
From a lsquoDatabasersquo to a lsquoKnowledge basersquo
bull lsquoLook-up tablesrsquo to lsquoAbility to Predictrsquo
bull Ability to predict = generate hypotheses
bull Ability (simulate) ask questions - what if
NIPTE Knowledge Management
3122015 Ajaz S Hussain PhD 13
Contact Prof Hoag Univ Maryland shoagrxumarylandedu
3122015 Ajaz S Hussain PhD 14
NIPTE Knowledge Management
This study was funded by the FDA-sponsored contract ldquoDevelopment of Quality by Design (QbD) Guidance Elements on Design Specifications across Scales with Stability Considerationsrdquo (contract number HHSF223200819929C)
3122015 Ajaz S Hussain PhD 15
Current hot topics ndashrsquoexcipientsrsquo regulatory trends amp insights ExcipientFest on 28-29 April 2015 in Washington Organizational Changes CDERFDA and Inspectional Trendshellip(Complex Genericshellip Continuous Manufacturing)
3122015 Ajaz S Hussain PhD 16
Current experience with lsquoSupplier Qualificationrsquo
bull Recent observations are summarized in this report by ECA Academy (21012015) Areas of attention
bull Accuracy and completeness of administrative documentation
bull Evidence to justify excipient and supplier qualification
bull Risk-assessment and effective integration within in QMS
bull Quality agreements
bull Going forward I envision a need to emphasize a life-cycle approach (eg linking to CAPA change control)
3122015 Ajaz S Hussain PhD 17
FDArsquos Inactive Ingredient Database -statusbull Substance Registration System (SRS)
bull Generic listing vs Specific Grade listing for commonly used excipients ndashmax precedent levels
bull Listing of Mixtures
bull The UNII code confusing the National Library of Medicine yet to finalize standards for assigning UNII codes for polymers
bull Individual Grades vs Family Data
bull Legal status of the IID and FDA communications of changes to the IID
bull DMF Implications
bull Impact on ANDAs ndash lsquoDelaysrsquo amp lsquoRefuse to File Lettersrsquo
3122015 Ajaz S Hussain PhD 18
3122015 Ajaz S Hussain PhD 19
Inactive Ingredientsrsquo to lsquoExcipientsrsquo to lsquoFunctionalityrsquo Where are we in this journeylsquo
Status of lsquoSubstances In Regulatory Practicersquo
Clearly we need a global database with improved precision and accuracy of naming (and coding) to identify describe compare and link (to products and AERs)
INDs NDAs BLAs CFRrsquos Orphan Drug ApplicationsProducts that Contain Each Substance
Pharmacological ClassificationActive Moieties Related Moieties and Salts
LADMERMetabolites
Metabolic Enzymes Transporters and EffectsDrug target (therapeutic and other) type of interaction
Solubility and Permeability (BCS)Protein Binding
Impurities and Related Substance
ISO 11238 (ISO IDMP) some challenges
Both substances amp specified substances
Implementation in EU EMA Task force
Global Ingredients Archive System (GInAS)
3122015 Ajaz S Hussain PhD 20
The War Against Fake Medicines Update on FDASIA - Guidance and Impact on Excipient Suppliers and
Users QbD Sampling Guidelines The NSFIPECANSI 363 2014 GMP standardsexplained Good Supply Practices ndash Using Cross Industry Knowledge to Devise Pragmatic Solutions Impact
of Non-harmonized Standards and What is Needed to Achieve Harmonization Advancements in the Question Based Review approach and various other excipient specific related topics An Overview of the FDA OGD
IID EWG activities Effective Sourcing and Purchasing of Excipients
Industry Collaboration for Science Based Implementation of Elemental Impurities Challenges And Opportunities In Developing
And Modernizing Public Standards For NF Excipients Monographs For Regulated Drug
Products Marketed In The USA Future Pharma Manufacturing Efficiencies and the Role of Innovative Excipient Technologies
IPEC ExcipientFest 2015
Current Hot Topics ExcipientFest on 28-29 April 2015 in Washington
3122015 Ajaz S Hussain PhD 21
The War Against Fake Medicines Update on FDASIA - Guidance and Impact on Excipient
Suppliers and Users QbD Sampling Guidelines The NSFIPECANSI 363 2014 GMP standards explained Good Supply Practices ndash Using Cross Industry Knowledge to Devise
Pragmatic Solutions Impact of Non-harmonized Standards and What is Needed to Achieve
Harmonization Advancements in the Question Based Review approach and various other
excipient specific related topics An Overview of the FDA OGD IID EWG activities Effective
Sourcing and Purchasing of Excipients Industry Collaboration for Science Based Implementation of Elemental Impurities Challenges And
Opportunities In Developing And Modernizing Public Standards For NF ExcipientsMonographs For Regulated Drug Products Marketed In The USA Future Pharma Manufacturing Efficiencies and the Role of Innovative Excipient Technologies
IPEC ExcipientFest 2015
Inspectional trends in data integrity (Bangalore Nov
2014)
22(d)
192
100(a)
160(b)
110(a)
67(b)
68(a)
25(a)
67(a)
100(b)
Recurring 483 Observations Top 10
22(d) 192 100(a) 160(b)110(a) 67(b) 68(a) 25(a)67(a) 100(b)
Jeff Medwid NIPTE-FDA Conference 13 June 2012
International Society for Pharmaceutical Engineering (ISPE) in conjunction with McKinsey amp Co will release preliminary data and findings from its Quality Metrics Pilot Program at the ISPE Quality Metrics Summit on April 21ndash22 in Baltimore
FDA Launches New Drug Quality Office With Goal of Improving the Pharmaceutical IndustryPosted 13 January 2015By Alexander Gaffney RAC
FDArsquos New Pharma Quality
Office Will Take a Team Approach
Yu Explains
Regulatory Recon Investigations Find Major Quality Problems at Indian Pharma Companies (3 December 2014)Posted 03 December 2014By Alexander Gaffney RAC
Currently the environment is complex there is high uncertainty D
on
rsquot f
org
et
fun
ctio
na
lity
o
f e
xcip
ien
ts i
s im
po
rta
nt
3122015 Ajaz S Hussain PhD 22
Need for urgent progress lsquoInactive Ingredientsrsquo to lsquoExcipientsrsquo to lsquoFunctional Excipientsrsquo
Importance of assuring quality and controlling
variability of excipients
including their lsquofunctionalityrsquo has
long been recognized
bull Increasing complexity of drugs their delivery and failure modes
bull Patient (eg pediatric) relevant failure modes
bull Simple generics to complex generics amp biosimilars
Urgent need to address gaps in the FDArsquos Inactive Ingredient Database
3122015 Ajaz S Hussain PhD 23
Trends Lab amp Manufacturing
ldquoDeletion of Datardquo
ldquoTesting Into Compliancerdquo
ldquoBMR manipulation is a slippery sloperdquo
ldquoSuggestive of faulty manufacturing process or practices even if this is not the caserdquo
ldquoIt is top managementrsquos responsibility to ensure the training program is robust and effectiverdquo
Inspectional trends in data integrity (Bangalore Nov 13 2014 - Nov 14 2014)
Growing concern some
companies ldquodata looks too good
to be truerdquo
3122015 Ajaz S Hussain PhD 24
GMP Compliance amp Remediation
Jeff Medwid NIPTE-FDA Conference 13 June 2012
QbD amp QbR Clarity on Critical Functionality
FDArsquos New Pharma Quality
Office Will Take a Team
Approach Yu Explains
Carmelo Rosa MS PsyD November 2014
Urgent Need amp Opportunity
To align amp ensure sound scientific basis of these critical regulatory decisions
FDA CDER OPQ Plans for Surveillance of Pharmaceutical Quality
Teresa Mullin PhD December 2014
3122015 Ajaz S Hussain PhD 25
Need for a comprehensive (excipient) knowledge base
Teresa Mullin PhD December 2014
3122015 Ajaz S Hussain PhD 26
Why attention to (excipient) knowledge management is criticalSpecifically for physical attributes functionality performance
3122015 Ajaz S Hussain PhD 27
3122015 Ajaz S Hussain PhD 28
Today there are several product categories (eg controlled release inhalation products DPIrsquos topical transdermal liposomal products etc) which requires an exquisite control of complex physical material and product attributes (functionality)
Many of our current measurement systems need improvement
We depend on these to ensure control of lot-lot variability
Measurement system capability must be confirmed to be able to assess process capability (calibration amp Gauge RampR)
Life-cycle approach to quality continued process verification (FDArsquos Process Validation 2011) is a safety net
Supplier amp Excipient Qualification amp Process Validation
Measurement System Analysis
bull From lsquocalibrationrsquo to lsquoGauge RampRrsquoParticularly for physical
attributes destructive analysis
bull Many (including regulators) have not yet understood its importance
Gauge RampR well established but not commonly practiced
bull Measurement system in a state of control effective CAPA quality metrics Culture of Quality
With the move towards Statistical Process Control
bull Demonstrate equivalent in vitro performance more exacting criteria
Development of complex generic products (ER
Injectable Inhalation etc)
3122015 Ajaz S Hussain PhD 29
Process Validation (2011) Statistical Confidence Continued Process Verificationhellip
3122015 Ajaz S Hussain PhD 30
httpwwwslideshareneta2zpharmsciperformance-testing-pharmaceutical-quality-2004(accessed 6 December 2014)
3122015 Ajaz S Hussain PhD 31
Supplier amp Excipient Qualification amp CAPA
Out of Specification events are difficult to resolve
Excipient functionality can be a significant contributing factor
Sometimes reluctantly have to settle with - ldquoRoot cause unknown
600 days
I have inserted the ldquo600 daysrsquo on the figure ndash this is based on cases I have seen while at FDA)
3122015 Ajaz S Hussain PhD 32
Prevention of OOS and Effective CAPA needs a focus on critical functional attributes
Out of Specification events are difficult to resolve
Excipient functionality can be a significant contributing factor
Sometimes reluctantly have to settle with - ldquoRoot cause unknown
Compendial standards and manufacturing
3122015 Ajaz S Hussain PhD 33
Practice Control Process Maturity
Initial
bull Unpredictable
Managed
bull Characterized but reactive
Defined
bull Characterized proactive
Measured amp Controlled
bull In control
Optimizing
bull Focus on improvement
3122015 Ajaz S Hussain PhD 34
Capability Maturity Model Integration Carnegie Mellon University
A validated process
Maturity Level amp Assurance of Quality
Managed Characterized but reactive
High perceived risk of
lsquoCheating by Designrsquo
ldquoTrial Injectionsrdquo
ldquoTesting in to Compliancerdquo
Defined Characterized proactive
Lower level of assurance
Stopping amp Correcting
Batch Rejection
Measured amp
ControlledIn control
Quality by Design
Quality Assured
Improvement Opportunities
3122015 Ajaz S Hussain PhD 35
At the individual level in QC functionndash how often does this occur
attitude toward
performing the behavior
Process validation is
done so quality is good
test prone to error
ldquoBatch failure means I made
a mistakerdquo
subjective norm
documentation not critical
Compendial testing
sufficient
Indian regulators
collect amp test samples ndash no issue there
3122015 Ajaz S Hussain PhD 36
ldquoTesting into compliancerdquo
In general ndash low empowerment is a significant challenge (low perceived behavioral control) plus reasons to rationalizehellip
Excipient Functionality Can be critical for safety efficacy and quality
3122015 Ajaz S Hussain PhD 37
July 15 2005 FDA Public Health Advisory Safety Warnings Regarding Use of Fentanyl Transdermal (Skin) Patches
A pattern of failure Pharmaceutical Equivalence by Design (2004)
3122015 Ajaz S Hussain PhD 38
httpwwwnihsgojpdrugPhForumdocuments041122Hussain041122pdf
An attempt to correct
3122015 Ajaz S Hussain PhD 39
httpipecamericasorgsystemfilesKeyNoteEF13May11LawrenceYu(FDA)pdf
Recent challenges
3122015 Ajaz S Hussain PhD 40
Th
e V
oic
e o
f th
eA
mer
ican
P
sych
iatr
ic A
sso
ciat
ion
and
th
e P
sych
iatr
ic C
om
mu
nit
y
Physicians Question FDAs Confidence in Generic Drugs Safety Efficacy (OCTOBER 24 2014)
bull ldquomost patientsrdquo is not the same asldquo all patientsrdquo and whether the 24 to 36 normal subjects used in the agencys bioequivalency tests represents the full range of individual variation in the way drugs are absorbed across the pharmaceutical using population is uncertain
bull Individuals can sometimes be allergic and react differently to whatever substance goes into making up the capsule or the tablet
FDA Flags Generic Versions of ADHD Medication(NOVEMBER 14 2014)
bull FDA changed the therapeutic equivalence (TE) rating from AB to BXmdashmeaning that the products are still approved and can be prescribed but are no longer recommended as automatic substitutes
RLD Variability Can be a block-buster opportunityFocus on lsquocontrol strategyrsquo
bull Overcoming CP amp IP provide FDA a submission they need to address CP
bull Then begin with QTPP CQArsquos hellip skip lsquodesign spacersquo and focus on lsquocontrol strategy
bull The entire development team should read the complete package insert of RLD
bull Discuss to ensure a common understandingbull Failure modes amp intended use
bull Pharmaceutical Equivalence
bull Bioequivalence
bull Other studies
QbD Challenges
3122015 Ajaz S Hussain PhD 41
NewRegulators are not prepared to handle QbD applications
NewMisalignment of international regulatory authorities
New and Generics
RampD incentivized for lsquoshots on the goalrsquo not QbD
GenericsLack of belief in business case ndash lsquoGenerics are all about file first figure out laterrsquo
Biologics Lack of technology to execute
Ted Fuhr Mackinsey amp Company June 2010 FDA Advisory Committee
Summary
bull Excipient functionality can contribute in critical ways to product quality amp performance adequate control is necessary
bull Our databases tools and knowledge are lagging behind the rapidly increasing complexity and uncertainty
bull Risk to quality and to business is increasing and regulatory transitions pose additional difficulties
bull Effective knowledge management ndash IT and Human practices ndash is critical for organizational lsquobottom-linersquo
bull We all must come together collaboratively to address the urgent needs we owe it to the patients we serve
3122015 Ajaz S Hussain PhD 42
Knowledge Management amp Culture of Quality
Ajaz S Hussain PhD
Insight Advice amp Solutions LLCMaryland USA
Executive Director the National Institute for Pharmaceutical Technology amp Education
3122015 Ajaz S Hussain PhD 43
3122015 Ajaz S Hussain PhD 44
Life-cycle approach needed for knowledge management
Investigational ProductscGMPs
DevelopmentTechnology
TransferCommercial
ManufacturingDiscontinuation
Management Responsibility
Process Performance amp Product Quality Monitoring SystemCAPA Change Management Management Review
PQS Elements
Knowledge ManagementQuality Risk ManagementEnablers
ICH Q10 KM is a systematic approach to acquiring analyzing storing and disseminating information related to products manufacturing processes and components
Based on ICH Q10
ldquowe can be blind to the obvious and we are also blind to our blindnessrdquo
Daniel Kahneman Thinking Fast and Slow
3142015 Ajazajazhussaincom 45
httpwebmiteduperscipeopleadelsoncheckershadow_proofhtml
3122015 Ajaz S Hussain PhD 46
1938 The Federal Food Drug and Cosmetic (FDC)
bull 1937 Elixir of Sulfanilamide
1962 Kefauver-Harris Drug Amendments
bull 1962 Thalidomide
bull 1960 Color Additive Amendment
bull 1958 Food Additives Amendment GRAS
bull 1960 Color Additive Amendment
bull 1958 Food Additives Amendment GRAS
1992 Generic Drug Enforcement Act
bull1989 L-Tryptophan
bull 1989 Generic Drug Scandal
bull 1988 Food and Drug Administration Act
bull 1984 Fines Enhancement Laws Drug Price Competition and Patent Term Restoration Act
2012 Food and Drug Administration Safety and Innovation Act (FDASIA)
bull 2007 Heparin Disaster
2013 Pandemic and All-Hazards Preparedness Reauthorization Act (PAHPRA) Drug Quality and Security Act
bull 2012 The Deadly Meningitis Outbreak
Past 70 years 1937 ndash 2007 The diethylene glycol (DEG) narrative
3122015 Ajaz S Hussain PhD 47
0
5
10
15
20
25
30
35
Yea
rs
DEG Years since the previous incident
0
50
100
150
200
250
300
350
Number of Reported Deaths
1937
Eli
xir
of
Sulf
anil
amid
e
2007T
ootp
aste
conta
min
atio
n
0 70 years 0 70 years
Frequent reports
Mumbai Mumbai
Data from Excipient Fest Janeen Skutnik Chair ndashIPECAmericas 2009
Past 70+ years DEG contamination or economically motivated adulteration
3122015 Ajaz S Hussain PhD 48
Reported cases underestimate the real tragedy rapid intervention may not occur
Epidemic of Pediatric Deaths From Acute Renal Failure Caused by
Diethylene Glycol Poisoning JAMA 1998279(15)1175-1180
doi101001jama279151175
Month of hospital admission for children with
acute renal failure Haiti
October 1995-October 1996
Diethylene glycol poisoning in Gurgaon India 1998Bulletin of the World Health Organization 2001 79 88ndash95
We report a second episode of poisoning occurring in 1998 in
India as a result of children ingesting diethylene glycol at
least 33 children are known to have died
At the beginning of the investigation we never imagined that
contaminated medicine was causing acute renal failure in
children
A brand of cough expectorant manufactured by a local
pharmaceutical company was found by the Central Drugs
Laboratory Calcutta to contain 175 (vv) diethylene
glycol
The district and state drug controller had tested many
samples using thin layer chromatography before a sample of
medicine tested positive for diethylene glycol at the Central
Drugs Laboratory None of the earlier samples was found to
be contaminated
3122015 Ajaz S Hussain PhD 49
Guidance for Industry Testing of
Glycerin for Diethylene Glycol
CDER May 2007 Compliance
1 Manufacturers did not perform full
identity testing on the glycerin raw
material including tests to quantify
the amount of DEG
2 Relied on the certificate of analysis
(COA)
3 The origin of the glycerin was not
easily apparent from the COA
4 The COA was often a copy of a COA
on the letterhead of the distributor
5 The chain of custody or distribution
history of the glycerin was also not
readily known
USP Glycerin Monograph
Type of Posting Revision Bulletin
Posting Date 04ndashFebndash2009
Official Date 01ndashMayndash2009
Because of the serious hazards
associated withhellip and in response to
recommendations set forth in the
FDA Guidance for Industry Testing
of Glycerin for Diethylene Glycol
published in May 2007 USP has
revised the USP Glycerin monograph
Because diethylene glycol and
ethylene glycol are considered
unacceptable toxic substances the
testing of USP Glycerin should
demonstrate the absence of these
substances
April 2007 FDA request to
USP to revise the Glycerin
monographrsquos
IDENTIFICATION section
Revision includes adding ndash
Identification test B LIMIT OF
DIETHYLENE GLYCOL AND
ETHYLENE GLYCOL to detect
and quantify DEGEG in Glycerin
minus Is no longer part of the impurity
testing
ldquoLimit of DEG and Related
Compoundsrdquo minus Introduces a
capillary gas-chromatographic
(GC) method with flame ionization
detection (FID) minus Limit of NMT
010 each for diethylene glycol
and ethylene glycol is found
70+ years to get here how difficult will it be to change habits such as lsquoblind reliance of COArsquo
3122015 Ajaz S Hussain PhD 50
Personality and Habitual Frame Biases
Myers Brigs ENTJ (first tested at FDA)
S
TF
Expanded frame
future
possibilities
objective lsquocause
and effectrsquo
Expanded frame
future
possibilities
people and
relationships
Narrow frame
the present
individuals and
relationships
Narrow frame
the present
objective
cause and
effect
N
Based on Stanford Webinar - How to Overcome the Top 3 MegaBiases in Decision-Making
Stanford Universityrsquos Strategic Decision and Risk Management certificate program
From Mapping a Managers Brain on Incentives
Social
influences
Relative
thinking
UncertaintyComplexity
By Design Intention to act consciously
bull In the interest of patients and to continually improve this ability bull To provide a healing touch ndash one life at a time in what we do and how we
do it
1292014 Ajazajazhussaincom 51
Consciously
Scientific methodology
Engineering Design
Plan-Do-Check-Act
Subconsciously
Habits (work to get rid of bad ones)
Habits (work to cultivate good one)
Keystone habits (Safety Alcoa ALCOA of data integrity)
The Power of Habit Why We Do What We Do in Life and Business Charles Duhigg (2012)
httpwwwslideshareneta2zpharmscipharmaceutical-culture-of-quality
What does it take to come out of the cGMP crisis
Persuasive demonstration of
(1) Ability to face facts
(2) Legal amp regulatory requirements
3) Systems approach to quality
4) Changing behavior amp culture
What is often missed or is unconvincing is how you will strengthen culture of quality
ldquoLet one who wants to move and convince others first be convinced and moved themselvesrdquo Thomas Carlyle
Signals that question the competence motivation andor integrity of company personnel
Do not defend the plainly indefensible it adds further serious credibility costs
3142015 Ajazajazhussaincom 52
Quality is everyones responsibility
Lack of knowledge that is
the problem
If you do not know how to ask the
right question you discover nothing
If you cant describe what you
are doing as a process you dont know what youre
doing
Rational behavior requires theory
Reactive behavior requires only reflex
action
Whenever there is fear you will get wrong figures
3142015 Ajazajazhussaincom 53
Selected quotes W Edwards Deming
3142015 Ajazajazhussaincom 54
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
ldquoWE CANNOT CHANGE THE HUMAN CONDITION BUThellipWE CAN CHANGE THE CONDITIONS UNDER WHICH HUMANS WORKrdquo JAMES REASON
Disregard to Malice
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 55
ldquohelliprecords not completed
contemporaneouslyrdquo
ldquohellipobserved analyst back-date logbooksrdquo
ldquohelliptrial injectionshelliprdquo
ldquohellipresults failing specifications are
retested until acceptable results are obtainedhelliprdquo
ldquohellipover-writing electronic raw datahelliprdquo
ldquohellipOOS not investigates per XYZ SOPrdquo
ldquohellipappropriate controls not establishedhelliprdquo
Each additional observation adds
reasons to confirm that this is very likely a system
with intentional lsquoholesrsquo in its
defenses
Preconditions
Rationalization amp Attitude
Pressure amp Incentive
Opportunity ndashlsquoholes in the QMSrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 56
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 57
Attitude towards the behavior
Subjective norm
Perceived behavioral
control
IntentionFuture
Behavior
usually found to predict behavioral intentions with a high degree of accuracy
intentions in combination with perceived behavioral control can account for a considerable proportion of variance in behavior
PastBehavior
Ajen I The theory of planned behavior ORGANIZATIONAL BEHAVIOR AND HUMAN DECISION PROCESSES 50 179-211 (1991)
Heparin tragedy 2007 and 2008
FDA reports 149 deaths with allergic or hypersensitivity symptoms during that period
bull Contaminated heparin from China
QC Testing
bull Initial testing failed to detect the contaminant
Pharmacovigilence
bull Signals in the pharmacovigilence systems responded slowly and
Eventually the severity of reactions associated made it likely that the contamination would be detected
bull too late for those who died or were injured
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 58
Congressman Shimkus When the drug safety system fails people get sick Some die
bull Some of these people are already very vulnerable and proving the cause of harm from impurities adulteration and counterfeits can be elusive
It is hard to detect harm
bull Certainly the companies are obligated to ensure a culture of quality and maintain vigilance as well This reflects a systems approach to safety
FDA inspectors look for a culture of quality at
manufacturing facilities
bull FDA policies led to the failure to inspect the Chinese plantThis system approach wasnt at
play here
bull While it doesnt deny the counterfeit source tries to say that counterfeits didnt cause the reaction as if the adulteration itself was no big deal Is this an acceptable mindset helliphelliphellip
This brings me to China and its quality culture or lack thereof
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 59
ONE HUNDRED TENTH CONGRESS SECOND SESSION APRIL 29 2008 Serial No 110-109
21 CFR PART 211 SUBPARTS -Deviations signal gaps in CoQ
bullGENERAL PROVISIONSA
bullORGANIZATION AND PERSONNELB
bullBUILDINGS AND FACILITIESC
bullEQUIPMENTD
bullCONTROL OF COMPONENTS AND DRUG PRODUCT CONTAINERS AND CLOSURESE
bullPRODUCTION AND PROCESS CONTROLSF
bullPACKAGING AND LABELING CONTROLG
bullHOLDING AND DISTRIBUTIONH
bullLABORATORY CONTROLSI
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 60
For example the combinationhellip
The Power of Habit Why We Do What We Do in Life and Business Charles Duhigg (2012)
bull Scientific methodology
bull Engineering Design
bull Plan-Do-Check-ActConsciously
bull Habits (work to get rid of bad ones)
bull Habits (work to cultivate good one)
bull Keystone habits (Safety Alcoa ALCOA of data integrity)
Subconsciously
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 61
CoQ How
bull What are the predictors of CoQCoQ Manifests by Design -
lsquoquality by designrsquo the foundation
bull 1 2 3When do people change their behaviors
bull A B C D (any body can dance)What makes a QMS effective
bull X Y ZWhen proactive compliance occurs
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 62
Going beyond rules pays
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 63
Human behavior Connecting the Dots With the Right Connectors
GXPs ndash rational behaviors
How proactive compliance is achieved X Y Z
Quality Management System
What makes a QMS reliable A B C D
Culture of Quality
Why people change their behavior 1 2 3
Human Behaviors Beyond GXPs
Predictors of Culture of Quality
Why What and How of Culture of Quality
9192014 copy Ajaz S Hussain | INSIGHT ADVICE amp SOLUTIONS LLC 64
Predictors of CoQ Act consciously in the interest of patients ndash when no one is looking
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 65
Only four attributes
actually predict a culture of
quality
Leadership Emphasis
Message Credibility
Peer Involvement
Employee Empower-ment
People will change their
behavior if they see the new behavior as
Normal
(1)
Rewarding
(2)
Easy
(3)
Dr W Edwards Demingrsquos - ldquoOut of the crisisrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 66
The journey requires leadership
with Profound Knowledge as a
guide
bull As leaders responsible for system change top management is most in need of profound knowledge
bull Quality is often determined in the boardroom
bull Problems arise when management reacts to common cause or chance variation as if it were special cause variation
bull Prediction based in theory provides a foundation for planning a course of action Plan ndash Do ndash Check ndash Act
bull The leader serves the people with clear vision and guidance to empower them To be empowered is to share ownership in the identity
bull Giving people a certain degree of control over their work fulfills the need for freedom and provides opportunity for taking joy in work
Profound Knowledge as a guide
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 67
Appreciation for a System
Theory of Knowledge
Knowledge about
Variation
Human Behavior -Psychology of Change
A
B
C
D+
Systems Approach for ErrorDeviation Management
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 68
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
Human error models and management J Reason BMJ 320 768ndash770 (2000)
D+
Culture of Error Management परबधनbull Error strain
bull Covering upFear of Errors
bull Anticipation
bull Risk takingAwareness
bull Development QbDRFT
bull Error detection Communication
bull Analyzing errors Correction
Mastery orientation
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 69
Dots amp Connections
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 70
CoQ
1
2
3
QMS
A
B
C
D
GXP Behaviors
X
Y
Z
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 71
Culture of Quality
Normal
Rewarding
Easy
QMS
System
Knowledge
Variation
Behavior
Behavior -GXPs
Fear Removed
Mastery
Awareness
EnvironmentLeadership Emphasis
Message Credibility
Peer Involvement
Employee Empowerment
Connect to CoQ
Connect to GXPs
A Framework and a Tool (for gap analysis)
Knowledge to inform policy improvement
3122015 Ajaz S Hussain PhD 8
Physical Attributes Can be critical for safety efficacy and quality
3122015 Ajaz S Hussain PhD 9
July 15 2005 FDA Public Health Advisory Safety Warnings Regarding Use of Fentanyl Transdermal (Skin) Patches
Also relevant today Pattern Recognition
3122015 Ajaz S Hussain PhD 10
Preliminary illustration of a concept Going forward expect to see regulators utilize state-of ndashthe ndashart pattern recognition and modeling systems
Effective Regulatory System Importance of Process Understanding and Quality by DesignAjaz Hussain Pharmaceutical Quality Forum 3rd Symposium November 2004 Tokyo Japan
Academic research
University of Cincinnati (1989-1994)
bull Formulation designbull Several projects ndash oral topical and
transdermalbull Example Elaborating the utility of
Transcutolreg (Gattefosseacute)
bull Computer aided formulation designbull Artificial Neural Network based
lsquoexpert systemsrsquobull Example Prototype for lsquoTechnical
Service Supportrsquo (funding - Aqualon)
NIPTE (Currently)
bull NIPTErsquos Excipient Knowledge basebull Available since 2007 at
httppharmahuborg
bull The goal of this project is to share information and modeling tools to support pharmaceutical product
3122015 Ajaz S Hussain PhD 11
Prototype for lsquoTechnical Service Supportrsquo
3122015 Ajaz S Hussain PhD 12
From a lsquoDatabasersquo to a lsquoKnowledge basersquo
bull lsquoLook-up tablesrsquo to lsquoAbility to Predictrsquo
bull Ability to predict = generate hypotheses
bull Ability (simulate) ask questions - what if
NIPTE Knowledge Management
3122015 Ajaz S Hussain PhD 13
Contact Prof Hoag Univ Maryland shoagrxumarylandedu
3122015 Ajaz S Hussain PhD 14
NIPTE Knowledge Management
This study was funded by the FDA-sponsored contract ldquoDevelopment of Quality by Design (QbD) Guidance Elements on Design Specifications across Scales with Stability Considerationsrdquo (contract number HHSF223200819929C)
3122015 Ajaz S Hussain PhD 15
Current hot topics ndashrsquoexcipientsrsquo regulatory trends amp insights ExcipientFest on 28-29 April 2015 in Washington Organizational Changes CDERFDA and Inspectional Trendshellip(Complex Genericshellip Continuous Manufacturing)
3122015 Ajaz S Hussain PhD 16
Current experience with lsquoSupplier Qualificationrsquo
bull Recent observations are summarized in this report by ECA Academy (21012015) Areas of attention
bull Accuracy and completeness of administrative documentation
bull Evidence to justify excipient and supplier qualification
bull Risk-assessment and effective integration within in QMS
bull Quality agreements
bull Going forward I envision a need to emphasize a life-cycle approach (eg linking to CAPA change control)
3122015 Ajaz S Hussain PhD 17
FDArsquos Inactive Ingredient Database -statusbull Substance Registration System (SRS)
bull Generic listing vs Specific Grade listing for commonly used excipients ndashmax precedent levels
bull Listing of Mixtures
bull The UNII code confusing the National Library of Medicine yet to finalize standards for assigning UNII codes for polymers
bull Individual Grades vs Family Data
bull Legal status of the IID and FDA communications of changes to the IID
bull DMF Implications
bull Impact on ANDAs ndash lsquoDelaysrsquo amp lsquoRefuse to File Lettersrsquo
3122015 Ajaz S Hussain PhD 18
3122015 Ajaz S Hussain PhD 19
Inactive Ingredientsrsquo to lsquoExcipientsrsquo to lsquoFunctionalityrsquo Where are we in this journeylsquo
Status of lsquoSubstances In Regulatory Practicersquo
Clearly we need a global database with improved precision and accuracy of naming (and coding) to identify describe compare and link (to products and AERs)
INDs NDAs BLAs CFRrsquos Orphan Drug ApplicationsProducts that Contain Each Substance
Pharmacological ClassificationActive Moieties Related Moieties and Salts
LADMERMetabolites
Metabolic Enzymes Transporters and EffectsDrug target (therapeutic and other) type of interaction
Solubility and Permeability (BCS)Protein Binding
Impurities and Related Substance
ISO 11238 (ISO IDMP) some challenges
Both substances amp specified substances
Implementation in EU EMA Task force
Global Ingredients Archive System (GInAS)
3122015 Ajaz S Hussain PhD 20
The War Against Fake Medicines Update on FDASIA - Guidance and Impact on Excipient Suppliers and
Users QbD Sampling Guidelines The NSFIPECANSI 363 2014 GMP standardsexplained Good Supply Practices ndash Using Cross Industry Knowledge to Devise Pragmatic Solutions Impact
of Non-harmonized Standards and What is Needed to Achieve Harmonization Advancements in the Question Based Review approach and various other excipient specific related topics An Overview of the FDA OGD
IID EWG activities Effective Sourcing and Purchasing of Excipients
Industry Collaboration for Science Based Implementation of Elemental Impurities Challenges And Opportunities In Developing
And Modernizing Public Standards For NF Excipients Monographs For Regulated Drug
Products Marketed In The USA Future Pharma Manufacturing Efficiencies and the Role of Innovative Excipient Technologies
IPEC ExcipientFest 2015
Current Hot Topics ExcipientFest on 28-29 April 2015 in Washington
3122015 Ajaz S Hussain PhD 21
The War Against Fake Medicines Update on FDASIA - Guidance and Impact on Excipient
Suppliers and Users QbD Sampling Guidelines The NSFIPECANSI 363 2014 GMP standards explained Good Supply Practices ndash Using Cross Industry Knowledge to Devise
Pragmatic Solutions Impact of Non-harmonized Standards and What is Needed to Achieve
Harmonization Advancements in the Question Based Review approach and various other
excipient specific related topics An Overview of the FDA OGD IID EWG activities Effective
Sourcing and Purchasing of Excipients Industry Collaboration for Science Based Implementation of Elemental Impurities Challenges And
Opportunities In Developing And Modernizing Public Standards For NF ExcipientsMonographs For Regulated Drug Products Marketed In The USA Future Pharma Manufacturing Efficiencies and the Role of Innovative Excipient Technologies
IPEC ExcipientFest 2015
Inspectional trends in data integrity (Bangalore Nov
2014)
22(d)
192
100(a)
160(b)
110(a)
67(b)
68(a)
25(a)
67(a)
100(b)
Recurring 483 Observations Top 10
22(d) 192 100(a) 160(b)110(a) 67(b) 68(a) 25(a)67(a) 100(b)
Jeff Medwid NIPTE-FDA Conference 13 June 2012
International Society for Pharmaceutical Engineering (ISPE) in conjunction with McKinsey amp Co will release preliminary data and findings from its Quality Metrics Pilot Program at the ISPE Quality Metrics Summit on April 21ndash22 in Baltimore
FDA Launches New Drug Quality Office With Goal of Improving the Pharmaceutical IndustryPosted 13 January 2015By Alexander Gaffney RAC
FDArsquos New Pharma Quality
Office Will Take a Team Approach
Yu Explains
Regulatory Recon Investigations Find Major Quality Problems at Indian Pharma Companies (3 December 2014)Posted 03 December 2014By Alexander Gaffney RAC
Currently the environment is complex there is high uncertainty D
on
rsquot f
org
et
fun
ctio
na
lity
o
f e
xcip
ien
ts i
s im
po
rta
nt
3122015 Ajaz S Hussain PhD 22
Need for urgent progress lsquoInactive Ingredientsrsquo to lsquoExcipientsrsquo to lsquoFunctional Excipientsrsquo
Importance of assuring quality and controlling
variability of excipients
including their lsquofunctionalityrsquo has
long been recognized
bull Increasing complexity of drugs their delivery and failure modes
bull Patient (eg pediatric) relevant failure modes
bull Simple generics to complex generics amp biosimilars
Urgent need to address gaps in the FDArsquos Inactive Ingredient Database
3122015 Ajaz S Hussain PhD 23
Trends Lab amp Manufacturing
ldquoDeletion of Datardquo
ldquoTesting Into Compliancerdquo
ldquoBMR manipulation is a slippery sloperdquo
ldquoSuggestive of faulty manufacturing process or practices even if this is not the caserdquo
ldquoIt is top managementrsquos responsibility to ensure the training program is robust and effectiverdquo
Inspectional trends in data integrity (Bangalore Nov 13 2014 - Nov 14 2014)
Growing concern some
companies ldquodata looks too good
to be truerdquo
3122015 Ajaz S Hussain PhD 24
GMP Compliance amp Remediation
Jeff Medwid NIPTE-FDA Conference 13 June 2012
QbD amp QbR Clarity on Critical Functionality
FDArsquos New Pharma Quality
Office Will Take a Team
Approach Yu Explains
Carmelo Rosa MS PsyD November 2014
Urgent Need amp Opportunity
To align amp ensure sound scientific basis of these critical regulatory decisions
FDA CDER OPQ Plans for Surveillance of Pharmaceutical Quality
Teresa Mullin PhD December 2014
3122015 Ajaz S Hussain PhD 25
Need for a comprehensive (excipient) knowledge base
Teresa Mullin PhD December 2014
3122015 Ajaz S Hussain PhD 26
Why attention to (excipient) knowledge management is criticalSpecifically for physical attributes functionality performance
3122015 Ajaz S Hussain PhD 27
3122015 Ajaz S Hussain PhD 28
Today there are several product categories (eg controlled release inhalation products DPIrsquos topical transdermal liposomal products etc) which requires an exquisite control of complex physical material and product attributes (functionality)
Many of our current measurement systems need improvement
We depend on these to ensure control of lot-lot variability
Measurement system capability must be confirmed to be able to assess process capability (calibration amp Gauge RampR)
Life-cycle approach to quality continued process verification (FDArsquos Process Validation 2011) is a safety net
Supplier amp Excipient Qualification amp Process Validation
Measurement System Analysis
bull From lsquocalibrationrsquo to lsquoGauge RampRrsquoParticularly for physical
attributes destructive analysis
bull Many (including regulators) have not yet understood its importance
Gauge RampR well established but not commonly practiced
bull Measurement system in a state of control effective CAPA quality metrics Culture of Quality
With the move towards Statistical Process Control
bull Demonstrate equivalent in vitro performance more exacting criteria
Development of complex generic products (ER
Injectable Inhalation etc)
3122015 Ajaz S Hussain PhD 29
Process Validation (2011) Statistical Confidence Continued Process Verificationhellip
3122015 Ajaz S Hussain PhD 30
httpwwwslideshareneta2zpharmsciperformance-testing-pharmaceutical-quality-2004(accessed 6 December 2014)
3122015 Ajaz S Hussain PhD 31
Supplier amp Excipient Qualification amp CAPA
Out of Specification events are difficult to resolve
Excipient functionality can be a significant contributing factor
Sometimes reluctantly have to settle with - ldquoRoot cause unknown
600 days
I have inserted the ldquo600 daysrsquo on the figure ndash this is based on cases I have seen while at FDA)
3122015 Ajaz S Hussain PhD 32
Prevention of OOS and Effective CAPA needs a focus on critical functional attributes
Out of Specification events are difficult to resolve
Excipient functionality can be a significant contributing factor
Sometimes reluctantly have to settle with - ldquoRoot cause unknown
Compendial standards and manufacturing
3122015 Ajaz S Hussain PhD 33
Practice Control Process Maturity
Initial
bull Unpredictable
Managed
bull Characterized but reactive
Defined
bull Characterized proactive
Measured amp Controlled
bull In control
Optimizing
bull Focus on improvement
3122015 Ajaz S Hussain PhD 34
Capability Maturity Model Integration Carnegie Mellon University
A validated process
Maturity Level amp Assurance of Quality
Managed Characterized but reactive
High perceived risk of
lsquoCheating by Designrsquo
ldquoTrial Injectionsrdquo
ldquoTesting in to Compliancerdquo
Defined Characterized proactive
Lower level of assurance
Stopping amp Correcting
Batch Rejection
Measured amp
ControlledIn control
Quality by Design
Quality Assured
Improvement Opportunities
3122015 Ajaz S Hussain PhD 35
At the individual level in QC functionndash how often does this occur
attitude toward
performing the behavior
Process validation is
done so quality is good
test prone to error
ldquoBatch failure means I made
a mistakerdquo
subjective norm
documentation not critical
Compendial testing
sufficient
Indian regulators
collect amp test samples ndash no issue there
3122015 Ajaz S Hussain PhD 36
ldquoTesting into compliancerdquo
In general ndash low empowerment is a significant challenge (low perceived behavioral control) plus reasons to rationalizehellip
Excipient Functionality Can be critical for safety efficacy and quality
3122015 Ajaz S Hussain PhD 37
July 15 2005 FDA Public Health Advisory Safety Warnings Regarding Use of Fentanyl Transdermal (Skin) Patches
A pattern of failure Pharmaceutical Equivalence by Design (2004)
3122015 Ajaz S Hussain PhD 38
httpwwwnihsgojpdrugPhForumdocuments041122Hussain041122pdf
An attempt to correct
3122015 Ajaz S Hussain PhD 39
httpipecamericasorgsystemfilesKeyNoteEF13May11LawrenceYu(FDA)pdf
Recent challenges
3122015 Ajaz S Hussain PhD 40
Th
e V
oic
e o
f th
eA
mer
ican
P
sych
iatr
ic A
sso
ciat
ion
and
th
e P
sych
iatr
ic C
om
mu
nit
y
Physicians Question FDAs Confidence in Generic Drugs Safety Efficacy (OCTOBER 24 2014)
bull ldquomost patientsrdquo is not the same asldquo all patientsrdquo and whether the 24 to 36 normal subjects used in the agencys bioequivalency tests represents the full range of individual variation in the way drugs are absorbed across the pharmaceutical using population is uncertain
bull Individuals can sometimes be allergic and react differently to whatever substance goes into making up the capsule or the tablet
FDA Flags Generic Versions of ADHD Medication(NOVEMBER 14 2014)
bull FDA changed the therapeutic equivalence (TE) rating from AB to BXmdashmeaning that the products are still approved and can be prescribed but are no longer recommended as automatic substitutes
RLD Variability Can be a block-buster opportunityFocus on lsquocontrol strategyrsquo
bull Overcoming CP amp IP provide FDA a submission they need to address CP
bull Then begin with QTPP CQArsquos hellip skip lsquodesign spacersquo and focus on lsquocontrol strategy
bull The entire development team should read the complete package insert of RLD
bull Discuss to ensure a common understandingbull Failure modes amp intended use
bull Pharmaceutical Equivalence
bull Bioequivalence
bull Other studies
QbD Challenges
3122015 Ajaz S Hussain PhD 41
NewRegulators are not prepared to handle QbD applications
NewMisalignment of international regulatory authorities
New and Generics
RampD incentivized for lsquoshots on the goalrsquo not QbD
GenericsLack of belief in business case ndash lsquoGenerics are all about file first figure out laterrsquo
Biologics Lack of technology to execute
Ted Fuhr Mackinsey amp Company June 2010 FDA Advisory Committee
Summary
bull Excipient functionality can contribute in critical ways to product quality amp performance adequate control is necessary
bull Our databases tools and knowledge are lagging behind the rapidly increasing complexity and uncertainty
bull Risk to quality and to business is increasing and regulatory transitions pose additional difficulties
bull Effective knowledge management ndash IT and Human practices ndash is critical for organizational lsquobottom-linersquo
bull We all must come together collaboratively to address the urgent needs we owe it to the patients we serve
3122015 Ajaz S Hussain PhD 42
Knowledge Management amp Culture of Quality
Ajaz S Hussain PhD
Insight Advice amp Solutions LLCMaryland USA
Executive Director the National Institute for Pharmaceutical Technology amp Education
3122015 Ajaz S Hussain PhD 43
3122015 Ajaz S Hussain PhD 44
Life-cycle approach needed for knowledge management
Investigational ProductscGMPs
DevelopmentTechnology
TransferCommercial
ManufacturingDiscontinuation
Management Responsibility
Process Performance amp Product Quality Monitoring SystemCAPA Change Management Management Review
PQS Elements
Knowledge ManagementQuality Risk ManagementEnablers
ICH Q10 KM is a systematic approach to acquiring analyzing storing and disseminating information related to products manufacturing processes and components
Based on ICH Q10
ldquowe can be blind to the obvious and we are also blind to our blindnessrdquo
Daniel Kahneman Thinking Fast and Slow
3142015 Ajazajazhussaincom 45
httpwebmiteduperscipeopleadelsoncheckershadow_proofhtml
3122015 Ajaz S Hussain PhD 46
1938 The Federal Food Drug and Cosmetic (FDC)
bull 1937 Elixir of Sulfanilamide
1962 Kefauver-Harris Drug Amendments
bull 1962 Thalidomide
bull 1960 Color Additive Amendment
bull 1958 Food Additives Amendment GRAS
bull 1960 Color Additive Amendment
bull 1958 Food Additives Amendment GRAS
1992 Generic Drug Enforcement Act
bull1989 L-Tryptophan
bull 1989 Generic Drug Scandal
bull 1988 Food and Drug Administration Act
bull 1984 Fines Enhancement Laws Drug Price Competition and Patent Term Restoration Act
2012 Food and Drug Administration Safety and Innovation Act (FDASIA)
bull 2007 Heparin Disaster
2013 Pandemic and All-Hazards Preparedness Reauthorization Act (PAHPRA) Drug Quality and Security Act
bull 2012 The Deadly Meningitis Outbreak
Past 70 years 1937 ndash 2007 The diethylene glycol (DEG) narrative
3122015 Ajaz S Hussain PhD 47
0
5
10
15
20
25
30
35
Yea
rs
DEG Years since the previous incident
0
50
100
150
200
250
300
350
Number of Reported Deaths
1937
Eli
xir
of
Sulf
anil
amid
e
2007T
ootp
aste
conta
min
atio
n
0 70 years 0 70 years
Frequent reports
Mumbai Mumbai
Data from Excipient Fest Janeen Skutnik Chair ndashIPECAmericas 2009
Past 70+ years DEG contamination or economically motivated adulteration
3122015 Ajaz S Hussain PhD 48
Reported cases underestimate the real tragedy rapid intervention may not occur
Epidemic of Pediatric Deaths From Acute Renal Failure Caused by
Diethylene Glycol Poisoning JAMA 1998279(15)1175-1180
doi101001jama279151175
Month of hospital admission for children with
acute renal failure Haiti
October 1995-October 1996
Diethylene glycol poisoning in Gurgaon India 1998Bulletin of the World Health Organization 2001 79 88ndash95
We report a second episode of poisoning occurring in 1998 in
India as a result of children ingesting diethylene glycol at
least 33 children are known to have died
At the beginning of the investigation we never imagined that
contaminated medicine was causing acute renal failure in
children
A brand of cough expectorant manufactured by a local
pharmaceutical company was found by the Central Drugs
Laboratory Calcutta to contain 175 (vv) diethylene
glycol
The district and state drug controller had tested many
samples using thin layer chromatography before a sample of
medicine tested positive for diethylene glycol at the Central
Drugs Laboratory None of the earlier samples was found to
be contaminated
3122015 Ajaz S Hussain PhD 49
Guidance for Industry Testing of
Glycerin for Diethylene Glycol
CDER May 2007 Compliance
1 Manufacturers did not perform full
identity testing on the glycerin raw
material including tests to quantify
the amount of DEG
2 Relied on the certificate of analysis
(COA)
3 The origin of the glycerin was not
easily apparent from the COA
4 The COA was often a copy of a COA
on the letterhead of the distributor
5 The chain of custody or distribution
history of the glycerin was also not
readily known
USP Glycerin Monograph
Type of Posting Revision Bulletin
Posting Date 04ndashFebndash2009
Official Date 01ndashMayndash2009
Because of the serious hazards
associated withhellip and in response to
recommendations set forth in the
FDA Guidance for Industry Testing
of Glycerin for Diethylene Glycol
published in May 2007 USP has
revised the USP Glycerin monograph
Because diethylene glycol and
ethylene glycol are considered
unacceptable toxic substances the
testing of USP Glycerin should
demonstrate the absence of these
substances
April 2007 FDA request to
USP to revise the Glycerin
monographrsquos
IDENTIFICATION section
Revision includes adding ndash
Identification test B LIMIT OF
DIETHYLENE GLYCOL AND
ETHYLENE GLYCOL to detect
and quantify DEGEG in Glycerin
minus Is no longer part of the impurity
testing
ldquoLimit of DEG and Related
Compoundsrdquo minus Introduces a
capillary gas-chromatographic
(GC) method with flame ionization
detection (FID) minus Limit of NMT
010 each for diethylene glycol
and ethylene glycol is found
70+ years to get here how difficult will it be to change habits such as lsquoblind reliance of COArsquo
3122015 Ajaz S Hussain PhD 50
Personality and Habitual Frame Biases
Myers Brigs ENTJ (first tested at FDA)
S
TF
Expanded frame
future
possibilities
objective lsquocause
and effectrsquo
Expanded frame
future
possibilities
people and
relationships
Narrow frame
the present
individuals and
relationships
Narrow frame
the present
objective
cause and
effect
N
Based on Stanford Webinar - How to Overcome the Top 3 MegaBiases in Decision-Making
Stanford Universityrsquos Strategic Decision and Risk Management certificate program
From Mapping a Managers Brain on Incentives
Social
influences
Relative
thinking
UncertaintyComplexity
By Design Intention to act consciously
bull In the interest of patients and to continually improve this ability bull To provide a healing touch ndash one life at a time in what we do and how we
do it
1292014 Ajazajazhussaincom 51
Consciously
Scientific methodology
Engineering Design
Plan-Do-Check-Act
Subconsciously
Habits (work to get rid of bad ones)
Habits (work to cultivate good one)
Keystone habits (Safety Alcoa ALCOA of data integrity)
The Power of Habit Why We Do What We Do in Life and Business Charles Duhigg (2012)
httpwwwslideshareneta2zpharmscipharmaceutical-culture-of-quality
What does it take to come out of the cGMP crisis
Persuasive demonstration of
(1) Ability to face facts
(2) Legal amp regulatory requirements
3) Systems approach to quality
4) Changing behavior amp culture
What is often missed or is unconvincing is how you will strengthen culture of quality
ldquoLet one who wants to move and convince others first be convinced and moved themselvesrdquo Thomas Carlyle
Signals that question the competence motivation andor integrity of company personnel
Do not defend the plainly indefensible it adds further serious credibility costs
3142015 Ajazajazhussaincom 52
Quality is everyones responsibility
Lack of knowledge that is
the problem
If you do not know how to ask the
right question you discover nothing
If you cant describe what you
are doing as a process you dont know what youre
doing
Rational behavior requires theory
Reactive behavior requires only reflex
action
Whenever there is fear you will get wrong figures
3142015 Ajazajazhussaincom 53
Selected quotes W Edwards Deming
3142015 Ajazajazhussaincom 54
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
ldquoWE CANNOT CHANGE THE HUMAN CONDITION BUThellipWE CAN CHANGE THE CONDITIONS UNDER WHICH HUMANS WORKrdquo JAMES REASON
Disregard to Malice
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 55
ldquohelliprecords not completed
contemporaneouslyrdquo
ldquohellipobserved analyst back-date logbooksrdquo
ldquohelliptrial injectionshelliprdquo
ldquohellipresults failing specifications are
retested until acceptable results are obtainedhelliprdquo
ldquohellipover-writing electronic raw datahelliprdquo
ldquohellipOOS not investigates per XYZ SOPrdquo
ldquohellipappropriate controls not establishedhelliprdquo
Each additional observation adds
reasons to confirm that this is very likely a system
with intentional lsquoholesrsquo in its
defenses
Preconditions
Rationalization amp Attitude
Pressure amp Incentive
Opportunity ndashlsquoholes in the QMSrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 56
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 57
Attitude towards the behavior
Subjective norm
Perceived behavioral
control
IntentionFuture
Behavior
usually found to predict behavioral intentions with a high degree of accuracy
intentions in combination with perceived behavioral control can account for a considerable proportion of variance in behavior
PastBehavior
Ajen I The theory of planned behavior ORGANIZATIONAL BEHAVIOR AND HUMAN DECISION PROCESSES 50 179-211 (1991)
Heparin tragedy 2007 and 2008
FDA reports 149 deaths with allergic or hypersensitivity symptoms during that period
bull Contaminated heparin from China
QC Testing
bull Initial testing failed to detect the contaminant
Pharmacovigilence
bull Signals in the pharmacovigilence systems responded slowly and
Eventually the severity of reactions associated made it likely that the contamination would be detected
bull too late for those who died or were injured
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 58
Congressman Shimkus When the drug safety system fails people get sick Some die
bull Some of these people are already very vulnerable and proving the cause of harm from impurities adulteration and counterfeits can be elusive
It is hard to detect harm
bull Certainly the companies are obligated to ensure a culture of quality and maintain vigilance as well This reflects a systems approach to safety
FDA inspectors look for a culture of quality at
manufacturing facilities
bull FDA policies led to the failure to inspect the Chinese plantThis system approach wasnt at
play here
bull While it doesnt deny the counterfeit source tries to say that counterfeits didnt cause the reaction as if the adulteration itself was no big deal Is this an acceptable mindset helliphelliphellip
This brings me to China and its quality culture or lack thereof
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 59
ONE HUNDRED TENTH CONGRESS SECOND SESSION APRIL 29 2008 Serial No 110-109
21 CFR PART 211 SUBPARTS -Deviations signal gaps in CoQ
bullGENERAL PROVISIONSA
bullORGANIZATION AND PERSONNELB
bullBUILDINGS AND FACILITIESC
bullEQUIPMENTD
bullCONTROL OF COMPONENTS AND DRUG PRODUCT CONTAINERS AND CLOSURESE
bullPRODUCTION AND PROCESS CONTROLSF
bullPACKAGING AND LABELING CONTROLG
bullHOLDING AND DISTRIBUTIONH
bullLABORATORY CONTROLSI
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 60
For example the combinationhellip
The Power of Habit Why We Do What We Do in Life and Business Charles Duhigg (2012)
bull Scientific methodology
bull Engineering Design
bull Plan-Do-Check-ActConsciously
bull Habits (work to get rid of bad ones)
bull Habits (work to cultivate good one)
bull Keystone habits (Safety Alcoa ALCOA of data integrity)
Subconsciously
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 61
CoQ How
bull What are the predictors of CoQCoQ Manifests by Design -
lsquoquality by designrsquo the foundation
bull 1 2 3When do people change their behaviors
bull A B C D (any body can dance)What makes a QMS effective
bull X Y ZWhen proactive compliance occurs
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 62
Going beyond rules pays
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 63
Human behavior Connecting the Dots With the Right Connectors
GXPs ndash rational behaviors
How proactive compliance is achieved X Y Z
Quality Management System
What makes a QMS reliable A B C D
Culture of Quality
Why people change their behavior 1 2 3
Human Behaviors Beyond GXPs
Predictors of Culture of Quality
Why What and How of Culture of Quality
9192014 copy Ajaz S Hussain | INSIGHT ADVICE amp SOLUTIONS LLC 64
Predictors of CoQ Act consciously in the interest of patients ndash when no one is looking
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 65
Only four attributes
actually predict a culture of
quality
Leadership Emphasis
Message Credibility
Peer Involvement
Employee Empower-ment
People will change their
behavior if they see the new behavior as
Normal
(1)
Rewarding
(2)
Easy
(3)
Dr W Edwards Demingrsquos - ldquoOut of the crisisrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 66
The journey requires leadership
with Profound Knowledge as a
guide
bull As leaders responsible for system change top management is most in need of profound knowledge
bull Quality is often determined in the boardroom
bull Problems arise when management reacts to common cause or chance variation as if it were special cause variation
bull Prediction based in theory provides a foundation for planning a course of action Plan ndash Do ndash Check ndash Act
bull The leader serves the people with clear vision and guidance to empower them To be empowered is to share ownership in the identity
bull Giving people a certain degree of control over their work fulfills the need for freedom and provides opportunity for taking joy in work
Profound Knowledge as a guide
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 67
Appreciation for a System
Theory of Knowledge
Knowledge about
Variation
Human Behavior -Psychology of Change
A
B
C
D+
Systems Approach for ErrorDeviation Management
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 68
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
Human error models and management J Reason BMJ 320 768ndash770 (2000)
D+
Culture of Error Management परबधनbull Error strain
bull Covering upFear of Errors
bull Anticipation
bull Risk takingAwareness
bull Development QbDRFT
bull Error detection Communication
bull Analyzing errors Correction
Mastery orientation
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 69
Dots amp Connections
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 70
CoQ
1
2
3
QMS
A
B
C
D
GXP Behaviors
X
Y
Z
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 71
Culture of Quality
Normal
Rewarding
Easy
QMS
System
Knowledge
Variation
Behavior
Behavior -GXPs
Fear Removed
Mastery
Awareness
EnvironmentLeadership Emphasis
Message Credibility
Peer Involvement
Employee Empowerment
Connect to CoQ
Connect to GXPs
A Framework and a Tool (for gap analysis)
Physical Attributes Can be critical for safety efficacy and quality
3122015 Ajaz S Hussain PhD 9
July 15 2005 FDA Public Health Advisory Safety Warnings Regarding Use of Fentanyl Transdermal (Skin) Patches
Also relevant today Pattern Recognition
3122015 Ajaz S Hussain PhD 10
Preliminary illustration of a concept Going forward expect to see regulators utilize state-of ndashthe ndashart pattern recognition and modeling systems
Effective Regulatory System Importance of Process Understanding and Quality by DesignAjaz Hussain Pharmaceutical Quality Forum 3rd Symposium November 2004 Tokyo Japan
Academic research
University of Cincinnati (1989-1994)
bull Formulation designbull Several projects ndash oral topical and
transdermalbull Example Elaborating the utility of
Transcutolreg (Gattefosseacute)
bull Computer aided formulation designbull Artificial Neural Network based
lsquoexpert systemsrsquobull Example Prototype for lsquoTechnical
Service Supportrsquo (funding - Aqualon)
NIPTE (Currently)
bull NIPTErsquos Excipient Knowledge basebull Available since 2007 at
httppharmahuborg
bull The goal of this project is to share information and modeling tools to support pharmaceutical product
3122015 Ajaz S Hussain PhD 11
Prototype for lsquoTechnical Service Supportrsquo
3122015 Ajaz S Hussain PhD 12
From a lsquoDatabasersquo to a lsquoKnowledge basersquo
bull lsquoLook-up tablesrsquo to lsquoAbility to Predictrsquo
bull Ability to predict = generate hypotheses
bull Ability (simulate) ask questions - what if
NIPTE Knowledge Management
3122015 Ajaz S Hussain PhD 13
Contact Prof Hoag Univ Maryland shoagrxumarylandedu
3122015 Ajaz S Hussain PhD 14
NIPTE Knowledge Management
This study was funded by the FDA-sponsored contract ldquoDevelopment of Quality by Design (QbD) Guidance Elements on Design Specifications across Scales with Stability Considerationsrdquo (contract number HHSF223200819929C)
3122015 Ajaz S Hussain PhD 15
Current hot topics ndashrsquoexcipientsrsquo regulatory trends amp insights ExcipientFest on 28-29 April 2015 in Washington Organizational Changes CDERFDA and Inspectional Trendshellip(Complex Genericshellip Continuous Manufacturing)
3122015 Ajaz S Hussain PhD 16
Current experience with lsquoSupplier Qualificationrsquo
bull Recent observations are summarized in this report by ECA Academy (21012015) Areas of attention
bull Accuracy and completeness of administrative documentation
bull Evidence to justify excipient and supplier qualification
bull Risk-assessment and effective integration within in QMS
bull Quality agreements
bull Going forward I envision a need to emphasize a life-cycle approach (eg linking to CAPA change control)
3122015 Ajaz S Hussain PhD 17
FDArsquos Inactive Ingredient Database -statusbull Substance Registration System (SRS)
bull Generic listing vs Specific Grade listing for commonly used excipients ndashmax precedent levels
bull Listing of Mixtures
bull The UNII code confusing the National Library of Medicine yet to finalize standards for assigning UNII codes for polymers
bull Individual Grades vs Family Data
bull Legal status of the IID and FDA communications of changes to the IID
bull DMF Implications
bull Impact on ANDAs ndash lsquoDelaysrsquo amp lsquoRefuse to File Lettersrsquo
3122015 Ajaz S Hussain PhD 18
3122015 Ajaz S Hussain PhD 19
Inactive Ingredientsrsquo to lsquoExcipientsrsquo to lsquoFunctionalityrsquo Where are we in this journeylsquo
Status of lsquoSubstances In Regulatory Practicersquo
Clearly we need a global database with improved precision and accuracy of naming (and coding) to identify describe compare and link (to products and AERs)
INDs NDAs BLAs CFRrsquos Orphan Drug ApplicationsProducts that Contain Each Substance
Pharmacological ClassificationActive Moieties Related Moieties and Salts
LADMERMetabolites
Metabolic Enzymes Transporters and EffectsDrug target (therapeutic and other) type of interaction
Solubility and Permeability (BCS)Protein Binding
Impurities and Related Substance
ISO 11238 (ISO IDMP) some challenges
Both substances amp specified substances
Implementation in EU EMA Task force
Global Ingredients Archive System (GInAS)
3122015 Ajaz S Hussain PhD 20
The War Against Fake Medicines Update on FDASIA - Guidance and Impact on Excipient Suppliers and
Users QbD Sampling Guidelines The NSFIPECANSI 363 2014 GMP standardsexplained Good Supply Practices ndash Using Cross Industry Knowledge to Devise Pragmatic Solutions Impact
of Non-harmonized Standards and What is Needed to Achieve Harmonization Advancements in the Question Based Review approach and various other excipient specific related topics An Overview of the FDA OGD
IID EWG activities Effective Sourcing and Purchasing of Excipients
Industry Collaboration for Science Based Implementation of Elemental Impurities Challenges And Opportunities In Developing
And Modernizing Public Standards For NF Excipients Monographs For Regulated Drug
Products Marketed In The USA Future Pharma Manufacturing Efficiencies and the Role of Innovative Excipient Technologies
IPEC ExcipientFest 2015
Current Hot Topics ExcipientFest on 28-29 April 2015 in Washington
3122015 Ajaz S Hussain PhD 21
The War Against Fake Medicines Update on FDASIA - Guidance and Impact on Excipient
Suppliers and Users QbD Sampling Guidelines The NSFIPECANSI 363 2014 GMP standards explained Good Supply Practices ndash Using Cross Industry Knowledge to Devise
Pragmatic Solutions Impact of Non-harmonized Standards and What is Needed to Achieve
Harmonization Advancements in the Question Based Review approach and various other
excipient specific related topics An Overview of the FDA OGD IID EWG activities Effective
Sourcing and Purchasing of Excipients Industry Collaboration for Science Based Implementation of Elemental Impurities Challenges And
Opportunities In Developing And Modernizing Public Standards For NF ExcipientsMonographs For Regulated Drug Products Marketed In The USA Future Pharma Manufacturing Efficiencies and the Role of Innovative Excipient Technologies
IPEC ExcipientFest 2015
Inspectional trends in data integrity (Bangalore Nov
2014)
22(d)
192
100(a)
160(b)
110(a)
67(b)
68(a)
25(a)
67(a)
100(b)
Recurring 483 Observations Top 10
22(d) 192 100(a) 160(b)110(a) 67(b) 68(a) 25(a)67(a) 100(b)
Jeff Medwid NIPTE-FDA Conference 13 June 2012
International Society for Pharmaceutical Engineering (ISPE) in conjunction with McKinsey amp Co will release preliminary data and findings from its Quality Metrics Pilot Program at the ISPE Quality Metrics Summit on April 21ndash22 in Baltimore
FDA Launches New Drug Quality Office With Goal of Improving the Pharmaceutical IndustryPosted 13 January 2015By Alexander Gaffney RAC
FDArsquos New Pharma Quality
Office Will Take a Team Approach
Yu Explains
Regulatory Recon Investigations Find Major Quality Problems at Indian Pharma Companies (3 December 2014)Posted 03 December 2014By Alexander Gaffney RAC
Currently the environment is complex there is high uncertainty D
on
rsquot f
org
et
fun
ctio
na
lity
o
f e
xcip
ien
ts i
s im
po
rta
nt
3122015 Ajaz S Hussain PhD 22
Need for urgent progress lsquoInactive Ingredientsrsquo to lsquoExcipientsrsquo to lsquoFunctional Excipientsrsquo
Importance of assuring quality and controlling
variability of excipients
including their lsquofunctionalityrsquo has
long been recognized
bull Increasing complexity of drugs their delivery and failure modes
bull Patient (eg pediatric) relevant failure modes
bull Simple generics to complex generics amp biosimilars
Urgent need to address gaps in the FDArsquos Inactive Ingredient Database
3122015 Ajaz S Hussain PhD 23
Trends Lab amp Manufacturing
ldquoDeletion of Datardquo
ldquoTesting Into Compliancerdquo
ldquoBMR manipulation is a slippery sloperdquo
ldquoSuggestive of faulty manufacturing process or practices even if this is not the caserdquo
ldquoIt is top managementrsquos responsibility to ensure the training program is robust and effectiverdquo
Inspectional trends in data integrity (Bangalore Nov 13 2014 - Nov 14 2014)
Growing concern some
companies ldquodata looks too good
to be truerdquo
3122015 Ajaz S Hussain PhD 24
GMP Compliance amp Remediation
Jeff Medwid NIPTE-FDA Conference 13 June 2012
QbD amp QbR Clarity on Critical Functionality
FDArsquos New Pharma Quality
Office Will Take a Team
Approach Yu Explains
Carmelo Rosa MS PsyD November 2014
Urgent Need amp Opportunity
To align amp ensure sound scientific basis of these critical regulatory decisions
FDA CDER OPQ Plans for Surveillance of Pharmaceutical Quality
Teresa Mullin PhD December 2014
3122015 Ajaz S Hussain PhD 25
Need for a comprehensive (excipient) knowledge base
Teresa Mullin PhD December 2014
3122015 Ajaz S Hussain PhD 26
Why attention to (excipient) knowledge management is criticalSpecifically for physical attributes functionality performance
3122015 Ajaz S Hussain PhD 27
3122015 Ajaz S Hussain PhD 28
Today there are several product categories (eg controlled release inhalation products DPIrsquos topical transdermal liposomal products etc) which requires an exquisite control of complex physical material and product attributes (functionality)
Many of our current measurement systems need improvement
We depend on these to ensure control of lot-lot variability
Measurement system capability must be confirmed to be able to assess process capability (calibration amp Gauge RampR)
Life-cycle approach to quality continued process verification (FDArsquos Process Validation 2011) is a safety net
Supplier amp Excipient Qualification amp Process Validation
Measurement System Analysis
bull From lsquocalibrationrsquo to lsquoGauge RampRrsquoParticularly for physical
attributes destructive analysis
bull Many (including regulators) have not yet understood its importance
Gauge RampR well established but not commonly practiced
bull Measurement system in a state of control effective CAPA quality metrics Culture of Quality
With the move towards Statistical Process Control
bull Demonstrate equivalent in vitro performance more exacting criteria
Development of complex generic products (ER
Injectable Inhalation etc)
3122015 Ajaz S Hussain PhD 29
Process Validation (2011) Statistical Confidence Continued Process Verificationhellip
3122015 Ajaz S Hussain PhD 30
httpwwwslideshareneta2zpharmsciperformance-testing-pharmaceutical-quality-2004(accessed 6 December 2014)
3122015 Ajaz S Hussain PhD 31
Supplier amp Excipient Qualification amp CAPA
Out of Specification events are difficult to resolve
Excipient functionality can be a significant contributing factor
Sometimes reluctantly have to settle with - ldquoRoot cause unknown
600 days
I have inserted the ldquo600 daysrsquo on the figure ndash this is based on cases I have seen while at FDA)
3122015 Ajaz S Hussain PhD 32
Prevention of OOS and Effective CAPA needs a focus on critical functional attributes
Out of Specification events are difficult to resolve
Excipient functionality can be a significant contributing factor
Sometimes reluctantly have to settle with - ldquoRoot cause unknown
Compendial standards and manufacturing
3122015 Ajaz S Hussain PhD 33
Practice Control Process Maturity
Initial
bull Unpredictable
Managed
bull Characterized but reactive
Defined
bull Characterized proactive
Measured amp Controlled
bull In control
Optimizing
bull Focus on improvement
3122015 Ajaz S Hussain PhD 34
Capability Maturity Model Integration Carnegie Mellon University
A validated process
Maturity Level amp Assurance of Quality
Managed Characterized but reactive
High perceived risk of
lsquoCheating by Designrsquo
ldquoTrial Injectionsrdquo
ldquoTesting in to Compliancerdquo
Defined Characterized proactive
Lower level of assurance
Stopping amp Correcting
Batch Rejection
Measured amp
ControlledIn control
Quality by Design
Quality Assured
Improvement Opportunities
3122015 Ajaz S Hussain PhD 35
At the individual level in QC functionndash how often does this occur
attitude toward
performing the behavior
Process validation is
done so quality is good
test prone to error
ldquoBatch failure means I made
a mistakerdquo
subjective norm
documentation not critical
Compendial testing
sufficient
Indian regulators
collect amp test samples ndash no issue there
3122015 Ajaz S Hussain PhD 36
ldquoTesting into compliancerdquo
In general ndash low empowerment is a significant challenge (low perceived behavioral control) plus reasons to rationalizehellip
Excipient Functionality Can be critical for safety efficacy and quality
3122015 Ajaz S Hussain PhD 37
July 15 2005 FDA Public Health Advisory Safety Warnings Regarding Use of Fentanyl Transdermal (Skin) Patches
A pattern of failure Pharmaceutical Equivalence by Design (2004)
3122015 Ajaz S Hussain PhD 38
httpwwwnihsgojpdrugPhForumdocuments041122Hussain041122pdf
An attempt to correct
3122015 Ajaz S Hussain PhD 39
httpipecamericasorgsystemfilesKeyNoteEF13May11LawrenceYu(FDA)pdf
Recent challenges
3122015 Ajaz S Hussain PhD 40
Th
e V
oic
e o
f th
eA
mer
ican
P
sych
iatr
ic A
sso
ciat
ion
and
th
e P
sych
iatr
ic C
om
mu
nit
y
Physicians Question FDAs Confidence in Generic Drugs Safety Efficacy (OCTOBER 24 2014)
bull ldquomost patientsrdquo is not the same asldquo all patientsrdquo and whether the 24 to 36 normal subjects used in the agencys bioequivalency tests represents the full range of individual variation in the way drugs are absorbed across the pharmaceutical using population is uncertain
bull Individuals can sometimes be allergic and react differently to whatever substance goes into making up the capsule or the tablet
FDA Flags Generic Versions of ADHD Medication(NOVEMBER 14 2014)
bull FDA changed the therapeutic equivalence (TE) rating from AB to BXmdashmeaning that the products are still approved and can be prescribed but are no longer recommended as automatic substitutes
RLD Variability Can be a block-buster opportunityFocus on lsquocontrol strategyrsquo
bull Overcoming CP amp IP provide FDA a submission they need to address CP
bull Then begin with QTPP CQArsquos hellip skip lsquodesign spacersquo and focus on lsquocontrol strategy
bull The entire development team should read the complete package insert of RLD
bull Discuss to ensure a common understandingbull Failure modes amp intended use
bull Pharmaceutical Equivalence
bull Bioequivalence
bull Other studies
QbD Challenges
3122015 Ajaz S Hussain PhD 41
NewRegulators are not prepared to handle QbD applications
NewMisalignment of international regulatory authorities
New and Generics
RampD incentivized for lsquoshots on the goalrsquo not QbD
GenericsLack of belief in business case ndash lsquoGenerics are all about file first figure out laterrsquo
Biologics Lack of technology to execute
Ted Fuhr Mackinsey amp Company June 2010 FDA Advisory Committee
Summary
bull Excipient functionality can contribute in critical ways to product quality amp performance adequate control is necessary
bull Our databases tools and knowledge are lagging behind the rapidly increasing complexity and uncertainty
bull Risk to quality and to business is increasing and regulatory transitions pose additional difficulties
bull Effective knowledge management ndash IT and Human practices ndash is critical for organizational lsquobottom-linersquo
bull We all must come together collaboratively to address the urgent needs we owe it to the patients we serve
3122015 Ajaz S Hussain PhD 42
Knowledge Management amp Culture of Quality
Ajaz S Hussain PhD
Insight Advice amp Solutions LLCMaryland USA
Executive Director the National Institute for Pharmaceutical Technology amp Education
3122015 Ajaz S Hussain PhD 43
3122015 Ajaz S Hussain PhD 44
Life-cycle approach needed for knowledge management
Investigational ProductscGMPs
DevelopmentTechnology
TransferCommercial
ManufacturingDiscontinuation
Management Responsibility
Process Performance amp Product Quality Monitoring SystemCAPA Change Management Management Review
PQS Elements
Knowledge ManagementQuality Risk ManagementEnablers
ICH Q10 KM is a systematic approach to acquiring analyzing storing and disseminating information related to products manufacturing processes and components
Based on ICH Q10
ldquowe can be blind to the obvious and we are also blind to our blindnessrdquo
Daniel Kahneman Thinking Fast and Slow
3142015 Ajazajazhussaincom 45
httpwebmiteduperscipeopleadelsoncheckershadow_proofhtml
3122015 Ajaz S Hussain PhD 46
1938 The Federal Food Drug and Cosmetic (FDC)
bull 1937 Elixir of Sulfanilamide
1962 Kefauver-Harris Drug Amendments
bull 1962 Thalidomide
bull 1960 Color Additive Amendment
bull 1958 Food Additives Amendment GRAS
bull 1960 Color Additive Amendment
bull 1958 Food Additives Amendment GRAS
1992 Generic Drug Enforcement Act
bull1989 L-Tryptophan
bull 1989 Generic Drug Scandal
bull 1988 Food and Drug Administration Act
bull 1984 Fines Enhancement Laws Drug Price Competition and Patent Term Restoration Act
2012 Food and Drug Administration Safety and Innovation Act (FDASIA)
bull 2007 Heparin Disaster
2013 Pandemic and All-Hazards Preparedness Reauthorization Act (PAHPRA) Drug Quality and Security Act
bull 2012 The Deadly Meningitis Outbreak
Past 70 years 1937 ndash 2007 The diethylene glycol (DEG) narrative
3122015 Ajaz S Hussain PhD 47
0
5
10
15
20
25
30
35
Yea
rs
DEG Years since the previous incident
0
50
100
150
200
250
300
350
Number of Reported Deaths
1937
Eli
xir
of
Sulf
anil
amid
e
2007T
ootp
aste
conta
min
atio
n
0 70 years 0 70 years
Frequent reports
Mumbai Mumbai
Data from Excipient Fest Janeen Skutnik Chair ndashIPECAmericas 2009
Past 70+ years DEG contamination or economically motivated adulteration
3122015 Ajaz S Hussain PhD 48
Reported cases underestimate the real tragedy rapid intervention may not occur
Epidemic of Pediatric Deaths From Acute Renal Failure Caused by
Diethylene Glycol Poisoning JAMA 1998279(15)1175-1180
doi101001jama279151175
Month of hospital admission for children with
acute renal failure Haiti
October 1995-October 1996
Diethylene glycol poisoning in Gurgaon India 1998Bulletin of the World Health Organization 2001 79 88ndash95
We report a second episode of poisoning occurring in 1998 in
India as a result of children ingesting diethylene glycol at
least 33 children are known to have died
At the beginning of the investigation we never imagined that
contaminated medicine was causing acute renal failure in
children
A brand of cough expectorant manufactured by a local
pharmaceutical company was found by the Central Drugs
Laboratory Calcutta to contain 175 (vv) diethylene
glycol
The district and state drug controller had tested many
samples using thin layer chromatography before a sample of
medicine tested positive for diethylene glycol at the Central
Drugs Laboratory None of the earlier samples was found to
be contaminated
3122015 Ajaz S Hussain PhD 49
Guidance for Industry Testing of
Glycerin for Diethylene Glycol
CDER May 2007 Compliance
1 Manufacturers did not perform full
identity testing on the glycerin raw
material including tests to quantify
the amount of DEG
2 Relied on the certificate of analysis
(COA)
3 The origin of the glycerin was not
easily apparent from the COA
4 The COA was often a copy of a COA
on the letterhead of the distributor
5 The chain of custody or distribution
history of the glycerin was also not
readily known
USP Glycerin Monograph
Type of Posting Revision Bulletin
Posting Date 04ndashFebndash2009
Official Date 01ndashMayndash2009
Because of the serious hazards
associated withhellip and in response to
recommendations set forth in the
FDA Guidance for Industry Testing
of Glycerin for Diethylene Glycol
published in May 2007 USP has
revised the USP Glycerin monograph
Because diethylene glycol and
ethylene glycol are considered
unacceptable toxic substances the
testing of USP Glycerin should
demonstrate the absence of these
substances
April 2007 FDA request to
USP to revise the Glycerin
monographrsquos
IDENTIFICATION section
Revision includes adding ndash
Identification test B LIMIT OF
DIETHYLENE GLYCOL AND
ETHYLENE GLYCOL to detect
and quantify DEGEG in Glycerin
minus Is no longer part of the impurity
testing
ldquoLimit of DEG and Related
Compoundsrdquo minus Introduces a
capillary gas-chromatographic
(GC) method with flame ionization
detection (FID) minus Limit of NMT
010 each for diethylene glycol
and ethylene glycol is found
70+ years to get here how difficult will it be to change habits such as lsquoblind reliance of COArsquo
3122015 Ajaz S Hussain PhD 50
Personality and Habitual Frame Biases
Myers Brigs ENTJ (first tested at FDA)
S
TF
Expanded frame
future
possibilities
objective lsquocause
and effectrsquo
Expanded frame
future
possibilities
people and
relationships
Narrow frame
the present
individuals and
relationships
Narrow frame
the present
objective
cause and
effect
N
Based on Stanford Webinar - How to Overcome the Top 3 MegaBiases in Decision-Making
Stanford Universityrsquos Strategic Decision and Risk Management certificate program
From Mapping a Managers Brain on Incentives
Social
influences
Relative
thinking
UncertaintyComplexity
By Design Intention to act consciously
bull In the interest of patients and to continually improve this ability bull To provide a healing touch ndash one life at a time in what we do and how we
do it
1292014 Ajazajazhussaincom 51
Consciously
Scientific methodology
Engineering Design
Plan-Do-Check-Act
Subconsciously
Habits (work to get rid of bad ones)
Habits (work to cultivate good one)
Keystone habits (Safety Alcoa ALCOA of data integrity)
The Power of Habit Why We Do What We Do in Life and Business Charles Duhigg (2012)
httpwwwslideshareneta2zpharmscipharmaceutical-culture-of-quality
What does it take to come out of the cGMP crisis
Persuasive demonstration of
(1) Ability to face facts
(2) Legal amp regulatory requirements
3) Systems approach to quality
4) Changing behavior amp culture
What is often missed or is unconvincing is how you will strengthen culture of quality
ldquoLet one who wants to move and convince others first be convinced and moved themselvesrdquo Thomas Carlyle
Signals that question the competence motivation andor integrity of company personnel
Do not defend the plainly indefensible it adds further serious credibility costs
3142015 Ajazajazhussaincom 52
Quality is everyones responsibility
Lack of knowledge that is
the problem
If you do not know how to ask the
right question you discover nothing
If you cant describe what you
are doing as a process you dont know what youre
doing
Rational behavior requires theory
Reactive behavior requires only reflex
action
Whenever there is fear you will get wrong figures
3142015 Ajazajazhussaincom 53
Selected quotes W Edwards Deming
3142015 Ajazajazhussaincom 54
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
ldquoWE CANNOT CHANGE THE HUMAN CONDITION BUThellipWE CAN CHANGE THE CONDITIONS UNDER WHICH HUMANS WORKrdquo JAMES REASON
Disregard to Malice
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 55
ldquohelliprecords not completed
contemporaneouslyrdquo
ldquohellipobserved analyst back-date logbooksrdquo
ldquohelliptrial injectionshelliprdquo
ldquohellipresults failing specifications are
retested until acceptable results are obtainedhelliprdquo
ldquohellipover-writing electronic raw datahelliprdquo
ldquohellipOOS not investigates per XYZ SOPrdquo
ldquohellipappropriate controls not establishedhelliprdquo
Each additional observation adds
reasons to confirm that this is very likely a system
with intentional lsquoholesrsquo in its
defenses
Preconditions
Rationalization amp Attitude
Pressure amp Incentive
Opportunity ndashlsquoholes in the QMSrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 56
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 57
Attitude towards the behavior
Subjective norm
Perceived behavioral
control
IntentionFuture
Behavior
usually found to predict behavioral intentions with a high degree of accuracy
intentions in combination with perceived behavioral control can account for a considerable proportion of variance in behavior
PastBehavior
Ajen I The theory of planned behavior ORGANIZATIONAL BEHAVIOR AND HUMAN DECISION PROCESSES 50 179-211 (1991)
Heparin tragedy 2007 and 2008
FDA reports 149 deaths with allergic or hypersensitivity symptoms during that period
bull Contaminated heparin from China
QC Testing
bull Initial testing failed to detect the contaminant
Pharmacovigilence
bull Signals in the pharmacovigilence systems responded slowly and
Eventually the severity of reactions associated made it likely that the contamination would be detected
bull too late for those who died or were injured
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 58
Congressman Shimkus When the drug safety system fails people get sick Some die
bull Some of these people are already very vulnerable and proving the cause of harm from impurities adulteration and counterfeits can be elusive
It is hard to detect harm
bull Certainly the companies are obligated to ensure a culture of quality and maintain vigilance as well This reflects a systems approach to safety
FDA inspectors look for a culture of quality at
manufacturing facilities
bull FDA policies led to the failure to inspect the Chinese plantThis system approach wasnt at
play here
bull While it doesnt deny the counterfeit source tries to say that counterfeits didnt cause the reaction as if the adulteration itself was no big deal Is this an acceptable mindset helliphelliphellip
This brings me to China and its quality culture or lack thereof
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 59
ONE HUNDRED TENTH CONGRESS SECOND SESSION APRIL 29 2008 Serial No 110-109
21 CFR PART 211 SUBPARTS -Deviations signal gaps in CoQ
bullGENERAL PROVISIONSA
bullORGANIZATION AND PERSONNELB
bullBUILDINGS AND FACILITIESC
bullEQUIPMENTD
bullCONTROL OF COMPONENTS AND DRUG PRODUCT CONTAINERS AND CLOSURESE
bullPRODUCTION AND PROCESS CONTROLSF
bullPACKAGING AND LABELING CONTROLG
bullHOLDING AND DISTRIBUTIONH
bullLABORATORY CONTROLSI
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 60
For example the combinationhellip
The Power of Habit Why We Do What We Do in Life and Business Charles Duhigg (2012)
bull Scientific methodology
bull Engineering Design
bull Plan-Do-Check-ActConsciously
bull Habits (work to get rid of bad ones)
bull Habits (work to cultivate good one)
bull Keystone habits (Safety Alcoa ALCOA of data integrity)
Subconsciously
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 61
CoQ How
bull What are the predictors of CoQCoQ Manifests by Design -
lsquoquality by designrsquo the foundation
bull 1 2 3When do people change their behaviors
bull A B C D (any body can dance)What makes a QMS effective
bull X Y ZWhen proactive compliance occurs
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 62
Going beyond rules pays
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 63
Human behavior Connecting the Dots With the Right Connectors
GXPs ndash rational behaviors
How proactive compliance is achieved X Y Z
Quality Management System
What makes a QMS reliable A B C D
Culture of Quality
Why people change their behavior 1 2 3
Human Behaviors Beyond GXPs
Predictors of Culture of Quality
Why What and How of Culture of Quality
9192014 copy Ajaz S Hussain | INSIGHT ADVICE amp SOLUTIONS LLC 64
Predictors of CoQ Act consciously in the interest of patients ndash when no one is looking
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 65
Only four attributes
actually predict a culture of
quality
Leadership Emphasis
Message Credibility
Peer Involvement
Employee Empower-ment
People will change their
behavior if they see the new behavior as
Normal
(1)
Rewarding
(2)
Easy
(3)
Dr W Edwards Demingrsquos - ldquoOut of the crisisrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 66
The journey requires leadership
with Profound Knowledge as a
guide
bull As leaders responsible for system change top management is most in need of profound knowledge
bull Quality is often determined in the boardroom
bull Problems arise when management reacts to common cause or chance variation as if it were special cause variation
bull Prediction based in theory provides a foundation for planning a course of action Plan ndash Do ndash Check ndash Act
bull The leader serves the people with clear vision and guidance to empower them To be empowered is to share ownership in the identity
bull Giving people a certain degree of control over their work fulfills the need for freedom and provides opportunity for taking joy in work
Profound Knowledge as a guide
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 67
Appreciation for a System
Theory of Knowledge
Knowledge about
Variation
Human Behavior -Psychology of Change
A
B
C
D+
Systems Approach for ErrorDeviation Management
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 68
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
Human error models and management J Reason BMJ 320 768ndash770 (2000)
D+
Culture of Error Management परबधनbull Error strain
bull Covering upFear of Errors
bull Anticipation
bull Risk takingAwareness
bull Development QbDRFT
bull Error detection Communication
bull Analyzing errors Correction
Mastery orientation
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 69
Dots amp Connections
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 70
CoQ
1
2
3
QMS
A
B
C
D
GXP Behaviors
X
Y
Z
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 71
Culture of Quality
Normal
Rewarding
Easy
QMS
System
Knowledge
Variation
Behavior
Behavior -GXPs
Fear Removed
Mastery
Awareness
EnvironmentLeadership Emphasis
Message Credibility
Peer Involvement
Employee Empowerment
Connect to CoQ
Connect to GXPs
A Framework and a Tool (for gap analysis)
Also relevant today Pattern Recognition
3122015 Ajaz S Hussain PhD 10
Preliminary illustration of a concept Going forward expect to see regulators utilize state-of ndashthe ndashart pattern recognition and modeling systems
Effective Regulatory System Importance of Process Understanding and Quality by DesignAjaz Hussain Pharmaceutical Quality Forum 3rd Symposium November 2004 Tokyo Japan
Academic research
University of Cincinnati (1989-1994)
bull Formulation designbull Several projects ndash oral topical and
transdermalbull Example Elaborating the utility of
Transcutolreg (Gattefosseacute)
bull Computer aided formulation designbull Artificial Neural Network based
lsquoexpert systemsrsquobull Example Prototype for lsquoTechnical
Service Supportrsquo (funding - Aqualon)
NIPTE (Currently)
bull NIPTErsquos Excipient Knowledge basebull Available since 2007 at
httppharmahuborg
bull The goal of this project is to share information and modeling tools to support pharmaceutical product
3122015 Ajaz S Hussain PhD 11
Prototype for lsquoTechnical Service Supportrsquo
3122015 Ajaz S Hussain PhD 12
From a lsquoDatabasersquo to a lsquoKnowledge basersquo
bull lsquoLook-up tablesrsquo to lsquoAbility to Predictrsquo
bull Ability to predict = generate hypotheses
bull Ability (simulate) ask questions - what if
NIPTE Knowledge Management
3122015 Ajaz S Hussain PhD 13
Contact Prof Hoag Univ Maryland shoagrxumarylandedu
3122015 Ajaz S Hussain PhD 14
NIPTE Knowledge Management
This study was funded by the FDA-sponsored contract ldquoDevelopment of Quality by Design (QbD) Guidance Elements on Design Specifications across Scales with Stability Considerationsrdquo (contract number HHSF223200819929C)
3122015 Ajaz S Hussain PhD 15
Current hot topics ndashrsquoexcipientsrsquo regulatory trends amp insights ExcipientFest on 28-29 April 2015 in Washington Organizational Changes CDERFDA and Inspectional Trendshellip(Complex Genericshellip Continuous Manufacturing)
3122015 Ajaz S Hussain PhD 16
Current experience with lsquoSupplier Qualificationrsquo
bull Recent observations are summarized in this report by ECA Academy (21012015) Areas of attention
bull Accuracy and completeness of administrative documentation
bull Evidence to justify excipient and supplier qualification
bull Risk-assessment and effective integration within in QMS
bull Quality agreements
bull Going forward I envision a need to emphasize a life-cycle approach (eg linking to CAPA change control)
3122015 Ajaz S Hussain PhD 17
FDArsquos Inactive Ingredient Database -statusbull Substance Registration System (SRS)
bull Generic listing vs Specific Grade listing for commonly used excipients ndashmax precedent levels
bull Listing of Mixtures
bull The UNII code confusing the National Library of Medicine yet to finalize standards for assigning UNII codes for polymers
bull Individual Grades vs Family Data
bull Legal status of the IID and FDA communications of changes to the IID
bull DMF Implications
bull Impact on ANDAs ndash lsquoDelaysrsquo amp lsquoRefuse to File Lettersrsquo
3122015 Ajaz S Hussain PhD 18
3122015 Ajaz S Hussain PhD 19
Inactive Ingredientsrsquo to lsquoExcipientsrsquo to lsquoFunctionalityrsquo Where are we in this journeylsquo
Status of lsquoSubstances In Regulatory Practicersquo
Clearly we need a global database with improved precision and accuracy of naming (and coding) to identify describe compare and link (to products and AERs)
INDs NDAs BLAs CFRrsquos Orphan Drug ApplicationsProducts that Contain Each Substance
Pharmacological ClassificationActive Moieties Related Moieties and Salts
LADMERMetabolites
Metabolic Enzymes Transporters and EffectsDrug target (therapeutic and other) type of interaction
Solubility and Permeability (BCS)Protein Binding
Impurities and Related Substance
ISO 11238 (ISO IDMP) some challenges
Both substances amp specified substances
Implementation in EU EMA Task force
Global Ingredients Archive System (GInAS)
3122015 Ajaz S Hussain PhD 20
The War Against Fake Medicines Update on FDASIA - Guidance and Impact on Excipient Suppliers and
Users QbD Sampling Guidelines The NSFIPECANSI 363 2014 GMP standardsexplained Good Supply Practices ndash Using Cross Industry Knowledge to Devise Pragmatic Solutions Impact
of Non-harmonized Standards and What is Needed to Achieve Harmonization Advancements in the Question Based Review approach and various other excipient specific related topics An Overview of the FDA OGD
IID EWG activities Effective Sourcing and Purchasing of Excipients
Industry Collaboration for Science Based Implementation of Elemental Impurities Challenges And Opportunities In Developing
And Modernizing Public Standards For NF Excipients Monographs For Regulated Drug
Products Marketed In The USA Future Pharma Manufacturing Efficiencies and the Role of Innovative Excipient Technologies
IPEC ExcipientFest 2015
Current Hot Topics ExcipientFest on 28-29 April 2015 in Washington
3122015 Ajaz S Hussain PhD 21
The War Against Fake Medicines Update on FDASIA - Guidance and Impact on Excipient
Suppliers and Users QbD Sampling Guidelines The NSFIPECANSI 363 2014 GMP standards explained Good Supply Practices ndash Using Cross Industry Knowledge to Devise
Pragmatic Solutions Impact of Non-harmonized Standards and What is Needed to Achieve
Harmonization Advancements in the Question Based Review approach and various other
excipient specific related topics An Overview of the FDA OGD IID EWG activities Effective
Sourcing and Purchasing of Excipients Industry Collaboration for Science Based Implementation of Elemental Impurities Challenges And
Opportunities In Developing And Modernizing Public Standards For NF ExcipientsMonographs For Regulated Drug Products Marketed In The USA Future Pharma Manufacturing Efficiencies and the Role of Innovative Excipient Technologies
IPEC ExcipientFest 2015
Inspectional trends in data integrity (Bangalore Nov
2014)
22(d)
192
100(a)
160(b)
110(a)
67(b)
68(a)
25(a)
67(a)
100(b)
Recurring 483 Observations Top 10
22(d) 192 100(a) 160(b)110(a) 67(b) 68(a) 25(a)67(a) 100(b)
Jeff Medwid NIPTE-FDA Conference 13 June 2012
International Society for Pharmaceutical Engineering (ISPE) in conjunction with McKinsey amp Co will release preliminary data and findings from its Quality Metrics Pilot Program at the ISPE Quality Metrics Summit on April 21ndash22 in Baltimore
FDA Launches New Drug Quality Office With Goal of Improving the Pharmaceutical IndustryPosted 13 January 2015By Alexander Gaffney RAC
FDArsquos New Pharma Quality
Office Will Take a Team Approach
Yu Explains
Regulatory Recon Investigations Find Major Quality Problems at Indian Pharma Companies (3 December 2014)Posted 03 December 2014By Alexander Gaffney RAC
Currently the environment is complex there is high uncertainty D
on
rsquot f
org
et
fun
ctio
na
lity
o
f e
xcip
ien
ts i
s im
po
rta
nt
3122015 Ajaz S Hussain PhD 22
Need for urgent progress lsquoInactive Ingredientsrsquo to lsquoExcipientsrsquo to lsquoFunctional Excipientsrsquo
Importance of assuring quality and controlling
variability of excipients
including their lsquofunctionalityrsquo has
long been recognized
bull Increasing complexity of drugs their delivery and failure modes
bull Patient (eg pediatric) relevant failure modes
bull Simple generics to complex generics amp biosimilars
Urgent need to address gaps in the FDArsquos Inactive Ingredient Database
3122015 Ajaz S Hussain PhD 23
Trends Lab amp Manufacturing
ldquoDeletion of Datardquo
ldquoTesting Into Compliancerdquo
ldquoBMR manipulation is a slippery sloperdquo
ldquoSuggestive of faulty manufacturing process or practices even if this is not the caserdquo
ldquoIt is top managementrsquos responsibility to ensure the training program is robust and effectiverdquo
Inspectional trends in data integrity (Bangalore Nov 13 2014 - Nov 14 2014)
Growing concern some
companies ldquodata looks too good
to be truerdquo
3122015 Ajaz S Hussain PhD 24
GMP Compliance amp Remediation
Jeff Medwid NIPTE-FDA Conference 13 June 2012
QbD amp QbR Clarity on Critical Functionality
FDArsquos New Pharma Quality
Office Will Take a Team
Approach Yu Explains
Carmelo Rosa MS PsyD November 2014
Urgent Need amp Opportunity
To align amp ensure sound scientific basis of these critical regulatory decisions
FDA CDER OPQ Plans for Surveillance of Pharmaceutical Quality
Teresa Mullin PhD December 2014
3122015 Ajaz S Hussain PhD 25
Need for a comprehensive (excipient) knowledge base
Teresa Mullin PhD December 2014
3122015 Ajaz S Hussain PhD 26
Why attention to (excipient) knowledge management is criticalSpecifically for physical attributes functionality performance
3122015 Ajaz S Hussain PhD 27
3122015 Ajaz S Hussain PhD 28
Today there are several product categories (eg controlled release inhalation products DPIrsquos topical transdermal liposomal products etc) which requires an exquisite control of complex physical material and product attributes (functionality)
Many of our current measurement systems need improvement
We depend on these to ensure control of lot-lot variability
Measurement system capability must be confirmed to be able to assess process capability (calibration amp Gauge RampR)
Life-cycle approach to quality continued process verification (FDArsquos Process Validation 2011) is a safety net
Supplier amp Excipient Qualification amp Process Validation
Measurement System Analysis
bull From lsquocalibrationrsquo to lsquoGauge RampRrsquoParticularly for physical
attributes destructive analysis
bull Many (including regulators) have not yet understood its importance
Gauge RampR well established but not commonly practiced
bull Measurement system in a state of control effective CAPA quality metrics Culture of Quality
With the move towards Statistical Process Control
bull Demonstrate equivalent in vitro performance more exacting criteria
Development of complex generic products (ER
Injectable Inhalation etc)
3122015 Ajaz S Hussain PhD 29
Process Validation (2011) Statistical Confidence Continued Process Verificationhellip
3122015 Ajaz S Hussain PhD 30
httpwwwslideshareneta2zpharmsciperformance-testing-pharmaceutical-quality-2004(accessed 6 December 2014)
3122015 Ajaz S Hussain PhD 31
Supplier amp Excipient Qualification amp CAPA
Out of Specification events are difficult to resolve
Excipient functionality can be a significant contributing factor
Sometimes reluctantly have to settle with - ldquoRoot cause unknown
600 days
I have inserted the ldquo600 daysrsquo on the figure ndash this is based on cases I have seen while at FDA)
3122015 Ajaz S Hussain PhD 32
Prevention of OOS and Effective CAPA needs a focus on critical functional attributes
Out of Specification events are difficult to resolve
Excipient functionality can be a significant contributing factor
Sometimes reluctantly have to settle with - ldquoRoot cause unknown
Compendial standards and manufacturing
3122015 Ajaz S Hussain PhD 33
Practice Control Process Maturity
Initial
bull Unpredictable
Managed
bull Characterized but reactive
Defined
bull Characterized proactive
Measured amp Controlled
bull In control
Optimizing
bull Focus on improvement
3122015 Ajaz S Hussain PhD 34
Capability Maturity Model Integration Carnegie Mellon University
A validated process
Maturity Level amp Assurance of Quality
Managed Characterized but reactive
High perceived risk of
lsquoCheating by Designrsquo
ldquoTrial Injectionsrdquo
ldquoTesting in to Compliancerdquo
Defined Characterized proactive
Lower level of assurance
Stopping amp Correcting
Batch Rejection
Measured amp
ControlledIn control
Quality by Design
Quality Assured
Improvement Opportunities
3122015 Ajaz S Hussain PhD 35
At the individual level in QC functionndash how often does this occur
attitude toward
performing the behavior
Process validation is
done so quality is good
test prone to error
ldquoBatch failure means I made
a mistakerdquo
subjective norm
documentation not critical
Compendial testing
sufficient
Indian regulators
collect amp test samples ndash no issue there
3122015 Ajaz S Hussain PhD 36
ldquoTesting into compliancerdquo
In general ndash low empowerment is a significant challenge (low perceived behavioral control) plus reasons to rationalizehellip
Excipient Functionality Can be critical for safety efficacy and quality
3122015 Ajaz S Hussain PhD 37
July 15 2005 FDA Public Health Advisory Safety Warnings Regarding Use of Fentanyl Transdermal (Skin) Patches
A pattern of failure Pharmaceutical Equivalence by Design (2004)
3122015 Ajaz S Hussain PhD 38
httpwwwnihsgojpdrugPhForumdocuments041122Hussain041122pdf
An attempt to correct
3122015 Ajaz S Hussain PhD 39
httpipecamericasorgsystemfilesKeyNoteEF13May11LawrenceYu(FDA)pdf
Recent challenges
3122015 Ajaz S Hussain PhD 40
Th
e V
oic
e o
f th
eA
mer
ican
P
sych
iatr
ic A
sso
ciat
ion
and
th
e P
sych
iatr
ic C
om
mu
nit
y
Physicians Question FDAs Confidence in Generic Drugs Safety Efficacy (OCTOBER 24 2014)
bull ldquomost patientsrdquo is not the same asldquo all patientsrdquo and whether the 24 to 36 normal subjects used in the agencys bioequivalency tests represents the full range of individual variation in the way drugs are absorbed across the pharmaceutical using population is uncertain
bull Individuals can sometimes be allergic and react differently to whatever substance goes into making up the capsule or the tablet
FDA Flags Generic Versions of ADHD Medication(NOVEMBER 14 2014)
bull FDA changed the therapeutic equivalence (TE) rating from AB to BXmdashmeaning that the products are still approved and can be prescribed but are no longer recommended as automatic substitutes
RLD Variability Can be a block-buster opportunityFocus on lsquocontrol strategyrsquo
bull Overcoming CP amp IP provide FDA a submission they need to address CP
bull Then begin with QTPP CQArsquos hellip skip lsquodesign spacersquo and focus on lsquocontrol strategy
bull The entire development team should read the complete package insert of RLD
bull Discuss to ensure a common understandingbull Failure modes amp intended use
bull Pharmaceutical Equivalence
bull Bioequivalence
bull Other studies
QbD Challenges
3122015 Ajaz S Hussain PhD 41
NewRegulators are not prepared to handle QbD applications
NewMisalignment of international regulatory authorities
New and Generics
RampD incentivized for lsquoshots on the goalrsquo not QbD
GenericsLack of belief in business case ndash lsquoGenerics are all about file first figure out laterrsquo
Biologics Lack of technology to execute
Ted Fuhr Mackinsey amp Company June 2010 FDA Advisory Committee
Summary
bull Excipient functionality can contribute in critical ways to product quality amp performance adequate control is necessary
bull Our databases tools and knowledge are lagging behind the rapidly increasing complexity and uncertainty
bull Risk to quality and to business is increasing and regulatory transitions pose additional difficulties
bull Effective knowledge management ndash IT and Human practices ndash is critical for organizational lsquobottom-linersquo
bull We all must come together collaboratively to address the urgent needs we owe it to the patients we serve
3122015 Ajaz S Hussain PhD 42
Knowledge Management amp Culture of Quality
Ajaz S Hussain PhD
Insight Advice amp Solutions LLCMaryland USA
Executive Director the National Institute for Pharmaceutical Technology amp Education
3122015 Ajaz S Hussain PhD 43
3122015 Ajaz S Hussain PhD 44
Life-cycle approach needed for knowledge management
Investigational ProductscGMPs
DevelopmentTechnology
TransferCommercial
ManufacturingDiscontinuation
Management Responsibility
Process Performance amp Product Quality Monitoring SystemCAPA Change Management Management Review
PQS Elements
Knowledge ManagementQuality Risk ManagementEnablers
ICH Q10 KM is a systematic approach to acquiring analyzing storing and disseminating information related to products manufacturing processes and components
Based on ICH Q10
ldquowe can be blind to the obvious and we are also blind to our blindnessrdquo
Daniel Kahneman Thinking Fast and Slow
3142015 Ajazajazhussaincom 45
httpwebmiteduperscipeopleadelsoncheckershadow_proofhtml
3122015 Ajaz S Hussain PhD 46
1938 The Federal Food Drug and Cosmetic (FDC)
bull 1937 Elixir of Sulfanilamide
1962 Kefauver-Harris Drug Amendments
bull 1962 Thalidomide
bull 1960 Color Additive Amendment
bull 1958 Food Additives Amendment GRAS
bull 1960 Color Additive Amendment
bull 1958 Food Additives Amendment GRAS
1992 Generic Drug Enforcement Act
bull1989 L-Tryptophan
bull 1989 Generic Drug Scandal
bull 1988 Food and Drug Administration Act
bull 1984 Fines Enhancement Laws Drug Price Competition and Patent Term Restoration Act
2012 Food and Drug Administration Safety and Innovation Act (FDASIA)
bull 2007 Heparin Disaster
2013 Pandemic and All-Hazards Preparedness Reauthorization Act (PAHPRA) Drug Quality and Security Act
bull 2012 The Deadly Meningitis Outbreak
Past 70 years 1937 ndash 2007 The diethylene glycol (DEG) narrative
3122015 Ajaz S Hussain PhD 47
0
5
10
15
20
25
30
35
Yea
rs
DEG Years since the previous incident
0
50
100
150
200
250
300
350
Number of Reported Deaths
1937
Eli
xir
of
Sulf
anil
amid
e
2007T
ootp
aste
conta
min
atio
n
0 70 years 0 70 years
Frequent reports
Mumbai Mumbai
Data from Excipient Fest Janeen Skutnik Chair ndashIPECAmericas 2009
Past 70+ years DEG contamination or economically motivated adulteration
3122015 Ajaz S Hussain PhD 48
Reported cases underestimate the real tragedy rapid intervention may not occur
Epidemic of Pediatric Deaths From Acute Renal Failure Caused by
Diethylene Glycol Poisoning JAMA 1998279(15)1175-1180
doi101001jama279151175
Month of hospital admission for children with
acute renal failure Haiti
October 1995-October 1996
Diethylene glycol poisoning in Gurgaon India 1998Bulletin of the World Health Organization 2001 79 88ndash95
We report a second episode of poisoning occurring in 1998 in
India as a result of children ingesting diethylene glycol at
least 33 children are known to have died
At the beginning of the investigation we never imagined that
contaminated medicine was causing acute renal failure in
children
A brand of cough expectorant manufactured by a local
pharmaceutical company was found by the Central Drugs
Laboratory Calcutta to contain 175 (vv) diethylene
glycol
The district and state drug controller had tested many
samples using thin layer chromatography before a sample of
medicine tested positive for diethylene glycol at the Central
Drugs Laboratory None of the earlier samples was found to
be contaminated
3122015 Ajaz S Hussain PhD 49
Guidance for Industry Testing of
Glycerin for Diethylene Glycol
CDER May 2007 Compliance
1 Manufacturers did not perform full
identity testing on the glycerin raw
material including tests to quantify
the amount of DEG
2 Relied on the certificate of analysis
(COA)
3 The origin of the glycerin was not
easily apparent from the COA
4 The COA was often a copy of a COA
on the letterhead of the distributor
5 The chain of custody or distribution
history of the glycerin was also not
readily known
USP Glycerin Monograph
Type of Posting Revision Bulletin
Posting Date 04ndashFebndash2009
Official Date 01ndashMayndash2009
Because of the serious hazards
associated withhellip and in response to
recommendations set forth in the
FDA Guidance for Industry Testing
of Glycerin for Diethylene Glycol
published in May 2007 USP has
revised the USP Glycerin monograph
Because diethylene glycol and
ethylene glycol are considered
unacceptable toxic substances the
testing of USP Glycerin should
demonstrate the absence of these
substances
April 2007 FDA request to
USP to revise the Glycerin
monographrsquos
IDENTIFICATION section
Revision includes adding ndash
Identification test B LIMIT OF
DIETHYLENE GLYCOL AND
ETHYLENE GLYCOL to detect
and quantify DEGEG in Glycerin
minus Is no longer part of the impurity
testing
ldquoLimit of DEG and Related
Compoundsrdquo minus Introduces a
capillary gas-chromatographic
(GC) method with flame ionization
detection (FID) minus Limit of NMT
010 each for diethylene glycol
and ethylene glycol is found
70+ years to get here how difficult will it be to change habits such as lsquoblind reliance of COArsquo
3122015 Ajaz S Hussain PhD 50
Personality and Habitual Frame Biases
Myers Brigs ENTJ (first tested at FDA)
S
TF
Expanded frame
future
possibilities
objective lsquocause
and effectrsquo
Expanded frame
future
possibilities
people and
relationships
Narrow frame
the present
individuals and
relationships
Narrow frame
the present
objective
cause and
effect
N
Based on Stanford Webinar - How to Overcome the Top 3 MegaBiases in Decision-Making
Stanford Universityrsquos Strategic Decision and Risk Management certificate program
From Mapping a Managers Brain on Incentives
Social
influences
Relative
thinking
UncertaintyComplexity
By Design Intention to act consciously
bull In the interest of patients and to continually improve this ability bull To provide a healing touch ndash one life at a time in what we do and how we
do it
1292014 Ajazajazhussaincom 51
Consciously
Scientific methodology
Engineering Design
Plan-Do-Check-Act
Subconsciously
Habits (work to get rid of bad ones)
Habits (work to cultivate good one)
Keystone habits (Safety Alcoa ALCOA of data integrity)
The Power of Habit Why We Do What We Do in Life and Business Charles Duhigg (2012)
httpwwwslideshareneta2zpharmscipharmaceutical-culture-of-quality
What does it take to come out of the cGMP crisis
Persuasive demonstration of
(1) Ability to face facts
(2) Legal amp regulatory requirements
3) Systems approach to quality
4) Changing behavior amp culture
What is often missed or is unconvincing is how you will strengthen culture of quality
ldquoLet one who wants to move and convince others first be convinced and moved themselvesrdquo Thomas Carlyle
Signals that question the competence motivation andor integrity of company personnel
Do not defend the plainly indefensible it adds further serious credibility costs
3142015 Ajazajazhussaincom 52
Quality is everyones responsibility
Lack of knowledge that is
the problem
If you do not know how to ask the
right question you discover nothing
If you cant describe what you
are doing as a process you dont know what youre
doing
Rational behavior requires theory
Reactive behavior requires only reflex
action
Whenever there is fear you will get wrong figures
3142015 Ajazajazhussaincom 53
Selected quotes W Edwards Deming
3142015 Ajazajazhussaincom 54
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
ldquoWE CANNOT CHANGE THE HUMAN CONDITION BUThellipWE CAN CHANGE THE CONDITIONS UNDER WHICH HUMANS WORKrdquo JAMES REASON
Disregard to Malice
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 55
ldquohelliprecords not completed
contemporaneouslyrdquo
ldquohellipobserved analyst back-date logbooksrdquo
ldquohelliptrial injectionshelliprdquo
ldquohellipresults failing specifications are
retested until acceptable results are obtainedhelliprdquo
ldquohellipover-writing electronic raw datahelliprdquo
ldquohellipOOS not investigates per XYZ SOPrdquo
ldquohellipappropriate controls not establishedhelliprdquo
Each additional observation adds
reasons to confirm that this is very likely a system
with intentional lsquoholesrsquo in its
defenses
Preconditions
Rationalization amp Attitude
Pressure amp Incentive
Opportunity ndashlsquoholes in the QMSrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 56
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 57
Attitude towards the behavior
Subjective norm
Perceived behavioral
control
IntentionFuture
Behavior
usually found to predict behavioral intentions with a high degree of accuracy
intentions in combination with perceived behavioral control can account for a considerable proportion of variance in behavior
PastBehavior
Ajen I The theory of planned behavior ORGANIZATIONAL BEHAVIOR AND HUMAN DECISION PROCESSES 50 179-211 (1991)
Heparin tragedy 2007 and 2008
FDA reports 149 deaths with allergic or hypersensitivity symptoms during that period
bull Contaminated heparin from China
QC Testing
bull Initial testing failed to detect the contaminant
Pharmacovigilence
bull Signals in the pharmacovigilence systems responded slowly and
Eventually the severity of reactions associated made it likely that the contamination would be detected
bull too late for those who died or were injured
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 58
Congressman Shimkus When the drug safety system fails people get sick Some die
bull Some of these people are already very vulnerable and proving the cause of harm from impurities adulteration and counterfeits can be elusive
It is hard to detect harm
bull Certainly the companies are obligated to ensure a culture of quality and maintain vigilance as well This reflects a systems approach to safety
FDA inspectors look for a culture of quality at
manufacturing facilities
bull FDA policies led to the failure to inspect the Chinese plantThis system approach wasnt at
play here
bull While it doesnt deny the counterfeit source tries to say that counterfeits didnt cause the reaction as if the adulteration itself was no big deal Is this an acceptable mindset helliphelliphellip
This brings me to China and its quality culture or lack thereof
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 59
ONE HUNDRED TENTH CONGRESS SECOND SESSION APRIL 29 2008 Serial No 110-109
21 CFR PART 211 SUBPARTS -Deviations signal gaps in CoQ
bullGENERAL PROVISIONSA
bullORGANIZATION AND PERSONNELB
bullBUILDINGS AND FACILITIESC
bullEQUIPMENTD
bullCONTROL OF COMPONENTS AND DRUG PRODUCT CONTAINERS AND CLOSURESE
bullPRODUCTION AND PROCESS CONTROLSF
bullPACKAGING AND LABELING CONTROLG
bullHOLDING AND DISTRIBUTIONH
bullLABORATORY CONTROLSI
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 60
For example the combinationhellip
The Power of Habit Why We Do What We Do in Life and Business Charles Duhigg (2012)
bull Scientific methodology
bull Engineering Design
bull Plan-Do-Check-ActConsciously
bull Habits (work to get rid of bad ones)
bull Habits (work to cultivate good one)
bull Keystone habits (Safety Alcoa ALCOA of data integrity)
Subconsciously
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 61
CoQ How
bull What are the predictors of CoQCoQ Manifests by Design -
lsquoquality by designrsquo the foundation
bull 1 2 3When do people change their behaviors
bull A B C D (any body can dance)What makes a QMS effective
bull X Y ZWhen proactive compliance occurs
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 62
Going beyond rules pays
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 63
Human behavior Connecting the Dots With the Right Connectors
GXPs ndash rational behaviors
How proactive compliance is achieved X Y Z
Quality Management System
What makes a QMS reliable A B C D
Culture of Quality
Why people change their behavior 1 2 3
Human Behaviors Beyond GXPs
Predictors of Culture of Quality
Why What and How of Culture of Quality
9192014 copy Ajaz S Hussain | INSIGHT ADVICE amp SOLUTIONS LLC 64
Predictors of CoQ Act consciously in the interest of patients ndash when no one is looking
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 65
Only four attributes
actually predict a culture of
quality
Leadership Emphasis
Message Credibility
Peer Involvement
Employee Empower-ment
People will change their
behavior if they see the new behavior as
Normal
(1)
Rewarding
(2)
Easy
(3)
Dr W Edwards Demingrsquos - ldquoOut of the crisisrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 66
The journey requires leadership
with Profound Knowledge as a
guide
bull As leaders responsible for system change top management is most in need of profound knowledge
bull Quality is often determined in the boardroom
bull Problems arise when management reacts to common cause or chance variation as if it were special cause variation
bull Prediction based in theory provides a foundation for planning a course of action Plan ndash Do ndash Check ndash Act
bull The leader serves the people with clear vision and guidance to empower them To be empowered is to share ownership in the identity
bull Giving people a certain degree of control over their work fulfills the need for freedom and provides opportunity for taking joy in work
Profound Knowledge as a guide
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 67
Appreciation for a System
Theory of Knowledge
Knowledge about
Variation
Human Behavior -Psychology of Change
A
B
C
D+
Systems Approach for ErrorDeviation Management
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 68
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
Human error models and management J Reason BMJ 320 768ndash770 (2000)
D+
Culture of Error Management परबधनbull Error strain
bull Covering upFear of Errors
bull Anticipation
bull Risk takingAwareness
bull Development QbDRFT
bull Error detection Communication
bull Analyzing errors Correction
Mastery orientation
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 69
Dots amp Connections
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 70
CoQ
1
2
3
QMS
A
B
C
D
GXP Behaviors
X
Y
Z
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 71
Culture of Quality
Normal
Rewarding
Easy
QMS
System
Knowledge
Variation
Behavior
Behavior -GXPs
Fear Removed
Mastery
Awareness
EnvironmentLeadership Emphasis
Message Credibility
Peer Involvement
Employee Empowerment
Connect to CoQ
Connect to GXPs
A Framework and a Tool (for gap analysis)
Academic research
University of Cincinnati (1989-1994)
bull Formulation designbull Several projects ndash oral topical and
transdermalbull Example Elaborating the utility of
Transcutolreg (Gattefosseacute)
bull Computer aided formulation designbull Artificial Neural Network based
lsquoexpert systemsrsquobull Example Prototype for lsquoTechnical
Service Supportrsquo (funding - Aqualon)
NIPTE (Currently)
bull NIPTErsquos Excipient Knowledge basebull Available since 2007 at
httppharmahuborg
bull The goal of this project is to share information and modeling tools to support pharmaceutical product
3122015 Ajaz S Hussain PhD 11
Prototype for lsquoTechnical Service Supportrsquo
3122015 Ajaz S Hussain PhD 12
From a lsquoDatabasersquo to a lsquoKnowledge basersquo
bull lsquoLook-up tablesrsquo to lsquoAbility to Predictrsquo
bull Ability to predict = generate hypotheses
bull Ability (simulate) ask questions - what if
NIPTE Knowledge Management
3122015 Ajaz S Hussain PhD 13
Contact Prof Hoag Univ Maryland shoagrxumarylandedu
3122015 Ajaz S Hussain PhD 14
NIPTE Knowledge Management
This study was funded by the FDA-sponsored contract ldquoDevelopment of Quality by Design (QbD) Guidance Elements on Design Specifications across Scales with Stability Considerationsrdquo (contract number HHSF223200819929C)
3122015 Ajaz S Hussain PhD 15
Current hot topics ndashrsquoexcipientsrsquo regulatory trends amp insights ExcipientFest on 28-29 April 2015 in Washington Organizational Changes CDERFDA and Inspectional Trendshellip(Complex Genericshellip Continuous Manufacturing)
3122015 Ajaz S Hussain PhD 16
Current experience with lsquoSupplier Qualificationrsquo
bull Recent observations are summarized in this report by ECA Academy (21012015) Areas of attention
bull Accuracy and completeness of administrative documentation
bull Evidence to justify excipient and supplier qualification
bull Risk-assessment and effective integration within in QMS
bull Quality agreements
bull Going forward I envision a need to emphasize a life-cycle approach (eg linking to CAPA change control)
3122015 Ajaz S Hussain PhD 17
FDArsquos Inactive Ingredient Database -statusbull Substance Registration System (SRS)
bull Generic listing vs Specific Grade listing for commonly used excipients ndashmax precedent levels
bull Listing of Mixtures
bull The UNII code confusing the National Library of Medicine yet to finalize standards for assigning UNII codes for polymers
bull Individual Grades vs Family Data
bull Legal status of the IID and FDA communications of changes to the IID
bull DMF Implications
bull Impact on ANDAs ndash lsquoDelaysrsquo amp lsquoRefuse to File Lettersrsquo
3122015 Ajaz S Hussain PhD 18
3122015 Ajaz S Hussain PhD 19
Inactive Ingredientsrsquo to lsquoExcipientsrsquo to lsquoFunctionalityrsquo Where are we in this journeylsquo
Status of lsquoSubstances In Regulatory Practicersquo
Clearly we need a global database with improved precision and accuracy of naming (and coding) to identify describe compare and link (to products and AERs)
INDs NDAs BLAs CFRrsquos Orphan Drug ApplicationsProducts that Contain Each Substance
Pharmacological ClassificationActive Moieties Related Moieties and Salts
LADMERMetabolites
Metabolic Enzymes Transporters and EffectsDrug target (therapeutic and other) type of interaction
Solubility and Permeability (BCS)Protein Binding
Impurities and Related Substance
ISO 11238 (ISO IDMP) some challenges
Both substances amp specified substances
Implementation in EU EMA Task force
Global Ingredients Archive System (GInAS)
3122015 Ajaz S Hussain PhD 20
The War Against Fake Medicines Update on FDASIA - Guidance and Impact on Excipient Suppliers and
Users QbD Sampling Guidelines The NSFIPECANSI 363 2014 GMP standardsexplained Good Supply Practices ndash Using Cross Industry Knowledge to Devise Pragmatic Solutions Impact
of Non-harmonized Standards and What is Needed to Achieve Harmonization Advancements in the Question Based Review approach and various other excipient specific related topics An Overview of the FDA OGD
IID EWG activities Effective Sourcing and Purchasing of Excipients
Industry Collaboration for Science Based Implementation of Elemental Impurities Challenges And Opportunities In Developing
And Modernizing Public Standards For NF Excipients Monographs For Regulated Drug
Products Marketed In The USA Future Pharma Manufacturing Efficiencies and the Role of Innovative Excipient Technologies
IPEC ExcipientFest 2015
Current Hot Topics ExcipientFest on 28-29 April 2015 in Washington
3122015 Ajaz S Hussain PhD 21
The War Against Fake Medicines Update on FDASIA - Guidance and Impact on Excipient
Suppliers and Users QbD Sampling Guidelines The NSFIPECANSI 363 2014 GMP standards explained Good Supply Practices ndash Using Cross Industry Knowledge to Devise
Pragmatic Solutions Impact of Non-harmonized Standards and What is Needed to Achieve
Harmonization Advancements in the Question Based Review approach and various other
excipient specific related topics An Overview of the FDA OGD IID EWG activities Effective
Sourcing and Purchasing of Excipients Industry Collaboration for Science Based Implementation of Elemental Impurities Challenges And
Opportunities In Developing And Modernizing Public Standards For NF ExcipientsMonographs For Regulated Drug Products Marketed In The USA Future Pharma Manufacturing Efficiencies and the Role of Innovative Excipient Technologies
IPEC ExcipientFest 2015
Inspectional trends in data integrity (Bangalore Nov
2014)
22(d)
192
100(a)
160(b)
110(a)
67(b)
68(a)
25(a)
67(a)
100(b)
Recurring 483 Observations Top 10
22(d) 192 100(a) 160(b)110(a) 67(b) 68(a) 25(a)67(a) 100(b)
Jeff Medwid NIPTE-FDA Conference 13 June 2012
International Society for Pharmaceutical Engineering (ISPE) in conjunction with McKinsey amp Co will release preliminary data and findings from its Quality Metrics Pilot Program at the ISPE Quality Metrics Summit on April 21ndash22 in Baltimore
FDA Launches New Drug Quality Office With Goal of Improving the Pharmaceutical IndustryPosted 13 January 2015By Alexander Gaffney RAC
FDArsquos New Pharma Quality
Office Will Take a Team Approach
Yu Explains
Regulatory Recon Investigations Find Major Quality Problems at Indian Pharma Companies (3 December 2014)Posted 03 December 2014By Alexander Gaffney RAC
Currently the environment is complex there is high uncertainty D
on
rsquot f
org
et
fun
ctio
na
lity
o
f e
xcip
ien
ts i
s im
po
rta
nt
3122015 Ajaz S Hussain PhD 22
Need for urgent progress lsquoInactive Ingredientsrsquo to lsquoExcipientsrsquo to lsquoFunctional Excipientsrsquo
Importance of assuring quality and controlling
variability of excipients
including their lsquofunctionalityrsquo has
long been recognized
bull Increasing complexity of drugs their delivery and failure modes
bull Patient (eg pediatric) relevant failure modes
bull Simple generics to complex generics amp biosimilars
Urgent need to address gaps in the FDArsquos Inactive Ingredient Database
3122015 Ajaz S Hussain PhD 23
Trends Lab amp Manufacturing
ldquoDeletion of Datardquo
ldquoTesting Into Compliancerdquo
ldquoBMR manipulation is a slippery sloperdquo
ldquoSuggestive of faulty manufacturing process or practices even if this is not the caserdquo
ldquoIt is top managementrsquos responsibility to ensure the training program is robust and effectiverdquo
Inspectional trends in data integrity (Bangalore Nov 13 2014 - Nov 14 2014)
Growing concern some
companies ldquodata looks too good
to be truerdquo
3122015 Ajaz S Hussain PhD 24
GMP Compliance amp Remediation
Jeff Medwid NIPTE-FDA Conference 13 June 2012
QbD amp QbR Clarity on Critical Functionality
FDArsquos New Pharma Quality
Office Will Take a Team
Approach Yu Explains
Carmelo Rosa MS PsyD November 2014
Urgent Need amp Opportunity
To align amp ensure sound scientific basis of these critical regulatory decisions
FDA CDER OPQ Plans for Surveillance of Pharmaceutical Quality
Teresa Mullin PhD December 2014
3122015 Ajaz S Hussain PhD 25
Need for a comprehensive (excipient) knowledge base
Teresa Mullin PhD December 2014
3122015 Ajaz S Hussain PhD 26
Why attention to (excipient) knowledge management is criticalSpecifically for physical attributes functionality performance
3122015 Ajaz S Hussain PhD 27
3122015 Ajaz S Hussain PhD 28
Today there are several product categories (eg controlled release inhalation products DPIrsquos topical transdermal liposomal products etc) which requires an exquisite control of complex physical material and product attributes (functionality)
Many of our current measurement systems need improvement
We depend on these to ensure control of lot-lot variability
Measurement system capability must be confirmed to be able to assess process capability (calibration amp Gauge RampR)
Life-cycle approach to quality continued process verification (FDArsquos Process Validation 2011) is a safety net
Supplier amp Excipient Qualification amp Process Validation
Measurement System Analysis
bull From lsquocalibrationrsquo to lsquoGauge RampRrsquoParticularly for physical
attributes destructive analysis
bull Many (including regulators) have not yet understood its importance
Gauge RampR well established but not commonly practiced
bull Measurement system in a state of control effective CAPA quality metrics Culture of Quality
With the move towards Statistical Process Control
bull Demonstrate equivalent in vitro performance more exacting criteria
Development of complex generic products (ER
Injectable Inhalation etc)
3122015 Ajaz S Hussain PhD 29
Process Validation (2011) Statistical Confidence Continued Process Verificationhellip
3122015 Ajaz S Hussain PhD 30
httpwwwslideshareneta2zpharmsciperformance-testing-pharmaceutical-quality-2004(accessed 6 December 2014)
3122015 Ajaz S Hussain PhD 31
Supplier amp Excipient Qualification amp CAPA
Out of Specification events are difficult to resolve
Excipient functionality can be a significant contributing factor
Sometimes reluctantly have to settle with - ldquoRoot cause unknown
600 days
I have inserted the ldquo600 daysrsquo on the figure ndash this is based on cases I have seen while at FDA)
3122015 Ajaz S Hussain PhD 32
Prevention of OOS and Effective CAPA needs a focus on critical functional attributes
Out of Specification events are difficult to resolve
Excipient functionality can be a significant contributing factor
Sometimes reluctantly have to settle with - ldquoRoot cause unknown
Compendial standards and manufacturing
3122015 Ajaz S Hussain PhD 33
Practice Control Process Maturity
Initial
bull Unpredictable
Managed
bull Characterized but reactive
Defined
bull Characterized proactive
Measured amp Controlled
bull In control
Optimizing
bull Focus on improvement
3122015 Ajaz S Hussain PhD 34
Capability Maturity Model Integration Carnegie Mellon University
A validated process
Maturity Level amp Assurance of Quality
Managed Characterized but reactive
High perceived risk of
lsquoCheating by Designrsquo
ldquoTrial Injectionsrdquo
ldquoTesting in to Compliancerdquo
Defined Characterized proactive
Lower level of assurance
Stopping amp Correcting
Batch Rejection
Measured amp
ControlledIn control
Quality by Design
Quality Assured
Improvement Opportunities
3122015 Ajaz S Hussain PhD 35
At the individual level in QC functionndash how often does this occur
attitude toward
performing the behavior
Process validation is
done so quality is good
test prone to error
ldquoBatch failure means I made
a mistakerdquo
subjective norm
documentation not critical
Compendial testing
sufficient
Indian regulators
collect amp test samples ndash no issue there
3122015 Ajaz S Hussain PhD 36
ldquoTesting into compliancerdquo
In general ndash low empowerment is a significant challenge (low perceived behavioral control) plus reasons to rationalizehellip
Excipient Functionality Can be critical for safety efficacy and quality
3122015 Ajaz S Hussain PhD 37
July 15 2005 FDA Public Health Advisory Safety Warnings Regarding Use of Fentanyl Transdermal (Skin) Patches
A pattern of failure Pharmaceutical Equivalence by Design (2004)
3122015 Ajaz S Hussain PhD 38
httpwwwnihsgojpdrugPhForumdocuments041122Hussain041122pdf
An attempt to correct
3122015 Ajaz S Hussain PhD 39
httpipecamericasorgsystemfilesKeyNoteEF13May11LawrenceYu(FDA)pdf
Recent challenges
3122015 Ajaz S Hussain PhD 40
Th
e V
oic
e o
f th
eA
mer
ican
P
sych
iatr
ic A
sso
ciat
ion
and
th
e P
sych
iatr
ic C
om
mu
nit
y
Physicians Question FDAs Confidence in Generic Drugs Safety Efficacy (OCTOBER 24 2014)
bull ldquomost patientsrdquo is not the same asldquo all patientsrdquo and whether the 24 to 36 normal subjects used in the agencys bioequivalency tests represents the full range of individual variation in the way drugs are absorbed across the pharmaceutical using population is uncertain
bull Individuals can sometimes be allergic and react differently to whatever substance goes into making up the capsule or the tablet
FDA Flags Generic Versions of ADHD Medication(NOVEMBER 14 2014)
bull FDA changed the therapeutic equivalence (TE) rating from AB to BXmdashmeaning that the products are still approved and can be prescribed but are no longer recommended as automatic substitutes
RLD Variability Can be a block-buster opportunityFocus on lsquocontrol strategyrsquo
bull Overcoming CP amp IP provide FDA a submission they need to address CP
bull Then begin with QTPP CQArsquos hellip skip lsquodesign spacersquo and focus on lsquocontrol strategy
bull The entire development team should read the complete package insert of RLD
bull Discuss to ensure a common understandingbull Failure modes amp intended use
bull Pharmaceutical Equivalence
bull Bioequivalence
bull Other studies
QbD Challenges
3122015 Ajaz S Hussain PhD 41
NewRegulators are not prepared to handle QbD applications
NewMisalignment of international regulatory authorities
New and Generics
RampD incentivized for lsquoshots on the goalrsquo not QbD
GenericsLack of belief in business case ndash lsquoGenerics are all about file first figure out laterrsquo
Biologics Lack of technology to execute
Ted Fuhr Mackinsey amp Company June 2010 FDA Advisory Committee
Summary
bull Excipient functionality can contribute in critical ways to product quality amp performance adequate control is necessary
bull Our databases tools and knowledge are lagging behind the rapidly increasing complexity and uncertainty
bull Risk to quality and to business is increasing and regulatory transitions pose additional difficulties
bull Effective knowledge management ndash IT and Human practices ndash is critical for organizational lsquobottom-linersquo
bull We all must come together collaboratively to address the urgent needs we owe it to the patients we serve
3122015 Ajaz S Hussain PhD 42
Knowledge Management amp Culture of Quality
Ajaz S Hussain PhD
Insight Advice amp Solutions LLCMaryland USA
Executive Director the National Institute for Pharmaceutical Technology amp Education
3122015 Ajaz S Hussain PhD 43
3122015 Ajaz S Hussain PhD 44
Life-cycle approach needed for knowledge management
Investigational ProductscGMPs
DevelopmentTechnology
TransferCommercial
ManufacturingDiscontinuation
Management Responsibility
Process Performance amp Product Quality Monitoring SystemCAPA Change Management Management Review
PQS Elements
Knowledge ManagementQuality Risk ManagementEnablers
ICH Q10 KM is a systematic approach to acquiring analyzing storing and disseminating information related to products manufacturing processes and components
Based on ICH Q10
ldquowe can be blind to the obvious and we are also blind to our blindnessrdquo
Daniel Kahneman Thinking Fast and Slow
3142015 Ajazajazhussaincom 45
httpwebmiteduperscipeopleadelsoncheckershadow_proofhtml
3122015 Ajaz S Hussain PhD 46
1938 The Federal Food Drug and Cosmetic (FDC)
bull 1937 Elixir of Sulfanilamide
1962 Kefauver-Harris Drug Amendments
bull 1962 Thalidomide
bull 1960 Color Additive Amendment
bull 1958 Food Additives Amendment GRAS
bull 1960 Color Additive Amendment
bull 1958 Food Additives Amendment GRAS
1992 Generic Drug Enforcement Act
bull1989 L-Tryptophan
bull 1989 Generic Drug Scandal
bull 1988 Food and Drug Administration Act
bull 1984 Fines Enhancement Laws Drug Price Competition and Patent Term Restoration Act
2012 Food and Drug Administration Safety and Innovation Act (FDASIA)
bull 2007 Heparin Disaster
2013 Pandemic and All-Hazards Preparedness Reauthorization Act (PAHPRA) Drug Quality and Security Act
bull 2012 The Deadly Meningitis Outbreak
Past 70 years 1937 ndash 2007 The diethylene glycol (DEG) narrative
3122015 Ajaz S Hussain PhD 47
0
5
10
15
20
25
30
35
Yea
rs
DEG Years since the previous incident
0
50
100
150
200
250
300
350
Number of Reported Deaths
1937
Eli
xir
of
Sulf
anil
amid
e
2007T
ootp
aste
conta
min
atio
n
0 70 years 0 70 years
Frequent reports
Mumbai Mumbai
Data from Excipient Fest Janeen Skutnik Chair ndashIPECAmericas 2009
Past 70+ years DEG contamination or economically motivated adulteration
3122015 Ajaz S Hussain PhD 48
Reported cases underestimate the real tragedy rapid intervention may not occur
Epidemic of Pediatric Deaths From Acute Renal Failure Caused by
Diethylene Glycol Poisoning JAMA 1998279(15)1175-1180
doi101001jama279151175
Month of hospital admission for children with
acute renal failure Haiti
October 1995-October 1996
Diethylene glycol poisoning in Gurgaon India 1998Bulletin of the World Health Organization 2001 79 88ndash95
We report a second episode of poisoning occurring in 1998 in
India as a result of children ingesting diethylene glycol at
least 33 children are known to have died
At the beginning of the investigation we never imagined that
contaminated medicine was causing acute renal failure in
children
A brand of cough expectorant manufactured by a local
pharmaceutical company was found by the Central Drugs
Laboratory Calcutta to contain 175 (vv) diethylene
glycol
The district and state drug controller had tested many
samples using thin layer chromatography before a sample of
medicine tested positive for diethylene glycol at the Central
Drugs Laboratory None of the earlier samples was found to
be contaminated
3122015 Ajaz S Hussain PhD 49
Guidance for Industry Testing of
Glycerin for Diethylene Glycol
CDER May 2007 Compliance
1 Manufacturers did not perform full
identity testing on the glycerin raw
material including tests to quantify
the amount of DEG
2 Relied on the certificate of analysis
(COA)
3 The origin of the glycerin was not
easily apparent from the COA
4 The COA was often a copy of a COA
on the letterhead of the distributor
5 The chain of custody or distribution
history of the glycerin was also not
readily known
USP Glycerin Monograph
Type of Posting Revision Bulletin
Posting Date 04ndashFebndash2009
Official Date 01ndashMayndash2009
Because of the serious hazards
associated withhellip and in response to
recommendations set forth in the
FDA Guidance for Industry Testing
of Glycerin for Diethylene Glycol
published in May 2007 USP has
revised the USP Glycerin monograph
Because diethylene glycol and
ethylene glycol are considered
unacceptable toxic substances the
testing of USP Glycerin should
demonstrate the absence of these
substances
April 2007 FDA request to
USP to revise the Glycerin
monographrsquos
IDENTIFICATION section
Revision includes adding ndash
Identification test B LIMIT OF
DIETHYLENE GLYCOL AND
ETHYLENE GLYCOL to detect
and quantify DEGEG in Glycerin
minus Is no longer part of the impurity
testing
ldquoLimit of DEG and Related
Compoundsrdquo minus Introduces a
capillary gas-chromatographic
(GC) method with flame ionization
detection (FID) minus Limit of NMT
010 each for diethylene glycol
and ethylene glycol is found
70+ years to get here how difficult will it be to change habits such as lsquoblind reliance of COArsquo
3122015 Ajaz S Hussain PhD 50
Personality and Habitual Frame Biases
Myers Brigs ENTJ (first tested at FDA)
S
TF
Expanded frame
future
possibilities
objective lsquocause
and effectrsquo
Expanded frame
future
possibilities
people and
relationships
Narrow frame
the present
individuals and
relationships
Narrow frame
the present
objective
cause and
effect
N
Based on Stanford Webinar - How to Overcome the Top 3 MegaBiases in Decision-Making
Stanford Universityrsquos Strategic Decision and Risk Management certificate program
From Mapping a Managers Brain on Incentives
Social
influences
Relative
thinking
UncertaintyComplexity
By Design Intention to act consciously
bull In the interest of patients and to continually improve this ability bull To provide a healing touch ndash one life at a time in what we do and how we
do it
1292014 Ajazajazhussaincom 51
Consciously
Scientific methodology
Engineering Design
Plan-Do-Check-Act
Subconsciously
Habits (work to get rid of bad ones)
Habits (work to cultivate good one)
Keystone habits (Safety Alcoa ALCOA of data integrity)
The Power of Habit Why We Do What We Do in Life and Business Charles Duhigg (2012)
httpwwwslideshareneta2zpharmscipharmaceutical-culture-of-quality
What does it take to come out of the cGMP crisis
Persuasive demonstration of
(1) Ability to face facts
(2) Legal amp regulatory requirements
3) Systems approach to quality
4) Changing behavior amp culture
What is often missed or is unconvincing is how you will strengthen culture of quality
ldquoLet one who wants to move and convince others first be convinced and moved themselvesrdquo Thomas Carlyle
Signals that question the competence motivation andor integrity of company personnel
Do not defend the plainly indefensible it adds further serious credibility costs
3142015 Ajazajazhussaincom 52
Quality is everyones responsibility
Lack of knowledge that is
the problem
If you do not know how to ask the
right question you discover nothing
If you cant describe what you
are doing as a process you dont know what youre
doing
Rational behavior requires theory
Reactive behavior requires only reflex
action
Whenever there is fear you will get wrong figures
3142015 Ajazajazhussaincom 53
Selected quotes W Edwards Deming
3142015 Ajazajazhussaincom 54
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
ldquoWE CANNOT CHANGE THE HUMAN CONDITION BUThellipWE CAN CHANGE THE CONDITIONS UNDER WHICH HUMANS WORKrdquo JAMES REASON
Disregard to Malice
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 55
ldquohelliprecords not completed
contemporaneouslyrdquo
ldquohellipobserved analyst back-date logbooksrdquo
ldquohelliptrial injectionshelliprdquo
ldquohellipresults failing specifications are
retested until acceptable results are obtainedhelliprdquo
ldquohellipover-writing electronic raw datahelliprdquo
ldquohellipOOS not investigates per XYZ SOPrdquo
ldquohellipappropriate controls not establishedhelliprdquo
Each additional observation adds
reasons to confirm that this is very likely a system
with intentional lsquoholesrsquo in its
defenses
Preconditions
Rationalization amp Attitude
Pressure amp Incentive
Opportunity ndashlsquoholes in the QMSrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 56
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 57
Attitude towards the behavior
Subjective norm
Perceived behavioral
control
IntentionFuture
Behavior
usually found to predict behavioral intentions with a high degree of accuracy
intentions in combination with perceived behavioral control can account for a considerable proportion of variance in behavior
PastBehavior
Ajen I The theory of planned behavior ORGANIZATIONAL BEHAVIOR AND HUMAN DECISION PROCESSES 50 179-211 (1991)
Heparin tragedy 2007 and 2008
FDA reports 149 deaths with allergic or hypersensitivity symptoms during that period
bull Contaminated heparin from China
QC Testing
bull Initial testing failed to detect the contaminant
Pharmacovigilence
bull Signals in the pharmacovigilence systems responded slowly and
Eventually the severity of reactions associated made it likely that the contamination would be detected
bull too late for those who died or were injured
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 58
Congressman Shimkus When the drug safety system fails people get sick Some die
bull Some of these people are already very vulnerable and proving the cause of harm from impurities adulteration and counterfeits can be elusive
It is hard to detect harm
bull Certainly the companies are obligated to ensure a culture of quality and maintain vigilance as well This reflects a systems approach to safety
FDA inspectors look for a culture of quality at
manufacturing facilities
bull FDA policies led to the failure to inspect the Chinese plantThis system approach wasnt at
play here
bull While it doesnt deny the counterfeit source tries to say that counterfeits didnt cause the reaction as if the adulteration itself was no big deal Is this an acceptable mindset helliphelliphellip
This brings me to China and its quality culture or lack thereof
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 59
ONE HUNDRED TENTH CONGRESS SECOND SESSION APRIL 29 2008 Serial No 110-109
21 CFR PART 211 SUBPARTS -Deviations signal gaps in CoQ
bullGENERAL PROVISIONSA
bullORGANIZATION AND PERSONNELB
bullBUILDINGS AND FACILITIESC
bullEQUIPMENTD
bullCONTROL OF COMPONENTS AND DRUG PRODUCT CONTAINERS AND CLOSURESE
bullPRODUCTION AND PROCESS CONTROLSF
bullPACKAGING AND LABELING CONTROLG
bullHOLDING AND DISTRIBUTIONH
bullLABORATORY CONTROLSI
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 60
For example the combinationhellip
The Power of Habit Why We Do What We Do in Life and Business Charles Duhigg (2012)
bull Scientific methodology
bull Engineering Design
bull Plan-Do-Check-ActConsciously
bull Habits (work to get rid of bad ones)
bull Habits (work to cultivate good one)
bull Keystone habits (Safety Alcoa ALCOA of data integrity)
Subconsciously
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 61
CoQ How
bull What are the predictors of CoQCoQ Manifests by Design -
lsquoquality by designrsquo the foundation
bull 1 2 3When do people change their behaviors
bull A B C D (any body can dance)What makes a QMS effective
bull X Y ZWhen proactive compliance occurs
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 62
Going beyond rules pays
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 63
Human behavior Connecting the Dots With the Right Connectors
GXPs ndash rational behaviors
How proactive compliance is achieved X Y Z
Quality Management System
What makes a QMS reliable A B C D
Culture of Quality
Why people change their behavior 1 2 3
Human Behaviors Beyond GXPs
Predictors of Culture of Quality
Why What and How of Culture of Quality
9192014 copy Ajaz S Hussain | INSIGHT ADVICE amp SOLUTIONS LLC 64
Predictors of CoQ Act consciously in the interest of patients ndash when no one is looking
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 65
Only four attributes
actually predict a culture of
quality
Leadership Emphasis
Message Credibility
Peer Involvement
Employee Empower-ment
People will change their
behavior if they see the new behavior as
Normal
(1)
Rewarding
(2)
Easy
(3)
Dr W Edwards Demingrsquos - ldquoOut of the crisisrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 66
The journey requires leadership
with Profound Knowledge as a
guide
bull As leaders responsible for system change top management is most in need of profound knowledge
bull Quality is often determined in the boardroom
bull Problems arise when management reacts to common cause or chance variation as if it were special cause variation
bull Prediction based in theory provides a foundation for planning a course of action Plan ndash Do ndash Check ndash Act
bull The leader serves the people with clear vision and guidance to empower them To be empowered is to share ownership in the identity
bull Giving people a certain degree of control over their work fulfills the need for freedom and provides opportunity for taking joy in work
Profound Knowledge as a guide
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 67
Appreciation for a System
Theory of Knowledge
Knowledge about
Variation
Human Behavior -Psychology of Change
A
B
C
D+
Systems Approach for ErrorDeviation Management
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 68
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
Human error models and management J Reason BMJ 320 768ndash770 (2000)
D+
Culture of Error Management परबधनbull Error strain
bull Covering upFear of Errors
bull Anticipation
bull Risk takingAwareness
bull Development QbDRFT
bull Error detection Communication
bull Analyzing errors Correction
Mastery orientation
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 69
Dots amp Connections
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 70
CoQ
1
2
3
QMS
A
B
C
D
GXP Behaviors
X
Y
Z
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 71
Culture of Quality
Normal
Rewarding
Easy
QMS
System
Knowledge
Variation
Behavior
Behavior -GXPs
Fear Removed
Mastery
Awareness
EnvironmentLeadership Emphasis
Message Credibility
Peer Involvement
Employee Empowerment
Connect to CoQ
Connect to GXPs
A Framework and a Tool (for gap analysis)
Prototype for lsquoTechnical Service Supportrsquo
3122015 Ajaz S Hussain PhD 12
From a lsquoDatabasersquo to a lsquoKnowledge basersquo
bull lsquoLook-up tablesrsquo to lsquoAbility to Predictrsquo
bull Ability to predict = generate hypotheses
bull Ability (simulate) ask questions - what if
NIPTE Knowledge Management
3122015 Ajaz S Hussain PhD 13
Contact Prof Hoag Univ Maryland shoagrxumarylandedu
3122015 Ajaz S Hussain PhD 14
NIPTE Knowledge Management
This study was funded by the FDA-sponsored contract ldquoDevelopment of Quality by Design (QbD) Guidance Elements on Design Specifications across Scales with Stability Considerationsrdquo (contract number HHSF223200819929C)
3122015 Ajaz S Hussain PhD 15
Current hot topics ndashrsquoexcipientsrsquo regulatory trends amp insights ExcipientFest on 28-29 April 2015 in Washington Organizational Changes CDERFDA and Inspectional Trendshellip(Complex Genericshellip Continuous Manufacturing)
3122015 Ajaz S Hussain PhD 16
Current experience with lsquoSupplier Qualificationrsquo
bull Recent observations are summarized in this report by ECA Academy (21012015) Areas of attention
bull Accuracy and completeness of administrative documentation
bull Evidence to justify excipient and supplier qualification
bull Risk-assessment and effective integration within in QMS
bull Quality agreements
bull Going forward I envision a need to emphasize a life-cycle approach (eg linking to CAPA change control)
3122015 Ajaz S Hussain PhD 17
FDArsquos Inactive Ingredient Database -statusbull Substance Registration System (SRS)
bull Generic listing vs Specific Grade listing for commonly used excipients ndashmax precedent levels
bull Listing of Mixtures
bull The UNII code confusing the National Library of Medicine yet to finalize standards for assigning UNII codes for polymers
bull Individual Grades vs Family Data
bull Legal status of the IID and FDA communications of changes to the IID
bull DMF Implications
bull Impact on ANDAs ndash lsquoDelaysrsquo amp lsquoRefuse to File Lettersrsquo
3122015 Ajaz S Hussain PhD 18
3122015 Ajaz S Hussain PhD 19
Inactive Ingredientsrsquo to lsquoExcipientsrsquo to lsquoFunctionalityrsquo Where are we in this journeylsquo
Status of lsquoSubstances In Regulatory Practicersquo
Clearly we need a global database with improved precision and accuracy of naming (and coding) to identify describe compare and link (to products and AERs)
INDs NDAs BLAs CFRrsquos Orphan Drug ApplicationsProducts that Contain Each Substance
Pharmacological ClassificationActive Moieties Related Moieties and Salts
LADMERMetabolites
Metabolic Enzymes Transporters and EffectsDrug target (therapeutic and other) type of interaction
Solubility and Permeability (BCS)Protein Binding
Impurities and Related Substance
ISO 11238 (ISO IDMP) some challenges
Both substances amp specified substances
Implementation in EU EMA Task force
Global Ingredients Archive System (GInAS)
3122015 Ajaz S Hussain PhD 20
The War Against Fake Medicines Update on FDASIA - Guidance and Impact on Excipient Suppliers and
Users QbD Sampling Guidelines The NSFIPECANSI 363 2014 GMP standardsexplained Good Supply Practices ndash Using Cross Industry Knowledge to Devise Pragmatic Solutions Impact
of Non-harmonized Standards and What is Needed to Achieve Harmonization Advancements in the Question Based Review approach and various other excipient specific related topics An Overview of the FDA OGD
IID EWG activities Effective Sourcing and Purchasing of Excipients
Industry Collaboration for Science Based Implementation of Elemental Impurities Challenges And Opportunities In Developing
And Modernizing Public Standards For NF Excipients Monographs For Regulated Drug
Products Marketed In The USA Future Pharma Manufacturing Efficiencies and the Role of Innovative Excipient Technologies
IPEC ExcipientFest 2015
Current Hot Topics ExcipientFest on 28-29 April 2015 in Washington
3122015 Ajaz S Hussain PhD 21
The War Against Fake Medicines Update on FDASIA - Guidance and Impact on Excipient
Suppliers and Users QbD Sampling Guidelines The NSFIPECANSI 363 2014 GMP standards explained Good Supply Practices ndash Using Cross Industry Knowledge to Devise
Pragmatic Solutions Impact of Non-harmonized Standards and What is Needed to Achieve
Harmonization Advancements in the Question Based Review approach and various other
excipient specific related topics An Overview of the FDA OGD IID EWG activities Effective
Sourcing and Purchasing of Excipients Industry Collaboration for Science Based Implementation of Elemental Impurities Challenges And
Opportunities In Developing And Modernizing Public Standards For NF ExcipientsMonographs For Regulated Drug Products Marketed In The USA Future Pharma Manufacturing Efficiencies and the Role of Innovative Excipient Technologies
IPEC ExcipientFest 2015
Inspectional trends in data integrity (Bangalore Nov
2014)
22(d)
192
100(a)
160(b)
110(a)
67(b)
68(a)
25(a)
67(a)
100(b)
Recurring 483 Observations Top 10
22(d) 192 100(a) 160(b)110(a) 67(b) 68(a) 25(a)67(a) 100(b)
Jeff Medwid NIPTE-FDA Conference 13 June 2012
International Society for Pharmaceutical Engineering (ISPE) in conjunction with McKinsey amp Co will release preliminary data and findings from its Quality Metrics Pilot Program at the ISPE Quality Metrics Summit on April 21ndash22 in Baltimore
FDA Launches New Drug Quality Office With Goal of Improving the Pharmaceutical IndustryPosted 13 January 2015By Alexander Gaffney RAC
FDArsquos New Pharma Quality
Office Will Take a Team Approach
Yu Explains
Regulatory Recon Investigations Find Major Quality Problems at Indian Pharma Companies (3 December 2014)Posted 03 December 2014By Alexander Gaffney RAC
Currently the environment is complex there is high uncertainty D
on
rsquot f
org
et
fun
ctio
na
lity
o
f e
xcip
ien
ts i
s im
po
rta
nt
3122015 Ajaz S Hussain PhD 22
Need for urgent progress lsquoInactive Ingredientsrsquo to lsquoExcipientsrsquo to lsquoFunctional Excipientsrsquo
Importance of assuring quality and controlling
variability of excipients
including their lsquofunctionalityrsquo has
long been recognized
bull Increasing complexity of drugs their delivery and failure modes
bull Patient (eg pediatric) relevant failure modes
bull Simple generics to complex generics amp biosimilars
Urgent need to address gaps in the FDArsquos Inactive Ingredient Database
3122015 Ajaz S Hussain PhD 23
Trends Lab amp Manufacturing
ldquoDeletion of Datardquo
ldquoTesting Into Compliancerdquo
ldquoBMR manipulation is a slippery sloperdquo
ldquoSuggestive of faulty manufacturing process or practices even if this is not the caserdquo
ldquoIt is top managementrsquos responsibility to ensure the training program is robust and effectiverdquo
Inspectional trends in data integrity (Bangalore Nov 13 2014 - Nov 14 2014)
Growing concern some
companies ldquodata looks too good
to be truerdquo
3122015 Ajaz S Hussain PhD 24
GMP Compliance amp Remediation
Jeff Medwid NIPTE-FDA Conference 13 June 2012
QbD amp QbR Clarity on Critical Functionality
FDArsquos New Pharma Quality
Office Will Take a Team
Approach Yu Explains
Carmelo Rosa MS PsyD November 2014
Urgent Need amp Opportunity
To align amp ensure sound scientific basis of these critical regulatory decisions
FDA CDER OPQ Plans for Surveillance of Pharmaceutical Quality
Teresa Mullin PhD December 2014
3122015 Ajaz S Hussain PhD 25
Need for a comprehensive (excipient) knowledge base
Teresa Mullin PhD December 2014
3122015 Ajaz S Hussain PhD 26
Why attention to (excipient) knowledge management is criticalSpecifically for physical attributes functionality performance
3122015 Ajaz S Hussain PhD 27
3122015 Ajaz S Hussain PhD 28
Today there are several product categories (eg controlled release inhalation products DPIrsquos topical transdermal liposomal products etc) which requires an exquisite control of complex physical material and product attributes (functionality)
Many of our current measurement systems need improvement
We depend on these to ensure control of lot-lot variability
Measurement system capability must be confirmed to be able to assess process capability (calibration amp Gauge RampR)
Life-cycle approach to quality continued process verification (FDArsquos Process Validation 2011) is a safety net
Supplier amp Excipient Qualification amp Process Validation
Measurement System Analysis
bull From lsquocalibrationrsquo to lsquoGauge RampRrsquoParticularly for physical
attributes destructive analysis
bull Many (including regulators) have not yet understood its importance
Gauge RampR well established but not commonly practiced
bull Measurement system in a state of control effective CAPA quality metrics Culture of Quality
With the move towards Statistical Process Control
bull Demonstrate equivalent in vitro performance more exacting criteria
Development of complex generic products (ER
Injectable Inhalation etc)
3122015 Ajaz S Hussain PhD 29
Process Validation (2011) Statistical Confidence Continued Process Verificationhellip
3122015 Ajaz S Hussain PhD 30
httpwwwslideshareneta2zpharmsciperformance-testing-pharmaceutical-quality-2004(accessed 6 December 2014)
3122015 Ajaz S Hussain PhD 31
Supplier amp Excipient Qualification amp CAPA
Out of Specification events are difficult to resolve
Excipient functionality can be a significant contributing factor
Sometimes reluctantly have to settle with - ldquoRoot cause unknown
600 days
I have inserted the ldquo600 daysrsquo on the figure ndash this is based on cases I have seen while at FDA)
3122015 Ajaz S Hussain PhD 32
Prevention of OOS and Effective CAPA needs a focus on critical functional attributes
Out of Specification events are difficult to resolve
Excipient functionality can be a significant contributing factor
Sometimes reluctantly have to settle with - ldquoRoot cause unknown
Compendial standards and manufacturing
3122015 Ajaz S Hussain PhD 33
Practice Control Process Maturity
Initial
bull Unpredictable
Managed
bull Characterized but reactive
Defined
bull Characterized proactive
Measured amp Controlled
bull In control
Optimizing
bull Focus on improvement
3122015 Ajaz S Hussain PhD 34
Capability Maturity Model Integration Carnegie Mellon University
A validated process
Maturity Level amp Assurance of Quality
Managed Characterized but reactive
High perceived risk of
lsquoCheating by Designrsquo
ldquoTrial Injectionsrdquo
ldquoTesting in to Compliancerdquo
Defined Characterized proactive
Lower level of assurance
Stopping amp Correcting
Batch Rejection
Measured amp
ControlledIn control
Quality by Design
Quality Assured
Improvement Opportunities
3122015 Ajaz S Hussain PhD 35
At the individual level in QC functionndash how often does this occur
attitude toward
performing the behavior
Process validation is
done so quality is good
test prone to error
ldquoBatch failure means I made
a mistakerdquo
subjective norm
documentation not critical
Compendial testing
sufficient
Indian regulators
collect amp test samples ndash no issue there
3122015 Ajaz S Hussain PhD 36
ldquoTesting into compliancerdquo
In general ndash low empowerment is a significant challenge (low perceived behavioral control) plus reasons to rationalizehellip
Excipient Functionality Can be critical for safety efficacy and quality
3122015 Ajaz S Hussain PhD 37
July 15 2005 FDA Public Health Advisory Safety Warnings Regarding Use of Fentanyl Transdermal (Skin) Patches
A pattern of failure Pharmaceutical Equivalence by Design (2004)
3122015 Ajaz S Hussain PhD 38
httpwwwnihsgojpdrugPhForumdocuments041122Hussain041122pdf
An attempt to correct
3122015 Ajaz S Hussain PhD 39
httpipecamericasorgsystemfilesKeyNoteEF13May11LawrenceYu(FDA)pdf
Recent challenges
3122015 Ajaz S Hussain PhD 40
Th
e V
oic
e o
f th
eA
mer
ican
P
sych
iatr
ic A
sso
ciat
ion
and
th
e P
sych
iatr
ic C
om
mu
nit
y
Physicians Question FDAs Confidence in Generic Drugs Safety Efficacy (OCTOBER 24 2014)
bull ldquomost patientsrdquo is not the same asldquo all patientsrdquo and whether the 24 to 36 normal subjects used in the agencys bioequivalency tests represents the full range of individual variation in the way drugs are absorbed across the pharmaceutical using population is uncertain
bull Individuals can sometimes be allergic and react differently to whatever substance goes into making up the capsule or the tablet
FDA Flags Generic Versions of ADHD Medication(NOVEMBER 14 2014)
bull FDA changed the therapeutic equivalence (TE) rating from AB to BXmdashmeaning that the products are still approved and can be prescribed but are no longer recommended as automatic substitutes
RLD Variability Can be a block-buster opportunityFocus on lsquocontrol strategyrsquo
bull Overcoming CP amp IP provide FDA a submission they need to address CP
bull Then begin with QTPP CQArsquos hellip skip lsquodesign spacersquo and focus on lsquocontrol strategy
bull The entire development team should read the complete package insert of RLD
bull Discuss to ensure a common understandingbull Failure modes amp intended use
bull Pharmaceutical Equivalence
bull Bioequivalence
bull Other studies
QbD Challenges
3122015 Ajaz S Hussain PhD 41
NewRegulators are not prepared to handle QbD applications
NewMisalignment of international regulatory authorities
New and Generics
RampD incentivized for lsquoshots on the goalrsquo not QbD
GenericsLack of belief in business case ndash lsquoGenerics are all about file first figure out laterrsquo
Biologics Lack of technology to execute
Ted Fuhr Mackinsey amp Company June 2010 FDA Advisory Committee
Summary
bull Excipient functionality can contribute in critical ways to product quality amp performance adequate control is necessary
bull Our databases tools and knowledge are lagging behind the rapidly increasing complexity and uncertainty
bull Risk to quality and to business is increasing and regulatory transitions pose additional difficulties
bull Effective knowledge management ndash IT and Human practices ndash is critical for organizational lsquobottom-linersquo
bull We all must come together collaboratively to address the urgent needs we owe it to the patients we serve
3122015 Ajaz S Hussain PhD 42
Knowledge Management amp Culture of Quality
Ajaz S Hussain PhD
Insight Advice amp Solutions LLCMaryland USA
Executive Director the National Institute for Pharmaceutical Technology amp Education
3122015 Ajaz S Hussain PhD 43
3122015 Ajaz S Hussain PhD 44
Life-cycle approach needed for knowledge management
Investigational ProductscGMPs
DevelopmentTechnology
TransferCommercial
ManufacturingDiscontinuation
Management Responsibility
Process Performance amp Product Quality Monitoring SystemCAPA Change Management Management Review
PQS Elements
Knowledge ManagementQuality Risk ManagementEnablers
ICH Q10 KM is a systematic approach to acquiring analyzing storing and disseminating information related to products manufacturing processes and components
Based on ICH Q10
ldquowe can be blind to the obvious and we are also blind to our blindnessrdquo
Daniel Kahneman Thinking Fast and Slow
3142015 Ajazajazhussaincom 45
httpwebmiteduperscipeopleadelsoncheckershadow_proofhtml
3122015 Ajaz S Hussain PhD 46
1938 The Federal Food Drug and Cosmetic (FDC)
bull 1937 Elixir of Sulfanilamide
1962 Kefauver-Harris Drug Amendments
bull 1962 Thalidomide
bull 1960 Color Additive Amendment
bull 1958 Food Additives Amendment GRAS
bull 1960 Color Additive Amendment
bull 1958 Food Additives Amendment GRAS
1992 Generic Drug Enforcement Act
bull1989 L-Tryptophan
bull 1989 Generic Drug Scandal
bull 1988 Food and Drug Administration Act
bull 1984 Fines Enhancement Laws Drug Price Competition and Patent Term Restoration Act
2012 Food and Drug Administration Safety and Innovation Act (FDASIA)
bull 2007 Heparin Disaster
2013 Pandemic and All-Hazards Preparedness Reauthorization Act (PAHPRA) Drug Quality and Security Act
bull 2012 The Deadly Meningitis Outbreak
Past 70 years 1937 ndash 2007 The diethylene glycol (DEG) narrative
3122015 Ajaz S Hussain PhD 47
0
5
10
15
20
25
30
35
Yea
rs
DEG Years since the previous incident
0
50
100
150
200
250
300
350
Number of Reported Deaths
1937
Eli
xir
of
Sulf
anil
amid
e
2007T
ootp
aste
conta
min
atio
n
0 70 years 0 70 years
Frequent reports
Mumbai Mumbai
Data from Excipient Fest Janeen Skutnik Chair ndashIPECAmericas 2009
Past 70+ years DEG contamination or economically motivated adulteration
3122015 Ajaz S Hussain PhD 48
Reported cases underestimate the real tragedy rapid intervention may not occur
Epidemic of Pediatric Deaths From Acute Renal Failure Caused by
Diethylene Glycol Poisoning JAMA 1998279(15)1175-1180
doi101001jama279151175
Month of hospital admission for children with
acute renal failure Haiti
October 1995-October 1996
Diethylene glycol poisoning in Gurgaon India 1998Bulletin of the World Health Organization 2001 79 88ndash95
We report a second episode of poisoning occurring in 1998 in
India as a result of children ingesting diethylene glycol at
least 33 children are known to have died
At the beginning of the investigation we never imagined that
contaminated medicine was causing acute renal failure in
children
A brand of cough expectorant manufactured by a local
pharmaceutical company was found by the Central Drugs
Laboratory Calcutta to contain 175 (vv) diethylene
glycol
The district and state drug controller had tested many
samples using thin layer chromatography before a sample of
medicine tested positive for diethylene glycol at the Central
Drugs Laboratory None of the earlier samples was found to
be contaminated
3122015 Ajaz S Hussain PhD 49
Guidance for Industry Testing of
Glycerin for Diethylene Glycol
CDER May 2007 Compliance
1 Manufacturers did not perform full
identity testing on the glycerin raw
material including tests to quantify
the amount of DEG
2 Relied on the certificate of analysis
(COA)
3 The origin of the glycerin was not
easily apparent from the COA
4 The COA was often a copy of a COA
on the letterhead of the distributor
5 The chain of custody or distribution
history of the glycerin was also not
readily known
USP Glycerin Monograph
Type of Posting Revision Bulletin
Posting Date 04ndashFebndash2009
Official Date 01ndashMayndash2009
Because of the serious hazards
associated withhellip and in response to
recommendations set forth in the
FDA Guidance for Industry Testing
of Glycerin for Diethylene Glycol
published in May 2007 USP has
revised the USP Glycerin monograph
Because diethylene glycol and
ethylene glycol are considered
unacceptable toxic substances the
testing of USP Glycerin should
demonstrate the absence of these
substances
April 2007 FDA request to
USP to revise the Glycerin
monographrsquos
IDENTIFICATION section
Revision includes adding ndash
Identification test B LIMIT OF
DIETHYLENE GLYCOL AND
ETHYLENE GLYCOL to detect
and quantify DEGEG in Glycerin
minus Is no longer part of the impurity
testing
ldquoLimit of DEG and Related
Compoundsrdquo minus Introduces a
capillary gas-chromatographic
(GC) method with flame ionization
detection (FID) minus Limit of NMT
010 each for diethylene glycol
and ethylene glycol is found
70+ years to get here how difficult will it be to change habits such as lsquoblind reliance of COArsquo
3122015 Ajaz S Hussain PhD 50
Personality and Habitual Frame Biases
Myers Brigs ENTJ (first tested at FDA)
S
TF
Expanded frame
future
possibilities
objective lsquocause
and effectrsquo
Expanded frame
future
possibilities
people and
relationships
Narrow frame
the present
individuals and
relationships
Narrow frame
the present
objective
cause and
effect
N
Based on Stanford Webinar - How to Overcome the Top 3 MegaBiases in Decision-Making
Stanford Universityrsquos Strategic Decision and Risk Management certificate program
From Mapping a Managers Brain on Incentives
Social
influences
Relative
thinking
UncertaintyComplexity
By Design Intention to act consciously
bull In the interest of patients and to continually improve this ability bull To provide a healing touch ndash one life at a time in what we do and how we
do it
1292014 Ajazajazhussaincom 51
Consciously
Scientific methodology
Engineering Design
Plan-Do-Check-Act
Subconsciously
Habits (work to get rid of bad ones)
Habits (work to cultivate good one)
Keystone habits (Safety Alcoa ALCOA of data integrity)
The Power of Habit Why We Do What We Do in Life and Business Charles Duhigg (2012)
httpwwwslideshareneta2zpharmscipharmaceutical-culture-of-quality
What does it take to come out of the cGMP crisis
Persuasive demonstration of
(1) Ability to face facts
(2) Legal amp regulatory requirements
3) Systems approach to quality
4) Changing behavior amp culture
What is often missed or is unconvincing is how you will strengthen culture of quality
ldquoLet one who wants to move and convince others first be convinced and moved themselvesrdquo Thomas Carlyle
Signals that question the competence motivation andor integrity of company personnel
Do not defend the plainly indefensible it adds further serious credibility costs
3142015 Ajazajazhussaincom 52
Quality is everyones responsibility
Lack of knowledge that is
the problem
If you do not know how to ask the
right question you discover nothing
If you cant describe what you
are doing as a process you dont know what youre
doing
Rational behavior requires theory
Reactive behavior requires only reflex
action
Whenever there is fear you will get wrong figures
3142015 Ajazajazhussaincom 53
Selected quotes W Edwards Deming
3142015 Ajazajazhussaincom 54
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
ldquoWE CANNOT CHANGE THE HUMAN CONDITION BUThellipWE CAN CHANGE THE CONDITIONS UNDER WHICH HUMANS WORKrdquo JAMES REASON
Disregard to Malice
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 55
ldquohelliprecords not completed
contemporaneouslyrdquo
ldquohellipobserved analyst back-date logbooksrdquo
ldquohelliptrial injectionshelliprdquo
ldquohellipresults failing specifications are
retested until acceptable results are obtainedhelliprdquo
ldquohellipover-writing electronic raw datahelliprdquo
ldquohellipOOS not investigates per XYZ SOPrdquo
ldquohellipappropriate controls not establishedhelliprdquo
Each additional observation adds
reasons to confirm that this is very likely a system
with intentional lsquoholesrsquo in its
defenses
Preconditions
Rationalization amp Attitude
Pressure amp Incentive
Opportunity ndashlsquoholes in the QMSrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 56
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 57
Attitude towards the behavior
Subjective norm
Perceived behavioral
control
IntentionFuture
Behavior
usually found to predict behavioral intentions with a high degree of accuracy
intentions in combination with perceived behavioral control can account for a considerable proportion of variance in behavior
PastBehavior
Ajen I The theory of planned behavior ORGANIZATIONAL BEHAVIOR AND HUMAN DECISION PROCESSES 50 179-211 (1991)
Heparin tragedy 2007 and 2008
FDA reports 149 deaths with allergic or hypersensitivity symptoms during that period
bull Contaminated heparin from China
QC Testing
bull Initial testing failed to detect the contaminant
Pharmacovigilence
bull Signals in the pharmacovigilence systems responded slowly and
Eventually the severity of reactions associated made it likely that the contamination would be detected
bull too late for those who died or were injured
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 58
Congressman Shimkus When the drug safety system fails people get sick Some die
bull Some of these people are already very vulnerable and proving the cause of harm from impurities adulteration and counterfeits can be elusive
It is hard to detect harm
bull Certainly the companies are obligated to ensure a culture of quality and maintain vigilance as well This reflects a systems approach to safety
FDA inspectors look for a culture of quality at
manufacturing facilities
bull FDA policies led to the failure to inspect the Chinese plantThis system approach wasnt at
play here
bull While it doesnt deny the counterfeit source tries to say that counterfeits didnt cause the reaction as if the adulteration itself was no big deal Is this an acceptable mindset helliphelliphellip
This brings me to China and its quality culture or lack thereof
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 59
ONE HUNDRED TENTH CONGRESS SECOND SESSION APRIL 29 2008 Serial No 110-109
21 CFR PART 211 SUBPARTS -Deviations signal gaps in CoQ
bullGENERAL PROVISIONSA
bullORGANIZATION AND PERSONNELB
bullBUILDINGS AND FACILITIESC
bullEQUIPMENTD
bullCONTROL OF COMPONENTS AND DRUG PRODUCT CONTAINERS AND CLOSURESE
bullPRODUCTION AND PROCESS CONTROLSF
bullPACKAGING AND LABELING CONTROLG
bullHOLDING AND DISTRIBUTIONH
bullLABORATORY CONTROLSI
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 60
For example the combinationhellip
The Power of Habit Why We Do What We Do in Life and Business Charles Duhigg (2012)
bull Scientific methodology
bull Engineering Design
bull Plan-Do-Check-ActConsciously
bull Habits (work to get rid of bad ones)
bull Habits (work to cultivate good one)
bull Keystone habits (Safety Alcoa ALCOA of data integrity)
Subconsciously
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 61
CoQ How
bull What are the predictors of CoQCoQ Manifests by Design -
lsquoquality by designrsquo the foundation
bull 1 2 3When do people change their behaviors
bull A B C D (any body can dance)What makes a QMS effective
bull X Y ZWhen proactive compliance occurs
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 62
Going beyond rules pays
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 63
Human behavior Connecting the Dots With the Right Connectors
GXPs ndash rational behaviors
How proactive compliance is achieved X Y Z
Quality Management System
What makes a QMS reliable A B C D
Culture of Quality
Why people change their behavior 1 2 3
Human Behaviors Beyond GXPs
Predictors of Culture of Quality
Why What and How of Culture of Quality
9192014 copy Ajaz S Hussain | INSIGHT ADVICE amp SOLUTIONS LLC 64
Predictors of CoQ Act consciously in the interest of patients ndash when no one is looking
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 65
Only four attributes
actually predict a culture of
quality
Leadership Emphasis
Message Credibility
Peer Involvement
Employee Empower-ment
People will change their
behavior if they see the new behavior as
Normal
(1)
Rewarding
(2)
Easy
(3)
Dr W Edwards Demingrsquos - ldquoOut of the crisisrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 66
The journey requires leadership
with Profound Knowledge as a
guide
bull As leaders responsible for system change top management is most in need of profound knowledge
bull Quality is often determined in the boardroom
bull Problems arise when management reacts to common cause or chance variation as if it were special cause variation
bull Prediction based in theory provides a foundation for planning a course of action Plan ndash Do ndash Check ndash Act
bull The leader serves the people with clear vision and guidance to empower them To be empowered is to share ownership in the identity
bull Giving people a certain degree of control over their work fulfills the need for freedom and provides opportunity for taking joy in work
Profound Knowledge as a guide
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 67
Appreciation for a System
Theory of Knowledge
Knowledge about
Variation
Human Behavior -Psychology of Change
A
B
C
D+
Systems Approach for ErrorDeviation Management
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 68
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
Human error models and management J Reason BMJ 320 768ndash770 (2000)
D+
Culture of Error Management परबधनbull Error strain
bull Covering upFear of Errors
bull Anticipation
bull Risk takingAwareness
bull Development QbDRFT
bull Error detection Communication
bull Analyzing errors Correction
Mastery orientation
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 69
Dots amp Connections
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 70
CoQ
1
2
3
QMS
A
B
C
D
GXP Behaviors
X
Y
Z
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 71
Culture of Quality
Normal
Rewarding
Easy
QMS
System
Knowledge
Variation
Behavior
Behavior -GXPs
Fear Removed
Mastery
Awareness
EnvironmentLeadership Emphasis
Message Credibility
Peer Involvement
Employee Empowerment
Connect to CoQ
Connect to GXPs
A Framework and a Tool (for gap analysis)
NIPTE Knowledge Management
3122015 Ajaz S Hussain PhD 13
Contact Prof Hoag Univ Maryland shoagrxumarylandedu
3122015 Ajaz S Hussain PhD 14
NIPTE Knowledge Management
This study was funded by the FDA-sponsored contract ldquoDevelopment of Quality by Design (QbD) Guidance Elements on Design Specifications across Scales with Stability Considerationsrdquo (contract number HHSF223200819929C)
3122015 Ajaz S Hussain PhD 15
Current hot topics ndashrsquoexcipientsrsquo regulatory trends amp insights ExcipientFest on 28-29 April 2015 in Washington Organizational Changes CDERFDA and Inspectional Trendshellip(Complex Genericshellip Continuous Manufacturing)
3122015 Ajaz S Hussain PhD 16
Current experience with lsquoSupplier Qualificationrsquo
bull Recent observations are summarized in this report by ECA Academy (21012015) Areas of attention
bull Accuracy and completeness of administrative documentation
bull Evidence to justify excipient and supplier qualification
bull Risk-assessment and effective integration within in QMS
bull Quality agreements
bull Going forward I envision a need to emphasize a life-cycle approach (eg linking to CAPA change control)
3122015 Ajaz S Hussain PhD 17
FDArsquos Inactive Ingredient Database -statusbull Substance Registration System (SRS)
bull Generic listing vs Specific Grade listing for commonly used excipients ndashmax precedent levels
bull Listing of Mixtures
bull The UNII code confusing the National Library of Medicine yet to finalize standards for assigning UNII codes for polymers
bull Individual Grades vs Family Data
bull Legal status of the IID and FDA communications of changes to the IID
bull DMF Implications
bull Impact on ANDAs ndash lsquoDelaysrsquo amp lsquoRefuse to File Lettersrsquo
3122015 Ajaz S Hussain PhD 18
3122015 Ajaz S Hussain PhD 19
Inactive Ingredientsrsquo to lsquoExcipientsrsquo to lsquoFunctionalityrsquo Where are we in this journeylsquo
Status of lsquoSubstances In Regulatory Practicersquo
Clearly we need a global database with improved precision and accuracy of naming (and coding) to identify describe compare and link (to products and AERs)
INDs NDAs BLAs CFRrsquos Orphan Drug ApplicationsProducts that Contain Each Substance
Pharmacological ClassificationActive Moieties Related Moieties and Salts
LADMERMetabolites
Metabolic Enzymes Transporters and EffectsDrug target (therapeutic and other) type of interaction
Solubility and Permeability (BCS)Protein Binding
Impurities and Related Substance
ISO 11238 (ISO IDMP) some challenges
Both substances amp specified substances
Implementation in EU EMA Task force
Global Ingredients Archive System (GInAS)
3122015 Ajaz S Hussain PhD 20
The War Against Fake Medicines Update on FDASIA - Guidance and Impact on Excipient Suppliers and
Users QbD Sampling Guidelines The NSFIPECANSI 363 2014 GMP standardsexplained Good Supply Practices ndash Using Cross Industry Knowledge to Devise Pragmatic Solutions Impact
of Non-harmonized Standards and What is Needed to Achieve Harmonization Advancements in the Question Based Review approach and various other excipient specific related topics An Overview of the FDA OGD
IID EWG activities Effective Sourcing and Purchasing of Excipients
Industry Collaboration for Science Based Implementation of Elemental Impurities Challenges And Opportunities In Developing
And Modernizing Public Standards For NF Excipients Monographs For Regulated Drug
Products Marketed In The USA Future Pharma Manufacturing Efficiencies and the Role of Innovative Excipient Technologies
IPEC ExcipientFest 2015
Current Hot Topics ExcipientFest on 28-29 April 2015 in Washington
3122015 Ajaz S Hussain PhD 21
The War Against Fake Medicines Update on FDASIA - Guidance and Impact on Excipient
Suppliers and Users QbD Sampling Guidelines The NSFIPECANSI 363 2014 GMP standards explained Good Supply Practices ndash Using Cross Industry Knowledge to Devise
Pragmatic Solutions Impact of Non-harmonized Standards and What is Needed to Achieve
Harmonization Advancements in the Question Based Review approach and various other
excipient specific related topics An Overview of the FDA OGD IID EWG activities Effective
Sourcing and Purchasing of Excipients Industry Collaboration for Science Based Implementation of Elemental Impurities Challenges And
Opportunities In Developing And Modernizing Public Standards For NF ExcipientsMonographs For Regulated Drug Products Marketed In The USA Future Pharma Manufacturing Efficiencies and the Role of Innovative Excipient Technologies
IPEC ExcipientFest 2015
Inspectional trends in data integrity (Bangalore Nov
2014)
22(d)
192
100(a)
160(b)
110(a)
67(b)
68(a)
25(a)
67(a)
100(b)
Recurring 483 Observations Top 10
22(d) 192 100(a) 160(b)110(a) 67(b) 68(a) 25(a)67(a) 100(b)
Jeff Medwid NIPTE-FDA Conference 13 June 2012
International Society for Pharmaceutical Engineering (ISPE) in conjunction with McKinsey amp Co will release preliminary data and findings from its Quality Metrics Pilot Program at the ISPE Quality Metrics Summit on April 21ndash22 in Baltimore
FDA Launches New Drug Quality Office With Goal of Improving the Pharmaceutical IndustryPosted 13 January 2015By Alexander Gaffney RAC
FDArsquos New Pharma Quality
Office Will Take a Team Approach
Yu Explains
Regulatory Recon Investigations Find Major Quality Problems at Indian Pharma Companies (3 December 2014)Posted 03 December 2014By Alexander Gaffney RAC
Currently the environment is complex there is high uncertainty D
on
rsquot f
org
et
fun
ctio
na
lity
o
f e
xcip
ien
ts i
s im
po
rta
nt
3122015 Ajaz S Hussain PhD 22
Need for urgent progress lsquoInactive Ingredientsrsquo to lsquoExcipientsrsquo to lsquoFunctional Excipientsrsquo
Importance of assuring quality and controlling
variability of excipients
including their lsquofunctionalityrsquo has
long been recognized
bull Increasing complexity of drugs their delivery and failure modes
bull Patient (eg pediatric) relevant failure modes
bull Simple generics to complex generics amp biosimilars
Urgent need to address gaps in the FDArsquos Inactive Ingredient Database
3122015 Ajaz S Hussain PhD 23
Trends Lab amp Manufacturing
ldquoDeletion of Datardquo
ldquoTesting Into Compliancerdquo
ldquoBMR manipulation is a slippery sloperdquo
ldquoSuggestive of faulty manufacturing process or practices even if this is not the caserdquo
ldquoIt is top managementrsquos responsibility to ensure the training program is robust and effectiverdquo
Inspectional trends in data integrity (Bangalore Nov 13 2014 - Nov 14 2014)
Growing concern some
companies ldquodata looks too good
to be truerdquo
3122015 Ajaz S Hussain PhD 24
GMP Compliance amp Remediation
Jeff Medwid NIPTE-FDA Conference 13 June 2012
QbD amp QbR Clarity on Critical Functionality
FDArsquos New Pharma Quality
Office Will Take a Team
Approach Yu Explains
Carmelo Rosa MS PsyD November 2014
Urgent Need amp Opportunity
To align amp ensure sound scientific basis of these critical regulatory decisions
FDA CDER OPQ Plans for Surveillance of Pharmaceutical Quality
Teresa Mullin PhD December 2014
3122015 Ajaz S Hussain PhD 25
Need for a comprehensive (excipient) knowledge base
Teresa Mullin PhD December 2014
3122015 Ajaz S Hussain PhD 26
Why attention to (excipient) knowledge management is criticalSpecifically for physical attributes functionality performance
3122015 Ajaz S Hussain PhD 27
3122015 Ajaz S Hussain PhD 28
Today there are several product categories (eg controlled release inhalation products DPIrsquos topical transdermal liposomal products etc) which requires an exquisite control of complex physical material and product attributes (functionality)
Many of our current measurement systems need improvement
We depend on these to ensure control of lot-lot variability
Measurement system capability must be confirmed to be able to assess process capability (calibration amp Gauge RampR)
Life-cycle approach to quality continued process verification (FDArsquos Process Validation 2011) is a safety net
Supplier amp Excipient Qualification amp Process Validation
Measurement System Analysis
bull From lsquocalibrationrsquo to lsquoGauge RampRrsquoParticularly for physical
attributes destructive analysis
bull Many (including regulators) have not yet understood its importance
Gauge RampR well established but not commonly practiced
bull Measurement system in a state of control effective CAPA quality metrics Culture of Quality
With the move towards Statistical Process Control
bull Demonstrate equivalent in vitro performance more exacting criteria
Development of complex generic products (ER
Injectable Inhalation etc)
3122015 Ajaz S Hussain PhD 29
Process Validation (2011) Statistical Confidence Continued Process Verificationhellip
3122015 Ajaz S Hussain PhD 30
httpwwwslideshareneta2zpharmsciperformance-testing-pharmaceutical-quality-2004(accessed 6 December 2014)
3122015 Ajaz S Hussain PhD 31
Supplier amp Excipient Qualification amp CAPA
Out of Specification events are difficult to resolve
Excipient functionality can be a significant contributing factor
Sometimes reluctantly have to settle with - ldquoRoot cause unknown
600 days
I have inserted the ldquo600 daysrsquo on the figure ndash this is based on cases I have seen while at FDA)
3122015 Ajaz S Hussain PhD 32
Prevention of OOS and Effective CAPA needs a focus on critical functional attributes
Out of Specification events are difficult to resolve
Excipient functionality can be a significant contributing factor
Sometimes reluctantly have to settle with - ldquoRoot cause unknown
Compendial standards and manufacturing
3122015 Ajaz S Hussain PhD 33
Practice Control Process Maturity
Initial
bull Unpredictable
Managed
bull Characterized but reactive
Defined
bull Characterized proactive
Measured amp Controlled
bull In control
Optimizing
bull Focus on improvement
3122015 Ajaz S Hussain PhD 34
Capability Maturity Model Integration Carnegie Mellon University
A validated process
Maturity Level amp Assurance of Quality
Managed Characterized but reactive
High perceived risk of
lsquoCheating by Designrsquo
ldquoTrial Injectionsrdquo
ldquoTesting in to Compliancerdquo
Defined Characterized proactive
Lower level of assurance
Stopping amp Correcting
Batch Rejection
Measured amp
ControlledIn control
Quality by Design
Quality Assured
Improvement Opportunities
3122015 Ajaz S Hussain PhD 35
At the individual level in QC functionndash how often does this occur
attitude toward
performing the behavior
Process validation is
done so quality is good
test prone to error
ldquoBatch failure means I made
a mistakerdquo
subjective norm
documentation not critical
Compendial testing
sufficient
Indian regulators
collect amp test samples ndash no issue there
3122015 Ajaz S Hussain PhD 36
ldquoTesting into compliancerdquo
In general ndash low empowerment is a significant challenge (low perceived behavioral control) plus reasons to rationalizehellip
Excipient Functionality Can be critical for safety efficacy and quality
3122015 Ajaz S Hussain PhD 37
July 15 2005 FDA Public Health Advisory Safety Warnings Regarding Use of Fentanyl Transdermal (Skin) Patches
A pattern of failure Pharmaceutical Equivalence by Design (2004)
3122015 Ajaz S Hussain PhD 38
httpwwwnihsgojpdrugPhForumdocuments041122Hussain041122pdf
An attempt to correct
3122015 Ajaz S Hussain PhD 39
httpipecamericasorgsystemfilesKeyNoteEF13May11LawrenceYu(FDA)pdf
Recent challenges
3122015 Ajaz S Hussain PhD 40
Th
e V
oic
e o
f th
eA
mer
ican
P
sych
iatr
ic A
sso
ciat
ion
and
th
e P
sych
iatr
ic C
om
mu
nit
y
Physicians Question FDAs Confidence in Generic Drugs Safety Efficacy (OCTOBER 24 2014)
bull ldquomost patientsrdquo is not the same asldquo all patientsrdquo and whether the 24 to 36 normal subjects used in the agencys bioequivalency tests represents the full range of individual variation in the way drugs are absorbed across the pharmaceutical using population is uncertain
bull Individuals can sometimes be allergic and react differently to whatever substance goes into making up the capsule or the tablet
FDA Flags Generic Versions of ADHD Medication(NOVEMBER 14 2014)
bull FDA changed the therapeutic equivalence (TE) rating from AB to BXmdashmeaning that the products are still approved and can be prescribed but are no longer recommended as automatic substitutes
RLD Variability Can be a block-buster opportunityFocus on lsquocontrol strategyrsquo
bull Overcoming CP amp IP provide FDA a submission they need to address CP
bull Then begin with QTPP CQArsquos hellip skip lsquodesign spacersquo and focus on lsquocontrol strategy
bull The entire development team should read the complete package insert of RLD
bull Discuss to ensure a common understandingbull Failure modes amp intended use
bull Pharmaceutical Equivalence
bull Bioequivalence
bull Other studies
QbD Challenges
3122015 Ajaz S Hussain PhD 41
NewRegulators are not prepared to handle QbD applications
NewMisalignment of international regulatory authorities
New and Generics
RampD incentivized for lsquoshots on the goalrsquo not QbD
GenericsLack of belief in business case ndash lsquoGenerics are all about file first figure out laterrsquo
Biologics Lack of technology to execute
Ted Fuhr Mackinsey amp Company June 2010 FDA Advisory Committee
Summary
bull Excipient functionality can contribute in critical ways to product quality amp performance adequate control is necessary
bull Our databases tools and knowledge are lagging behind the rapidly increasing complexity and uncertainty
bull Risk to quality and to business is increasing and regulatory transitions pose additional difficulties
bull Effective knowledge management ndash IT and Human practices ndash is critical for organizational lsquobottom-linersquo
bull We all must come together collaboratively to address the urgent needs we owe it to the patients we serve
3122015 Ajaz S Hussain PhD 42
Knowledge Management amp Culture of Quality
Ajaz S Hussain PhD
Insight Advice amp Solutions LLCMaryland USA
Executive Director the National Institute for Pharmaceutical Technology amp Education
3122015 Ajaz S Hussain PhD 43
3122015 Ajaz S Hussain PhD 44
Life-cycle approach needed for knowledge management
Investigational ProductscGMPs
DevelopmentTechnology
TransferCommercial
ManufacturingDiscontinuation
Management Responsibility
Process Performance amp Product Quality Monitoring SystemCAPA Change Management Management Review
PQS Elements
Knowledge ManagementQuality Risk ManagementEnablers
ICH Q10 KM is a systematic approach to acquiring analyzing storing and disseminating information related to products manufacturing processes and components
Based on ICH Q10
ldquowe can be blind to the obvious and we are also blind to our blindnessrdquo
Daniel Kahneman Thinking Fast and Slow
3142015 Ajazajazhussaincom 45
httpwebmiteduperscipeopleadelsoncheckershadow_proofhtml
3122015 Ajaz S Hussain PhD 46
1938 The Federal Food Drug and Cosmetic (FDC)
bull 1937 Elixir of Sulfanilamide
1962 Kefauver-Harris Drug Amendments
bull 1962 Thalidomide
bull 1960 Color Additive Amendment
bull 1958 Food Additives Amendment GRAS
bull 1960 Color Additive Amendment
bull 1958 Food Additives Amendment GRAS
1992 Generic Drug Enforcement Act
bull1989 L-Tryptophan
bull 1989 Generic Drug Scandal
bull 1988 Food and Drug Administration Act
bull 1984 Fines Enhancement Laws Drug Price Competition and Patent Term Restoration Act
2012 Food and Drug Administration Safety and Innovation Act (FDASIA)
bull 2007 Heparin Disaster
2013 Pandemic and All-Hazards Preparedness Reauthorization Act (PAHPRA) Drug Quality and Security Act
bull 2012 The Deadly Meningitis Outbreak
Past 70 years 1937 ndash 2007 The diethylene glycol (DEG) narrative
3122015 Ajaz S Hussain PhD 47
0
5
10
15
20
25
30
35
Yea
rs
DEG Years since the previous incident
0
50
100
150
200
250
300
350
Number of Reported Deaths
1937
Eli
xir
of
Sulf
anil
amid
e
2007T
ootp
aste
conta
min
atio
n
0 70 years 0 70 years
Frequent reports
Mumbai Mumbai
Data from Excipient Fest Janeen Skutnik Chair ndashIPECAmericas 2009
Past 70+ years DEG contamination or economically motivated adulteration
3122015 Ajaz S Hussain PhD 48
Reported cases underestimate the real tragedy rapid intervention may not occur
Epidemic of Pediatric Deaths From Acute Renal Failure Caused by
Diethylene Glycol Poisoning JAMA 1998279(15)1175-1180
doi101001jama279151175
Month of hospital admission for children with
acute renal failure Haiti
October 1995-October 1996
Diethylene glycol poisoning in Gurgaon India 1998Bulletin of the World Health Organization 2001 79 88ndash95
We report a second episode of poisoning occurring in 1998 in
India as a result of children ingesting diethylene glycol at
least 33 children are known to have died
At the beginning of the investigation we never imagined that
contaminated medicine was causing acute renal failure in
children
A brand of cough expectorant manufactured by a local
pharmaceutical company was found by the Central Drugs
Laboratory Calcutta to contain 175 (vv) diethylene
glycol
The district and state drug controller had tested many
samples using thin layer chromatography before a sample of
medicine tested positive for diethylene glycol at the Central
Drugs Laboratory None of the earlier samples was found to
be contaminated
3122015 Ajaz S Hussain PhD 49
Guidance for Industry Testing of
Glycerin for Diethylene Glycol
CDER May 2007 Compliance
1 Manufacturers did not perform full
identity testing on the glycerin raw
material including tests to quantify
the amount of DEG
2 Relied on the certificate of analysis
(COA)
3 The origin of the glycerin was not
easily apparent from the COA
4 The COA was often a copy of a COA
on the letterhead of the distributor
5 The chain of custody or distribution
history of the glycerin was also not
readily known
USP Glycerin Monograph
Type of Posting Revision Bulletin
Posting Date 04ndashFebndash2009
Official Date 01ndashMayndash2009
Because of the serious hazards
associated withhellip and in response to
recommendations set forth in the
FDA Guidance for Industry Testing
of Glycerin for Diethylene Glycol
published in May 2007 USP has
revised the USP Glycerin monograph
Because diethylene glycol and
ethylene glycol are considered
unacceptable toxic substances the
testing of USP Glycerin should
demonstrate the absence of these
substances
April 2007 FDA request to
USP to revise the Glycerin
monographrsquos
IDENTIFICATION section
Revision includes adding ndash
Identification test B LIMIT OF
DIETHYLENE GLYCOL AND
ETHYLENE GLYCOL to detect
and quantify DEGEG in Glycerin
minus Is no longer part of the impurity
testing
ldquoLimit of DEG and Related
Compoundsrdquo minus Introduces a
capillary gas-chromatographic
(GC) method with flame ionization
detection (FID) minus Limit of NMT
010 each for diethylene glycol
and ethylene glycol is found
70+ years to get here how difficult will it be to change habits such as lsquoblind reliance of COArsquo
3122015 Ajaz S Hussain PhD 50
Personality and Habitual Frame Biases
Myers Brigs ENTJ (first tested at FDA)
S
TF
Expanded frame
future
possibilities
objective lsquocause
and effectrsquo
Expanded frame
future
possibilities
people and
relationships
Narrow frame
the present
individuals and
relationships
Narrow frame
the present
objective
cause and
effect
N
Based on Stanford Webinar - How to Overcome the Top 3 MegaBiases in Decision-Making
Stanford Universityrsquos Strategic Decision and Risk Management certificate program
From Mapping a Managers Brain on Incentives
Social
influences
Relative
thinking
UncertaintyComplexity
By Design Intention to act consciously
bull In the interest of patients and to continually improve this ability bull To provide a healing touch ndash one life at a time in what we do and how we
do it
1292014 Ajazajazhussaincom 51
Consciously
Scientific methodology
Engineering Design
Plan-Do-Check-Act
Subconsciously
Habits (work to get rid of bad ones)
Habits (work to cultivate good one)
Keystone habits (Safety Alcoa ALCOA of data integrity)
The Power of Habit Why We Do What We Do in Life and Business Charles Duhigg (2012)
httpwwwslideshareneta2zpharmscipharmaceutical-culture-of-quality
What does it take to come out of the cGMP crisis
Persuasive demonstration of
(1) Ability to face facts
(2) Legal amp regulatory requirements
3) Systems approach to quality
4) Changing behavior amp culture
What is often missed or is unconvincing is how you will strengthen culture of quality
ldquoLet one who wants to move and convince others first be convinced and moved themselvesrdquo Thomas Carlyle
Signals that question the competence motivation andor integrity of company personnel
Do not defend the plainly indefensible it adds further serious credibility costs
3142015 Ajazajazhussaincom 52
Quality is everyones responsibility
Lack of knowledge that is
the problem
If you do not know how to ask the
right question you discover nothing
If you cant describe what you
are doing as a process you dont know what youre
doing
Rational behavior requires theory
Reactive behavior requires only reflex
action
Whenever there is fear you will get wrong figures
3142015 Ajazajazhussaincom 53
Selected quotes W Edwards Deming
3142015 Ajazajazhussaincom 54
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
ldquoWE CANNOT CHANGE THE HUMAN CONDITION BUThellipWE CAN CHANGE THE CONDITIONS UNDER WHICH HUMANS WORKrdquo JAMES REASON
Disregard to Malice
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 55
ldquohelliprecords not completed
contemporaneouslyrdquo
ldquohellipobserved analyst back-date logbooksrdquo
ldquohelliptrial injectionshelliprdquo
ldquohellipresults failing specifications are
retested until acceptable results are obtainedhelliprdquo
ldquohellipover-writing electronic raw datahelliprdquo
ldquohellipOOS not investigates per XYZ SOPrdquo
ldquohellipappropriate controls not establishedhelliprdquo
Each additional observation adds
reasons to confirm that this is very likely a system
with intentional lsquoholesrsquo in its
defenses
Preconditions
Rationalization amp Attitude
Pressure amp Incentive
Opportunity ndashlsquoholes in the QMSrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 56
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 57
Attitude towards the behavior
Subjective norm
Perceived behavioral
control
IntentionFuture
Behavior
usually found to predict behavioral intentions with a high degree of accuracy
intentions in combination with perceived behavioral control can account for a considerable proportion of variance in behavior
PastBehavior
Ajen I The theory of planned behavior ORGANIZATIONAL BEHAVIOR AND HUMAN DECISION PROCESSES 50 179-211 (1991)
Heparin tragedy 2007 and 2008
FDA reports 149 deaths with allergic or hypersensitivity symptoms during that period
bull Contaminated heparin from China
QC Testing
bull Initial testing failed to detect the contaminant
Pharmacovigilence
bull Signals in the pharmacovigilence systems responded slowly and
Eventually the severity of reactions associated made it likely that the contamination would be detected
bull too late for those who died or were injured
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 58
Congressman Shimkus When the drug safety system fails people get sick Some die
bull Some of these people are already very vulnerable and proving the cause of harm from impurities adulteration and counterfeits can be elusive
It is hard to detect harm
bull Certainly the companies are obligated to ensure a culture of quality and maintain vigilance as well This reflects a systems approach to safety
FDA inspectors look for a culture of quality at
manufacturing facilities
bull FDA policies led to the failure to inspect the Chinese plantThis system approach wasnt at
play here
bull While it doesnt deny the counterfeit source tries to say that counterfeits didnt cause the reaction as if the adulteration itself was no big deal Is this an acceptable mindset helliphelliphellip
This brings me to China and its quality culture or lack thereof
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 59
ONE HUNDRED TENTH CONGRESS SECOND SESSION APRIL 29 2008 Serial No 110-109
21 CFR PART 211 SUBPARTS -Deviations signal gaps in CoQ
bullGENERAL PROVISIONSA
bullORGANIZATION AND PERSONNELB
bullBUILDINGS AND FACILITIESC
bullEQUIPMENTD
bullCONTROL OF COMPONENTS AND DRUG PRODUCT CONTAINERS AND CLOSURESE
bullPRODUCTION AND PROCESS CONTROLSF
bullPACKAGING AND LABELING CONTROLG
bullHOLDING AND DISTRIBUTIONH
bullLABORATORY CONTROLSI
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 60
For example the combinationhellip
The Power of Habit Why We Do What We Do in Life and Business Charles Duhigg (2012)
bull Scientific methodology
bull Engineering Design
bull Plan-Do-Check-ActConsciously
bull Habits (work to get rid of bad ones)
bull Habits (work to cultivate good one)
bull Keystone habits (Safety Alcoa ALCOA of data integrity)
Subconsciously
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 61
CoQ How
bull What are the predictors of CoQCoQ Manifests by Design -
lsquoquality by designrsquo the foundation
bull 1 2 3When do people change their behaviors
bull A B C D (any body can dance)What makes a QMS effective
bull X Y ZWhen proactive compliance occurs
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 62
Going beyond rules pays
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 63
Human behavior Connecting the Dots With the Right Connectors
GXPs ndash rational behaviors
How proactive compliance is achieved X Y Z
Quality Management System
What makes a QMS reliable A B C D
Culture of Quality
Why people change their behavior 1 2 3
Human Behaviors Beyond GXPs
Predictors of Culture of Quality
Why What and How of Culture of Quality
9192014 copy Ajaz S Hussain | INSIGHT ADVICE amp SOLUTIONS LLC 64
Predictors of CoQ Act consciously in the interest of patients ndash when no one is looking
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 65
Only four attributes
actually predict a culture of
quality
Leadership Emphasis
Message Credibility
Peer Involvement
Employee Empower-ment
People will change their
behavior if they see the new behavior as
Normal
(1)
Rewarding
(2)
Easy
(3)
Dr W Edwards Demingrsquos - ldquoOut of the crisisrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 66
The journey requires leadership
with Profound Knowledge as a
guide
bull As leaders responsible for system change top management is most in need of profound knowledge
bull Quality is often determined in the boardroom
bull Problems arise when management reacts to common cause or chance variation as if it were special cause variation
bull Prediction based in theory provides a foundation for planning a course of action Plan ndash Do ndash Check ndash Act
bull The leader serves the people with clear vision and guidance to empower them To be empowered is to share ownership in the identity
bull Giving people a certain degree of control over their work fulfills the need for freedom and provides opportunity for taking joy in work
Profound Knowledge as a guide
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 67
Appreciation for a System
Theory of Knowledge
Knowledge about
Variation
Human Behavior -Psychology of Change
A
B
C
D+
Systems Approach for ErrorDeviation Management
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 68
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
Human error models and management J Reason BMJ 320 768ndash770 (2000)
D+
Culture of Error Management परबधनbull Error strain
bull Covering upFear of Errors
bull Anticipation
bull Risk takingAwareness
bull Development QbDRFT
bull Error detection Communication
bull Analyzing errors Correction
Mastery orientation
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 69
Dots amp Connections
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 70
CoQ
1
2
3
QMS
A
B
C
D
GXP Behaviors
X
Y
Z
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 71
Culture of Quality
Normal
Rewarding
Easy
QMS
System
Knowledge
Variation
Behavior
Behavior -GXPs
Fear Removed
Mastery
Awareness
EnvironmentLeadership Emphasis
Message Credibility
Peer Involvement
Employee Empowerment
Connect to CoQ
Connect to GXPs
A Framework and a Tool (for gap analysis)
Contact Prof Hoag Univ Maryland shoagrxumarylandedu
3122015 Ajaz S Hussain PhD 14
NIPTE Knowledge Management
This study was funded by the FDA-sponsored contract ldquoDevelopment of Quality by Design (QbD) Guidance Elements on Design Specifications across Scales with Stability Considerationsrdquo (contract number HHSF223200819929C)
3122015 Ajaz S Hussain PhD 15
Current hot topics ndashrsquoexcipientsrsquo regulatory trends amp insights ExcipientFest on 28-29 April 2015 in Washington Organizational Changes CDERFDA and Inspectional Trendshellip(Complex Genericshellip Continuous Manufacturing)
3122015 Ajaz S Hussain PhD 16
Current experience with lsquoSupplier Qualificationrsquo
bull Recent observations are summarized in this report by ECA Academy (21012015) Areas of attention
bull Accuracy and completeness of administrative documentation
bull Evidence to justify excipient and supplier qualification
bull Risk-assessment and effective integration within in QMS
bull Quality agreements
bull Going forward I envision a need to emphasize a life-cycle approach (eg linking to CAPA change control)
3122015 Ajaz S Hussain PhD 17
FDArsquos Inactive Ingredient Database -statusbull Substance Registration System (SRS)
bull Generic listing vs Specific Grade listing for commonly used excipients ndashmax precedent levels
bull Listing of Mixtures
bull The UNII code confusing the National Library of Medicine yet to finalize standards for assigning UNII codes for polymers
bull Individual Grades vs Family Data
bull Legal status of the IID and FDA communications of changes to the IID
bull DMF Implications
bull Impact on ANDAs ndash lsquoDelaysrsquo amp lsquoRefuse to File Lettersrsquo
3122015 Ajaz S Hussain PhD 18
3122015 Ajaz S Hussain PhD 19
Inactive Ingredientsrsquo to lsquoExcipientsrsquo to lsquoFunctionalityrsquo Where are we in this journeylsquo
Status of lsquoSubstances In Regulatory Practicersquo
Clearly we need a global database with improved precision and accuracy of naming (and coding) to identify describe compare and link (to products and AERs)
INDs NDAs BLAs CFRrsquos Orphan Drug ApplicationsProducts that Contain Each Substance
Pharmacological ClassificationActive Moieties Related Moieties and Salts
LADMERMetabolites
Metabolic Enzymes Transporters and EffectsDrug target (therapeutic and other) type of interaction
Solubility and Permeability (BCS)Protein Binding
Impurities and Related Substance
ISO 11238 (ISO IDMP) some challenges
Both substances amp specified substances
Implementation in EU EMA Task force
Global Ingredients Archive System (GInAS)
3122015 Ajaz S Hussain PhD 20
The War Against Fake Medicines Update on FDASIA - Guidance and Impact on Excipient Suppliers and
Users QbD Sampling Guidelines The NSFIPECANSI 363 2014 GMP standardsexplained Good Supply Practices ndash Using Cross Industry Knowledge to Devise Pragmatic Solutions Impact
of Non-harmonized Standards and What is Needed to Achieve Harmonization Advancements in the Question Based Review approach and various other excipient specific related topics An Overview of the FDA OGD
IID EWG activities Effective Sourcing and Purchasing of Excipients
Industry Collaboration for Science Based Implementation of Elemental Impurities Challenges And Opportunities In Developing
And Modernizing Public Standards For NF Excipients Monographs For Regulated Drug
Products Marketed In The USA Future Pharma Manufacturing Efficiencies and the Role of Innovative Excipient Technologies
IPEC ExcipientFest 2015
Current Hot Topics ExcipientFest on 28-29 April 2015 in Washington
3122015 Ajaz S Hussain PhD 21
The War Against Fake Medicines Update on FDASIA - Guidance and Impact on Excipient
Suppliers and Users QbD Sampling Guidelines The NSFIPECANSI 363 2014 GMP standards explained Good Supply Practices ndash Using Cross Industry Knowledge to Devise
Pragmatic Solutions Impact of Non-harmonized Standards and What is Needed to Achieve
Harmonization Advancements in the Question Based Review approach and various other
excipient specific related topics An Overview of the FDA OGD IID EWG activities Effective
Sourcing and Purchasing of Excipients Industry Collaboration for Science Based Implementation of Elemental Impurities Challenges And
Opportunities In Developing And Modernizing Public Standards For NF ExcipientsMonographs For Regulated Drug Products Marketed In The USA Future Pharma Manufacturing Efficiencies and the Role of Innovative Excipient Technologies
IPEC ExcipientFest 2015
Inspectional trends in data integrity (Bangalore Nov
2014)
22(d)
192
100(a)
160(b)
110(a)
67(b)
68(a)
25(a)
67(a)
100(b)
Recurring 483 Observations Top 10
22(d) 192 100(a) 160(b)110(a) 67(b) 68(a) 25(a)67(a) 100(b)
Jeff Medwid NIPTE-FDA Conference 13 June 2012
International Society for Pharmaceutical Engineering (ISPE) in conjunction with McKinsey amp Co will release preliminary data and findings from its Quality Metrics Pilot Program at the ISPE Quality Metrics Summit on April 21ndash22 in Baltimore
FDA Launches New Drug Quality Office With Goal of Improving the Pharmaceutical IndustryPosted 13 January 2015By Alexander Gaffney RAC
FDArsquos New Pharma Quality
Office Will Take a Team Approach
Yu Explains
Regulatory Recon Investigations Find Major Quality Problems at Indian Pharma Companies (3 December 2014)Posted 03 December 2014By Alexander Gaffney RAC
Currently the environment is complex there is high uncertainty D
on
rsquot f
org
et
fun
ctio
na
lity
o
f e
xcip
ien
ts i
s im
po
rta
nt
3122015 Ajaz S Hussain PhD 22
Need for urgent progress lsquoInactive Ingredientsrsquo to lsquoExcipientsrsquo to lsquoFunctional Excipientsrsquo
Importance of assuring quality and controlling
variability of excipients
including their lsquofunctionalityrsquo has
long been recognized
bull Increasing complexity of drugs their delivery and failure modes
bull Patient (eg pediatric) relevant failure modes
bull Simple generics to complex generics amp biosimilars
Urgent need to address gaps in the FDArsquos Inactive Ingredient Database
3122015 Ajaz S Hussain PhD 23
Trends Lab amp Manufacturing
ldquoDeletion of Datardquo
ldquoTesting Into Compliancerdquo
ldquoBMR manipulation is a slippery sloperdquo
ldquoSuggestive of faulty manufacturing process or practices even if this is not the caserdquo
ldquoIt is top managementrsquos responsibility to ensure the training program is robust and effectiverdquo
Inspectional trends in data integrity (Bangalore Nov 13 2014 - Nov 14 2014)
Growing concern some
companies ldquodata looks too good
to be truerdquo
3122015 Ajaz S Hussain PhD 24
GMP Compliance amp Remediation
Jeff Medwid NIPTE-FDA Conference 13 June 2012
QbD amp QbR Clarity on Critical Functionality
FDArsquos New Pharma Quality
Office Will Take a Team
Approach Yu Explains
Carmelo Rosa MS PsyD November 2014
Urgent Need amp Opportunity
To align amp ensure sound scientific basis of these critical regulatory decisions
FDA CDER OPQ Plans for Surveillance of Pharmaceutical Quality
Teresa Mullin PhD December 2014
3122015 Ajaz S Hussain PhD 25
Need for a comprehensive (excipient) knowledge base
Teresa Mullin PhD December 2014
3122015 Ajaz S Hussain PhD 26
Why attention to (excipient) knowledge management is criticalSpecifically for physical attributes functionality performance
3122015 Ajaz S Hussain PhD 27
3122015 Ajaz S Hussain PhD 28
Today there are several product categories (eg controlled release inhalation products DPIrsquos topical transdermal liposomal products etc) which requires an exquisite control of complex physical material and product attributes (functionality)
Many of our current measurement systems need improvement
We depend on these to ensure control of lot-lot variability
Measurement system capability must be confirmed to be able to assess process capability (calibration amp Gauge RampR)
Life-cycle approach to quality continued process verification (FDArsquos Process Validation 2011) is a safety net
Supplier amp Excipient Qualification amp Process Validation
Measurement System Analysis
bull From lsquocalibrationrsquo to lsquoGauge RampRrsquoParticularly for physical
attributes destructive analysis
bull Many (including regulators) have not yet understood its importance
Gauge RampR well established but not commonly practiced
bull Measurement system in a state of control effective CAPA quality metrics Culture of Quality
With the move towards Statistical Process Control
bull Demonstrate equivalent in vitro performance more exacting criteria
Development of complex generic products (ER
Injectable Inhalation etc)
3122015 Ajaz S Hussain PhD 29
Process Validation (2011) Statistical Confidence Continued Process Verificationhellip
3122015 Ajaz S Hussain PhD 30
httpwwwslideshareneta2zpharmsciperformance-testing-pharmaceutical-quality-2004(accessed 6 December 2014)
3122015 Ajaz S Hussain PhD 31
Supplier amp Excipient Qualification amp CAPA
Out of Specification events are difficult to resolve
Excipient functionality can be a significant contributing factor
Sometimes reluctantly have to settle with - ldquoRoot cause unknown
600 days
I have inserted the ldquo600 daysrsquo on the figure ndash this is based on cases I have seen while at FDA)
3122015 Ajaz S Hussain PhD 32
Prevention of OOS and Effective CAPA needs a focus on critical functional attributes
Out of Specification events are difficult to resolve
Excipient functionality can be a significant contributing factor
Sometimes reluctantly have to settle with - ldquoRoot cause unknown
Compendial standards and manufacturing
3122015 Ajaz S Hussain PhD 33
Practice Control Process Maturity
Initial
bull Unpredictable
Managed
bull Characterized but reactive
Defined
bull Characterized proactive
Measured amp Controlled
bull In control
Optimizing
bull Focus on improvement
3122015 Ajaz S Hussain PhD 34
Capability Maturity Model Integration Carnegie Mellon University
A validated process
Maturity Level amp Assurance of Quality
Managed Characterized but reactive
High perceived risk of
lsquoCheating by Designrsquo
ldquoTrial Injectionsrdquo
ldquoTesting in to Compliancerdquo
Defined Characterized proactive
Lower level of assurance
Stopping amp Correcting
Batch Rejection
Measured amp
ControlledIn control
Quality by Design
Quality Assured
Improvement Opportunities
3122015 Ajaz S Hussain PhD 35
At the individual level in QC functionndash how often does this occur
attitude toward
performing the behavior
Process validation is
done so quality is good
test prone to error
ldquoBatch failure means I made
a mistakerdquo
subjective norm
documentation not critical
Compendial testing
sufficient
Indian regulators
collect amp test samples ndash no issue there
3122015 Ajaz S Hussain PhD 36
ldquoTesting into compliancerdquo
In general ndash low empowerment is a significant challenge (low perceived behavioral control) plus reasons to rationalizehellip
Excipient Functionality Can be critical for safety efficacy and quality
3122015 Ajaz S Hussain PhD 37
July 15 2005 FDA Public Health Advisory Safety Warnings Regarding Use of Fentanyl Transdermal (Skin) Patches
A pattern of failure Pharmaceutical Equivalence by Design (2004)
3122015 Ajaz S Hussain PhD 38
httpwwwnihsgojpdrugPhForumdocuments041122Hussain041122pdf
An attempt to correct
3122015 Ajaz S Hussain PhD 39
httpipecamericasorgsystemfilesKeyNoteEF13May11LawrenceYu(FDA)pdf
Recent challenges
3122015 Ajaz S Hussain PhD 40
Th
e V
oic
e o
f th
eA
mer
ican
P
sych
iatr
ic A
sso
ciat
ion
and
th
e P
sych
iatr
ic C
om
mu
nit
y
Physicians Question FDAs Confidence in Generic Drugs Safety Efficacy (OCTOBER 24 2014)
bull ldquomost patientsrdquo is not the same asldquo all patientsrdquo and whether the 24 to 36 normal subjects used in the agencys bioequivalency tests represents the full range of individual variation in the way drugs are absorbed across the pharmaceutical using population is uncertain
bull Individuals can sometimes be allergic and react differently to whatever substance goes into making up the capsule or the tablet
FDA Flags Generic Versions of ADHD Medication(NOVEMBER 14 2014)
bull FDA changed the therapeutic equivalence (TE) rating from AB to BXmdashmeaning that the products are still approved and can be prescribed but are no longer recommended as automatic substitutes
RLD Variability Can be a block-buster opportunityFocus on lsquocontrol strategyrsquo
bull Overcoming CP amp IP provide FDA a submission they need to address CP
bull Then begin with QTPP CQArsquos hellip skip lsquodesign spacersquo and focus on lsquocontrol strategy
bull The entire development team should read the complete package insert of RLD
bull Discuss to ensure a common understandingbull Failure modes amp intended use
bull Pharmaceutical Equivalence
bull Bioequivalence
bull Other studies
QbD Challenges
3122015 Ajaz S Hussain PhD 41
NewRegulators are not prepared to handle QbD applications
NewMisalignment of international regulatory authorities
New and Generics
RampD incentivized for lsquoshots on the goalrsquo not QbD
GenericsLack of belief in business case ndash lsquoGenerics are all about file first figure out laterrsquo
Biologics Lack of technology to execute
Ted Fuhr Mackinsey amp Company June 2010 FDA Advisory Committee
Summary
bull Excipient functionality can contribute in critical ways to product quality amp performance adequate control is necessary
bull Our databases tools and knowledge are lagging behind the rapidly increasing complexity and uncertainty
bull Risk to quality and to business is increasing and regulatory transitions pose additional difficulties
bull Effective knowledge management ndash IT and Human practices ndash is critical for organizational lsquobottom-linersquo
bull We all must come together collaboratively to address the urgent needs we owe it to the patients we serve
3122015 Ajaz S Hussain PhD 42
Knowledge Management amp Culture of Quality
Ajaz S Hussain PhD
Insight Advice amp Solutions LLCMaryland USA
Executive Director the National Institute for Pharmaceutical Technology amp Education
3122015 Ajaz S Hussain PhD 43
3122015 Ajaz S Hussain PhD 44
Life-cycle approach needed for knowledge management
Investigational ProductscGMPs
DevelopmentTechnology
TransferCommercial
ManufacturingDiscontinuation
Management Responsibility
Process Performance amp Product Quality Monitoring SystemCAPA Change Management Management Review
PQS Elements
Knowledge ManagementQuality Risk ManagementEnablers
ICH Q10 KM is a systematic approach to acquiring analyzing storing and disseminating information related to products manufacturing processes and components
Based on ICH Q10
ldquowe can be blind to the obvious and we are also blind to our blindnessrdquo
Daniel Kahneman Thinking Fast and Slow
3142015 Ajazajazhussaincom 45
httpwebmiteduperscipeopleadelsoncheckershadow_proofhtml
3122015 Ajaz S Hussain PhD 46
1938 The Federal Food Drug and Cosmetic (FDC)
bull 1937 Elixir of Sulfanilamide
1962 Kefauver-Harris Drug Amendments
bull 1962 Thalidomide
bull 1960 Color Additive Amendment
bull 1958 Food Additives Amendment GRAS
bull 1960 Color Additive Amendment
bull 1958 Food Additives Amendment GRAS
1992 Generic Drug Enforcement Act
bull1989 L-Tryptophan
bull 1989 Generic Drug Scandal
bull 1988 Food and Drug Administration Act
bull 1984 Fines Enhancement Laws Drug Price Competition and Patent Term Restoration Act
2012 Food and Drug Administration Safety and Innovation Act (FDASIA)
bull 2007 Heparin Disaster
2013 Pandemic and All-Hazards Preparedness Reauthorization Act (PAHPRA) Drug Quality and Security Act
bull 2012 The Deadly Meningitis Outbreak
Past 70 years 1937 ndash 2007 The diethylene glycol (DEG) narrative
3122015 Ajaz S Hussain PhD 47
0
5
10
15
20
25
30
35
Yea
rs
DEG Years since the previous incident
0
50
100
150
200
250
300
350
Number of Reported Deaths
1937
Eli
xir
of
Sulf
anil
amid
e
2007T
ootp
aste
conta
min
atio
n
0 70 years 0 70 years
Frequent reports
Mumbai Mumbai
Data from Excipient Fest Janeen Skutnik Chair ndashIPECAmericas 2009
Past 70+ years DEG contamination or economically motivated adulteration
3122015 Ajaz S Hussain PhD 48
Reported cases underestimate the real tragedy rapid intervention may not occur
Epidemic of Pediatric Deaths From Acute Renal Failure Caused by
Diethylene Glycol Poisoning JAMA 1998279(15)1175-1180
doi101001jama279151175
Month of hospital admission for children with
acute renal failure Haiti
October 1995-October 1996
Diethylene glycol poisoning in Gurgaon India 1998Bulletin of the World Health Organization 2001 79 88ndash95
We report a second episode of poisoning occurring in 1998 in
India as a result of children ingesting diethylene glycol at
least 33 children are known to have died
At the beginning of the investigation we never imagined that
contaminated medicine was causing acute renal failure in
children
A brand of cough expectorant manufactured by a local
pharmaceutical company was found by the Central Drugs
Laboratory Calcutta to contain 175 (vv) diethylene
glycol
The district and state drug controller had tested many
samples using thin layer chromatography before a sample of
medicine tested positive for diethylene glycol at the Central
Drugs Laboratory None of the earlier samples was found to
be contaminated
3122015 Ajaz S Hussain PhD 49
Guidance for Industry Testing of
Glycerin for Diethylene Glycol
CDER May 2007 Compliance
1 Manufacturers did not perform full
identity testing on the glycerin raw
material including tests to quantify
the amount of DEG
2 Relied on the certificate of analysis
(COA)
3 The origin of the glycerin was not
easily apparent from the COA
4 The COA was often a copy of a COA
on the letterhead of the distributor
5 The chain of custody or distribution
history of the glycerin was also not
readily known
USP Glycerin Monograph
Type of Posting Revision Bulletin
Posting Date 04ndashFebndash2009
Official Date 01ndashMayndash2009
Because of the serious hazards
associated withhellip and in response to
recommendations set forth in the
FDA Guidance for Industry Testing
of Glycerin for Diethylene Glycol
published in May 2007 USP has
revised the USP Glycerin monograph
Because diethylene glycol and
ethylene glycol are considered
unacceptable toxic substances the
testing of USP Glycerin should
demonstrate the absence of these
substances
April 2007 FDA request to
USP to revise the Glycerin
monographrsquos
IDENTIFICATION section
Revision includes adding ndash
Identification test B LIMIT OF
DIETHYLENE GLYCOL AND
ETHYLENE GLYCOL to detect
and quantify DEGEG in Glycerin
minus Is no longer part of the impurity
testing
ldquoLimit of DEG and Related
Compoundsrdquo minus Introduces a
capillary gas-chromatographic
(GC) method with flame ionization
detection (FID) minus Limit of NMT
010 each for diethylene glycol
and ethylene glycol is found
70+ years to get here how difficult will it be to change habits such as lsquoblind reliance of COArsquo
3122015 Ajaz S Hussain PhD 50
Personality and Habitual Frame Biases
Myers Brigs ENTJ (first tested at FDA)
S
TF
Expanded frame
future
possibilities
objective lsquocause
and effectrsquo
Expanded frame
future
possibilities
people and
relationships
Narrow frame
the present
individuals and
relationships
Narrow frame
the present
objective
cause and
effect
N
Based on Stanford Webinar - How to Overcome the Top 3 MegaBiases in Decision-Making
Stanford Universityrsquos Strategic Decision and Risk Management certificate program
From Mapping a Managers Brain on Incentives
Social
influences
Relative
thinking
UncertaintyComplexity
By Design Intention to act consciously
bull In the interest of patients and to continually improve this ability bull To provide a healing touch ndash one life at a time in what we do and how we
do it
1292014 Ajazajazhussaincom 51
Consciously
Scientific methodology
Engineering Design
Plan-Do-Check-Act
Subconsciously
Habits (work to get rid of bad ones)
Habits (work to cultivate good one)
Keystone habits (Safety Alcoa ALCOA of data integrity)
The Power of Habit Why We Do What We Do in Life and Business Charles Duhigg (2012)
httpwwwslideshareneta2zpharmscipharmaceutical-culture-of-quality
What does it take to come out of the cGMP crisis
Persuasive demonstration of
(1) Ability to face facts
(2) Legal amp regulatory requirements
3) Systems approach to quality
4) Changing behavior amp culture
What is often missed or is unconvincing is how you will strengthen culture of quality
ldquoLet one who wants to move and convince others first be convinced and moved themselvesrdquo Thomas Carlyle
Signals that question the competence motivation andor integrity of company personnel
Do not defend the plainly indefensible it adds further serious credibility costs
3142015 Ajazajazhussaincom 52
Quality is everyones responsibility
Lack of knowledge that is
the problem
If you do not know how to ask the
right question you discover nothing
If you cant describe what you
are doing as a process you dont know what youre
doing
Rational behavior requires theory
Reactive behavior requires only reflex
action
Whenever there is fear you will get wrong figures
3142015 Ajazajazhussaincom 53
Selected quotes W Edwards Deming
3142015 Ajazajazhussaincom 54
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
ldquoWE CANNOT CHANGE THE HUMAN CONDITION BUThellipWE CAN CHANGE THE CONDITIONS UNDER WHICH HUMANS WORKrdquo JAMES REASON
Disregard to Malice
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 55
ldquohelliprecords not completed
contemporaneouslyrdquo
ldquohellipobserved analyst back-date logbooksrdquo
ldquohelliptrial injectionshelliprdquo
ldquohellipresults failing specifications are
retested until acceptable results are obtainedhelliprdquo
ldquohellipover-writing electronic raw datahelliprdquo
ldquohellipOOS not investigates per XYZ SOPrdquo
ldquohellipappropriate controls not establishedhelliprdquo
Each additional observation adds
reasons to confirm that this is very likely a system
with intentional lsquoholesrsquo in its
defenses
Preconditions
Rationalization amp Attitude
Pressure amp Incentive
Opportunity ndashlsquoholes in the QMSrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 56
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 57
Attitude towards the behavior
Subjective norm
Perceived behavioral
control
IntentionFuture
Behavior
usually found to predict behavioral intentions with a high degree of accuracy
intentions in combination with perceived behavioral control can account for a considerable proportion of variance in behavior
PastBehavior
Ajen I The theory of planned behavior ORGANIZATIONAL BEHAVIOR AND HUMAN DECISION PROCESSES 50 179-211 (1991)
Heparin tragedy 2007 and 2008
FDA reports 149 deaths with allergic or hypersensitivity symptoms during that period
bull Contaminated heparin from China
QC Testing
bull Initial testing failed to detect the contaminant
Pharmacovigilence
bull Signals in the pharmacovigilence systems responded slowly and
Eventually the severity of reactions associated made it likely that the contamination would be detected
bull too late for those who died or were injured
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 58
Congressman Shimkus When the drug safety system fails people get sick Some die
bull Some of these people are already very vulnerable and proving the cause of harm from impurities adulteration and counterfeits can be elusive
It is hard to detect harm
bull Certainly the companies are obligated to ensure a culture of quality and maintain vigilance as well This reflects a systems approach to safety
FDA inspectors look for a culture of quality at
manufacturing facilities
bull FDA policies led to the failure to inspect the Chinese plantThis system approach wasnt at
play here
bull While it doesnt deny the counterfeit source tries to say that counterfeits didnt cause the reaction as if the adulteration itself was no big deal Is this an acceptable mindset helliphelliphellip
This brings me to China and its quality culture or lack thereof
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 59
ONE HUNDRED TENTH CONGRESS SECOND SESSION APRIL 29 2008 Serial No 110-109
21 CFR PART 211 SUBPARTS -Deviations signal gaps in CoQ
bullGENERAL PROVISIONSA
bullORGANIZATION AND PERSONNELB
bullBUILDINGS AND FACILITIESC
bullEQUIPMENTD
bullCONTROL OF COMPONENTS AND DRUG PRODUCT CONTAINERS AND CLOSURESE
bullPRODUCTION AND PROCESS CONTROLSF
bullPACKAGING AND LABELING CONTROLG
bullHOLDING AND DISTRIBUTIONH
bullLABORATORY CONTROLSI
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 60
For example the combinationhellip
The Power of Habit Why We Do What We Do in Life and Business Charles Duhigg (2012)
bull Scientific methodology
bull Engineering Design
bull Plan-Do-Check-ActConsciously
bull Habits (work to get rid of bad ones)
bull Habits (work to cultivate good one)
bull Keystone habits (Safety Alcoa ALCOA of data integrity)
Subconsciously
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 61
CoQ How
bull What are the predictors of CoQCoQ Manifests by Design -
lsquoquality by designrsquo the foundation
bull 1 2 3When do people change their behaviors
bull A B C D (any body can dance)What makes a QMS effective
bull X Y ZWhen proactive compliance occurs
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 62
Going beyond rules pays
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 63
Human behavior Connecting the Dots With the Right Connectors
GXPs ndash rational behaviors
How proactive compliance is achieved X Y Z
Quality Management System
What makes a QMS reliable A B C D
Culture of Quality
Why people change their behavior 1 2 3
Human Behaviors Beyond GXPs
Predictors of Culture of Quality
Why What and How of Culture of Quality
9192014 copy Ajaz S Hussain | INSIGHT ADVICE amp SOLUTIONS LLC 64
Predictors of CoQ Act consciously in the interest of patients ndash when no one is looking
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 65
Only four attributes
actually predict a culture of
quality
Leadership Emphasis
Message Credibility
Peer Involvement
Employee Empower-ment
People will change their
behavior if they see the new behavior as
Normal
(1)
Rewarding
(2)
Easy
(3)
Dr W Edwards Demingrsquos - ldquoOut of the crisisrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 66
The journey requires leadership
with Profound Knowledge as a
guide
bull As leaders responsible for system change top management is most in need of profound knowledge
bull Quality is often determined in the boardroom
bull Problems arise when management reacts to common cause or chance variation as if it were special cause variation
bull Prediction based in theory provides a foundation for planning a course of action Plan ndash Do ndash Check ndash Act
bull The leader serves the people with clear vision and guidance to empower them To be empowered is to share ownership in the identity
bull Giving people a certain degree of control over their work fulfills the need for freedom and provides opportunity for taking joy in work
Profound Knowledge as a guide
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 67
Appreciation for a System
Theory of Knowledge
Knowledge about
Variation
Human Behavior -Psychology of Change
A
B
C
D+
Systems Approach for ErrorDeviation Management
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 68
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
Human error models and management J Reason BMJ 320 768ndash770 (2000)
D+
Culture of Error Management परबधनbull Error strain
bull Covering upFear of Errors
bull Anticipation
bull Risk takingAwareness
bull Development QbDRFT
bull Error detection Communication
bull Analyzing errors Correction
Mastery orientation
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 69
Dots amp Connections
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 70
CoQ
1
2
3
QMS
A
B
C
D
GXP Behaviors
X
Y
Z
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 71
Culture of Quality
Normal
Rewarding
Easy
QMS
System
Knowledge
Variation
Behavior
Behavior -GXPs
Fear Removed
Mastery
Awareness
EnvironmentLeadership Emphasis
Message Credibility
Peer Involvement
Employee Empowerment
Connect to CoQ
Connect to GXPs
A Framework and a Tool (for gap analysis)
NIPTE Knowledge Management
This study was funded by the FDA-sponsored contract ldquoDevelopment of Quality by Design (QbD) Guidance Elements on Design Specifications across Scales with Stability Considerationsrdquo (contract number HHSF223200819929C)
3122015 Ajaz S Hussain PhD 15
Current hot topics ndashrsquoexcipientsrsquo regulatory trends amp insights ExcipientFest on 28-29 April 2015 in Washington Organizational Changes CDERFDA and Inspectional Trendshellip(Complex Genericshellip Continuous Manufacturing)
3122015 Ajaz S Hussain PhD 16
Current experience with lsquoSupplier Qualificationrsquo
bull Recent observations are summarized in this report by ECA Academy (21012015) Areas of attention
bull Accuracy and completeness of administrative documentation
bull Evidence to justify excipient and supplier qualification
bull Risk-assessment and effective integration within in QMS
bull Quality agreements
bull Going forward I envision a need to emphasize a life-cycle approach (eg linking to CAPA change control)
3122015 Ajaz S Hussain PhD 17
FDArsquos Inactive Ingredient Database -statusbull Substance Registration System (SRS)
bull Generic listing vs Specific Grade listing for commonly used excipients ndashmax precedent levels
bull Listing of Mixtures
bull The UNII code confusing the National Library of Medicine yet to finalize standards for assigning UNII codes for polymers
bull Individual Grades vs Family Data
bull Legal status of the IID and FDA communications of changes to the IID
bull DMF Implications
bull Impact on ANDAs ndash lsquoDelaysrsquo amp lsquoRefuse to File Lettersrsquo
3122015 Ajaz S Hussain PhD 18
3122015 Ajaz S Hussain PhD 19
Inactive Ingredientsrsquo to lsquoExcipientsrsquo to lsquoFunctionalityrsquo Where are we in this journeylsquo
Status of lsquoSubstances In Regulatory Practicersquo
Clearly we need a global database with improved precision and accuracy of naming (and coding) to identify describe compare and link (to products and AERs)
INDs NDAs BLAs CFRrsquos Orphan Drug ApplicationsProducts that Contain Each Substance
Pharmacological ClassificationActive Moieties Related Moieties and Salts
LADMERMetabolites
Metabolic Enzymes Transporters and EffectsDrug target (therapeutic and other) type of interaction
Solubility and Permeability (BCS)Protein Binding
Impurities and Related Substance
ISO 11238 (ISO IDMP) some challenges
Both substances amp specified substances
Implementation in EU EMA Task force
Global Ingredients Archive System (GInAS)
3122015 Ajaz S Hussain PhD 20
The War Against Fake Medicines Update on FDASIA - Guidance and Impact on Excipient Suppliers and
Users QbD Sampling Guidelines The NSFIPECANSI 363 2014 GMP standardsexplained Good Supply Practices ndash Using Cross Industry Knowledge to Devise Pragmatic Solutions Impact
of Non-harmonized Standards and What is Needed to Achieve Harmonization Advancements in the Question Based Review approach and various other excipient specific related topics An Overview of the FDA OGD
IID EWG activities Effective Sourcing and Purchasing of Excipients
Industry Collaboration for Science Based Implementation of Elemental Impurities Challenges And Opportunities In Developing
And Modernizing Public Standards For NF Excipients Monographs For Regulated Drug
Products Marketed In The USA Future Pharma Manufacturing Efficiencies and the Role of Innovative Excipient Technologies
IPEC ExcipientFest 2015
Current Hot Topics ExcipientFest on 28-29 April 2015 in Washington
3122015 Ajaz S Hussain PhD 21
The War Against Fake Medicines Update on FDASIA - Guidance and Impact on Excipient
Suppliers and Users QbD Sampling Guidelines The NSFIPECANSI 363 2014 GMP standards explained Good Supply Practices ndash Using Cross Industry Knowledge to Devise
Pragmatic Solutions Impact of Non-harmonized Standards and What is Needed to Achieve
Harmonization Advancements in the Question Based Review approach and various other
excipient specific related topics An Overview of the FDA OGD IID EWG activities Effective
Sourcing and Purchasing of Excipients Industry Collaboration for Science Based Implementation of Elemental Impurities Challenges And
Opportunities In Developing And Modernizing Public Standards For NF ExcipientsMonographs For Regulated Drug Products Marketed In The USA Future Pharma Manufacturing Efficiencies and the Role of Innovative Excipient Technologies
IPEC ExcipientFest 2015
Inspectional trends in data integrity (Bangalore Nov
2014)
22(d)
192
100(a)
160(b)
110(a)
67(b)
68(a)
25(a)
67(a)
100(b)
Recurring 483 Observations Top 10
22(d) 192 100(a) 160(b)110(a) 67(b) 68(a) 25(a)67(a) 100(b)
Jeff Medwid NIPTE-FDA Conference 13 June 2012
International Society for Pharmaceutical Engineering (ISPE) in conjunction with McKinsey amp Co will release preliminary data and findings from its Quality Metrics Pilot Program at the ISPE Quality Metrics Summit on April 21ndash22 in Baltimore
FDA Launches New Drug Quality Office With Goal of Improving the Pharmaceutical IndustryPosted 13 January 2015By Alexander Gaffney RAC
FDArsquos New Pharma Quality
Office Will Take a Team Approach
Yu Explains
Regulatory Recon Investigations Find Major Quality Problems at Indian Pharma Companies (3 December 2014)Posted 03 December 2014By Alexander Gaffney RAC
Currently the environment is complex there is high uncertainty D
on
rsquot f
org
et
fun
ctio
na
lity
o
f e
xcip
ien
ts i
s im
po
rta
nt
3122015 Ajaz S Hussain PhD 22
Need for urgent progress lsquoInactive Ingredientsrsquo to lsquoExcipientsrsquo to lsquoFunctional Excipientsrsquo
Importance of assuring quality and controlling
variability of excipients
including their lsquofunctionalityrsquo has
long been recognized
bull Increasing complexity of drugs their delivery and failure modes
bull Patient (eg pediatric) relevant failure modes
bull Simple generics to complex generics amp biosimilars
Urgent need to address gaps in the FDArsquos Inactive Ingredient Database
3122015 Ajaz S Hussain PhD 23
Trends Lab amp Manufacturing
ldquoDeletion of Datardquo
ldquoTesting Into Compliancerdquo
ldquoBMR manipulation is a slippery sloperdquo
ldquoSuggestive of faulty manufacturing process or practices even if this is not the caserdquo
ldquoIt is top managementrsquos responsibility to ensure the training program is robust and effectiverdquo
Inspectional trends in data integrity (Bangalore Nov 13 2014 - Nov 14 2014)
Growing concern some
companies ldquodata looks too good
to be truerdquo
3122015 Ajaz S Hussain PhD 24
GMP Compliance amp Remediation
Jeff Medwid NIPTE-FDA Conference 13 June 2012
QbD amp QbR Clarity on Critical Functionality
FDArsquos New Pharma Quality
Office Will Take a Team
Approach Yu Explains
Carmelo Rosa MS PsyD November 2014
Urgent Need amp Opportunity
To align amp ensure sound scientific basis of these critical regulatory decisions
FDA CDER OPQ Plans for Surveillance of Pharmaceutical Quality
Teresa Mullin PhD December 2014
3122015 Ajaz S Hussain PhD 25
Need for a comprehensive (excipient) knowledge base
Teresa Mullin PhD December 2014
3122015 Ajaz S Hussain PhD 26
Why attention to (excipient) knowledge management is criticalSpecifically for physical attributes functionality performance
3122015 Ajaz S Hussain PhD 27
3122015 Ajaz S Hussain PhD 28
Today there are several product categories (eg controlled release inhalation products DPIrsquos topical transdermal liposomal products etc) which requires an exquisite control of complex physical material and product attributes (functionality)
Many of our current measurement systems need improvement
We depend on these to ensure control of lot-lot variability
Measurement system capability must be confirmed to be able to assess process capability (calibration amp Gauge RampR)
Life-cycle approach to quality continued process verification (FDArsquos Process Validation 2011) is a safety net
Supplier amp Excipient Qualification amp Process Validation
Measurement System Analysis
bull From lsquocalibrationrsquo to lsquoGauge RampRrsquoParticularly for physical
attributes destructive analysis
bull Many (including regulators) have not yet understood its importance
Gauge RampR well established but not commonly practiced
bull Measurement system in a state of control effective CAPA quality metrics Culture of Quality
With the move towards Statistical Process Control
bull Demonstrate equivalent in vitro performance more exacting criteria
Development of complex generic products (ER
Injectable Inhalation etc)
3122015 Ajaz S Hussain PhD 29
Process Validation (2011) Statistical Confidence Continued Process Verificationhellip
3122015 Ajaz S Hussain PhD 30
httpwwwslideshareneta2zpharmsciperformance-testing-pharmaceutical-quality-2004(accessed 6 December 2014)
3122015 Ajaz S Hussain PhD 31
Supplier amp Excipient Qualification amp CAPA
Out of Specification events are difficult to resolve
Excipient functionality can be a significant contributing factor
Sometimes reluctantly have to settle with - ldquoRoot cause unknown
600 days
I have inserted the ldquo600 daysrsquo on the figure ndash this is based on cases I have seen while at FDA)
3122015 Ajaz S Hussain PhD 32
Prevention of OOS and Effective CAPA needs a focus on critical functional attributes
Out of Specification events are difficult to resolve
Excipient functionality can be a significant contributing factor
Sometimes reluctantly have to settle with - ldquoRoot cause unknown
Compendial standards and manufacturing
3122015 Ajaz S Hussain PhD 33
Practice Control Process Maturity
Initial
bull Unpredictable
Managed
bull Characterized but reactive
Defined
bull Characterized proactive
Measured amp Controlled
bull In control
Optimizing
bull Focus on improvement
3122015 Ajaz S Hussain PhD 34
Capability Maturity Model Integration Carnegie Mellon University
A validated process
Maturity Level amp Assurance of Quality
Managed Characterized but reactive
High perceived risk of
lsquoCheating by Designrsquo
ldquoTrial Injectionsrdquo
ldquoTesting in to Compliancerdquo
Defined Characterized proactive
Lower level of assurance
Stopping amp Correcting
Batch Rejection
Measured amp
ControlledIn control
Quality by Design
Quality Assured
Improvement Opportunities
3122015 Ajaz S Hussain PhD 35
At the individual level in QC functionndash how often does this occur
attitude toward
performing the behavior
Process validation is
done so quality is good
test prone to error
ldquoBatch failure means I made
a mistakerdquo
subjective norm
documentation not critical
Compendial testing
sufficient
Indian regulators
collect amp test samples ndash no issue there
3122015 Ajaz S Hussain PhD 36
ldquoTesting into compliancerdquo
In general ndash low empowerment is a significant challenge (low perceived behavioral control) plus reasons to rationalizehellip
Excipient Functionality Can be critical for safety efficacy and quality
3122015 Ajaz S Hussain PhD 37
July 15 2005 FDA Public Health Advisory Safety Warnings Regarding Use of Fentanyl Transdermal (Skin) Patches
A pattern of failure Pharmaceutical Equivalence by Design (2004)
3122015 Ajaz S Hussain PhD 38
httpwwwnihsgojpdrugPhForumdocuments041122Hussain041122pdf
An attempt to correct
3122015 Ajaz S Hussain PhD 39
httpipecamericasorgsystemfilesKeyNoteEF13May11LawrenceYu(FDA)pdf
Recent challenges
3122015 Ajaz S Hussain PhD 40
Th
e V
oic
e o
f th
eA
mer
ican
P
sych
iatr
ic A
sso
ciat
ion
and
th
e P
sych
iatr
ic C
om
mu
nit
y
Physicians Question FDAs Confidence in Generic Drugs Safety Efficacy (OCTOBER 24 2014)
bull ldquomost patientsrdquo is not the same asldquo all patientsrdquo and whether the 24 to 36 normal subjects used in the agencys bioequivalency tests represents the full range of individual variation in the way drugs are absorbed across the pharmaceutical using population is uncertain
bull Individuals can sometimes be allergic and react differently to whatever substance goes into making up the capsule or the tablet
FDA Flags Generic Versions of ADHD Medication(NOVEMBER 14 2014)
bull FDA changed the therapeutic equivalence (TE) rating from AB to BXmdashmeaning that the products are still approved and can be prescribed but are no longer recommended as automatic substitutes
RLD Variability Can be a block-buster opportunityFocus on lsquocontrol strategyrsquo
bull Overcoming CP amp IP provide FDA a submission they need to address CP
bull Then begin with QTPP CQArsquos hellip skip lsquodesign spacersquo and focus on lsquocontrol strategy
bull The entire development team should read the complete package insert of RLD
bull Discuss to ensure a common understandingbull Failure modes amp intended use
bull Pharmaceutical Equivalence
bull Bioequivalence
bull Other studies
QbD Challenges
3122015 Ajaz S Hussain PhD 41
NewRegulators are not prepared to handle QbD applications
NewMisalignment of international regulatory authorities
New and Generics
RampD incentivized for lsquoshots on the goalrsquo not QbD
GenericsLack of belief in business case ndash lsquoGenerics are all about file first figure out laterrsquo
Biologics Lack of technology to execute
Ted Fuhr Mackinsey amp Company June 2010 FDA Advisory Committee
Summary
bull Excipient functionality can contribute in critical ways to product quality amp performance adequate control is necessary
bull Our databases tools and knowledge are lagging behind the rapidly increasing complexity and uncertainty
bull Risk to quality and to business is increasing and regulatory transitions pose additional difficulties
bull Effective knowledge management ndash IT and Human practices ndash is critical for organizational lsquobottom-linersquo
bull We all must come together collaboratively to address the urgent needs we owe it to the patients we serve
3122015 Ajaz S Hussain PhD 42
Knowledge Management amp Culture of Quality
Ajaz S Hussain PhD
Insight Advice amp Solutions LLCMaryland USA
Executive Director the National Institute for Pharmaceutical Technology amp Education
3122015 Ajaz S Hussain PhD 43
3122015 Ajaz S Hussain PhD 44
Life-cycle approach needed for knowledge management
Investigational ProductscGMPs
DevelopmentTechnology
TransferCommercial
ManufacturingDiscontinuation
Management Responsibility
Process Performance amp Product Quality Monitoring SystemCAPA Change Management Management Review
PQS Elements
Knowledge ManagementQuality Risk ManagementEnablers
ICH Q10 KM is a systematic approach to acquiring analyzing storing and disseminating information related to products manufacturing processes and components
Based on ICH Q10
ldquowe can be blind to the obvious and we are also blind to our blindnessrdquo
Daniel Kahneman Thinking Fast and Slow
3142015 Ajazajazhussaincom 45
httpwebmiteduperscipeopleadelsoncheckershadow_proofhtml
3122015 Ajaz S Hussain PhD 46
1938 The Federal Food Drug and Cosmetic (FDC)
bull 1937 Elixir of Sulfanilamide
1962 Kefauver-Harris Drug Amendments
bull 1962 Thalidomide
bull 1960 Color Additive Amendment
bull 1958 Food Additives Amendment GRAS
bull 1960 Color Additive Amendment
bull 1958 Food Additives Amendment GRAS
1992 Generic Drug Enforcement Act
bull1989 L-Tryptophan
bull 1989 Generic Drug Scandal
bull 1988 Food and Drug Administration Act
bull 1984 Fines Enhancement Laws Drug Price Competition and Patent Term Restoration Act
2012 Food and Drug Administration Safety and Innovation Act (FDASIA)
bull 2007 Heparin Disaster
2013 Pandemic and All-Hazards Preparedness Reauthorization Act (PAHPRA) Drug Quality and Security Act
bull 2012 The Deadly Meningitis Outbreak
Past 70 years 1937 ndash 2007 The diethylene glycol (DEG) narrative
3122015 Ajaz S Hussain PhD 47
0
5
10
15
20
25
30
35
Yea
rs
DEG Years since the previous incident
0
50
100
150
200
250
300
350
Number of Reported Deaths
1937
Eli
xir
of
Sulf
anil
amid
e
2007T
ootp
aste
conta
min
atio
n
0 70 years 0 70 years
Frequent reports
Mumbai Mumbai
Data from Excipient Fest Janeen Skutnik Chair ndashIPECAmericas 2009
Past 70+ years DEG contamination or economically motivated adulteration
3122015 Ajaz S Hussain PhD 48
Reported cases underestimate the real tragedy rapid intervention may not occur
Epidemic of Pediatric Deaths From Acute Renal Failure Caused by
Diethylene Glycol Poisoning JAMA 1998279(15)1175-1180
doi101001jama279151175
Month of hospital admission for children with
acute renal failure Haiti
October 1995-October 1996
Diethylene glycol poisoning in Gurgaon India 1998Bulletin of the World Health Organization 2001 79 88ndash95
We report a second episode of poisoning occurring in 1998 in
India as a result of children ingesting diethylene glycol at
least 33 children are known to have died
At the beginning of the investigation we never imagined that
contaminated medicine was causing acute renal failure in
children
A brand of cough expectorant manufactured by a local
pharmaceutical company was found by the Central Drugs
Laboratory Calcutta to contain 175 (vv) diethylene
glycol
The district and state drug controller had tested many
samples using thin layer chromatography before a sample of
medicine tested positive for diethylene glycol at the Central
Drugs Laboratory None of the earlier samples was found to
be contaminated
3122015 Ajaz S Hussain PhD 49
Guidance for Industry Testing of
Glycerin for Diethylene Glycol
CDER May 2007 Compliance
1 Manufacturers did not perform full
identity testing on the glycerin raw
material including tests to quantify
the amount of DEG
2 Relied on the certificate of analysis
(COA)
3 The origin of the glycerin was not
easily apparent from the COA
4 The COA was often a copy of a COA
on the letterhead of the distributor
5 The chain of custody or distribution
history of the glycerin was also not
readily known
USP Glycerin Monograph
Type of Posting Revision Bulletin
Posting Date 04ndashFebndash2009
Official Date 01ndashMayndash2009
Because of the serious hazards
associated withhellip and in response to
recommendations set forth in the
FDA Guidance for Industry Testing
of Glycerin for Diethylene Glycol
published in May 2007 USP has
revised the USP Glycerin monograph
Because diethylene glycol and
ethylene glycol are considered
unacceptable toxic substances the
testing of USP Glycerin should
demonstrate the absence of these
substances
April 2007 FDA request to
USP to revise the Glycerin
monographrsquos
IDENTIFICATION section
Revision includes adding ndash
Identification test B LIMIT OF
DIETHYLENE GLYCOL AND
ETHYLENE GLYCOL to detect
and quantify DEGEG in Glycerin
minus Is no longer part of the impurity
testing
ldquoLimit of DEG and Related
Compoundsrdquo minus Introduces a
capillary gas-chromatographic
(GC) method with flame ionization
detection (FID) minus Limit of NMT
010 each for diethylene glycol
and ethylene glycol is found
70+ years to get here how difficult will it be to change habits such as lsquoblind reliance of COArsquo
3122015 Ajaz S Hussain PhD 50
Personality and Habitual Frame Biases
Myers Brigs ENTJ (first tested at FDA)
S
TF
Expanded frame
future
possibilities
objective lsquocause
and effectrsquo
Expanded frame
future
possibilities
people and
relationships
Narrow frame
the present
individuals and
relationships
Narrow frame
the present
objective
cause and
effect
N
Based on Stanford Webinar - How to Overcome the Top 3 MegaBiases in Decision-Making
Stanford Universityrsquos Strategic Decision and Risk Management certificate program
From Mapping a Managers Brain on Incentives
Social
influences
Relative
thinking
UncertaintyComplexity
By Design Intention to act consciously
bull In the interest of patients and to continually improve this ability bull To provide a healing touch ndash one life at a time in what we do and how we
do it
1292014 Ajazajazhussaincom 51
Consciously
Scientific methodology
Engineering Design
Plan-Do-Check-Act
Subconsciously
Habits (work to get rid of bad ones)
Habits (work to cultivate good one)
Keystone habits (Safety Alcoa ALCOA of data integrity)
The Power of Habit Why We Do What We Do in Life and Business Charles Duhigg (2012)
httpwwwslideshareneta2zpharmscipharmaceutical-culture-of-quality
What does it take to come out of the cGMP crisis
Persuasive demonstration of
(1) Ability to face facts
(2) Legal amp regulatory requirements
3) Systems approach to quality
4) Changing behavior amp culture
What is often missed or is unconvincing is how you will strengthen culture of quality
ldquoLet one who wants to move and convince others first be convinced and moved themselvesrdquo Thomas Carlyle
Signals that question the competence motivation andor integrity of company personnel
Do not defend the plainly indefensible it adds further serious credibility costs
3142015 Ajazajazhussaincom 52
Quality is everyones responsibility
Lack of knowledge that is
the problem
If you do not know how to ask the
right question you discover nothing
If you cant describe what you
are doing as a process you dont know what youre
doing
Rational behavior requires theory
Reactive behavior requires only reflex
action
Whenever there is fear you will get wrong figures
3142015 Ajazajazhussaincom 53
Selected quotes W Edwards Deming
3142015 Ajazajazhussaincom 54
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
ldquoWE CANNOT CHANGE THE HUMAN CONDITION BUThellipWE CAN CHANGE THE CONDITIONS UNDER WHICH HUMANS WORKrdquo JAMES REASON
Disregard to Malice
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 55
ldquohelliprecords not completed
contemporaneouslyrdquo
ldquohellipobserved analyst back-date logbooksrdquo
ldquohelliptrial injectionshelliprdquo
ldquohellipresults failing specifications are
retested until acceptable results are obtainedhelliprdquo
ldquohellipover-writing electronic raw datahelliprdquo
ldquohellipOOS not investigates per XYZ SOPrdquo
ldquohellipappropriate controls not establishedhelliprdquo
Each additional observation adds
reasons to confirm that this is very likely a system
with intentional lsquoholesrsquo in its
defenses
Preconditions
Rationalization amp Attitude
Pressure amp Incentive
Opportunity ndashlsquoholes in the QMSrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 56
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 57
Attitude towards the behavior
Subjective norm
Perceived behavioral
control
IntentionFuture
Behavior
usually found to predict behavioral intentions with a high degree of accuracy
intentions in combination with perceived behavioral control can account for a considerable proportion of variance in behavior
PastBehavior
Ajen I The theory of planned behavior ORGANIZATIONAL BEHAVIOR AND HUMAN DECISION PROCESSES 50 179-211 (1991)
Heparin tragedy 2007 and 2008
FDA reports 149 deaths with allergic or hypersensitivity symptoms during that period
bull Contaminated heparin from China
QC Testing
bull Initial testing failed to detect the contaminant
Pharmacovigilence
bull Signals in the pharmacovigilence systems responded slowly and
Eventually the severity of reactions associated made it likely that the contamination would be detected
bull too late for those who died or were injured
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 58
Congressman Shimkus When the drug safety system fails people get sick Some die
bull Some of these people are already very vulnerable and proving the cause of harm from impurities adulteration and counterfeits can be elusive
It is hard to detect harm
bull Certainly the companies are obligated to ensure a culture of quality and maintain vigilance as well This reflects a systems approach to safety
FDA inspectors look for a culture of quality at
manufacturing facilities
bull FDA policies led to the failure to inspect the Chinese plantThis system approach wasnt at
play here
bull While it doesnt deny the counterfeit source tries to say that counterfeits didnt cause the reaction as if the adulteration itself was no big deal Is this an acceptable mindset helliphelliphellip
This brings me to China and its quality culture or lack thereof
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 59
ONE HUNDRED TENTH CONGRESS SECOND SESSION APRIL 29 2008 Serial No 110-109
21 CFR PART 211 SUBPARTS -Deviations signal gaps in CoQ
bullGENERAL PROVISIONSA
bullORGANIZATION AND PERSONNELB
bullBUILDINGS AND FACILITIESC
bullEQUIPMENTD
bullCONTROL OF COMPONENTS AND DRUG PRODUCT CONTAINERS AND CLOSURESE
bullPRODUCTION AND PROCESS CONTROLSF
bullPACKAGING AND LABELING CONTROLG
bullHOLDING AND DISTRIBUTIONH
bullLABORATORY CONTROLSI
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 60
For example the combinationhellip
The Power of Habit Why We Do What We Do in Life and Business Charles Duhigg (2012)
bull Scientific methodology
bull Engineering Design
bull Plan-Do-Check-ActConsciously
bull Habits (work to get rid of bad ones)
bull Habits (work to cultivate good one)
bull Keystone habits (Safety Alcoa ALCOA of data integrity)
Subconsciously
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 61
CoQ How
bull What are the predictors of CoQCoQ Manifests by Design -
lsquoquality by designrsquo the foundation
bull 1 2 3When do people change their behaviors
bull A B C D (any body can dance)What makes a QMS effective
bull X Y ZWhen proactive compliance occurs
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 62
Going beyond rules pays
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 63
Human behavior Connecting the Dots With the Right Connectors
GXPs ndash rational behaviors
How proactive compliance is achieved X Y Z
Quality Management System
What makes a QMS reliable A B C D
Culture of Quality
Why people change their behavior 1 2 3
Human Behaviors Beyond GXPs
Predictors of Culture of Quality
Why What and How of Culture of Quality
9192014 copy Ajaz S Hussain | INSIGHT ADVICE amp SOLUTIONS LLC 64
Predictors of CoQ Act consciously in the interest of patients ndash when no one is looking
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 65
Only four attributes
actually predict a culture of
quality
Leadership Emphasis
Message Credibility
Peer Involvement
Employee Empower-ment
People will change their
behavior if they see the new behavior as
Normal
(1)
Rewarding
(2)
Easy
(3)
Dr W Edwards Demingrsquos - ldquoOut of the crisisrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 66
The journey requires leadership
with Profound Knowledge as a
guide
bull As leaders responsible for system change top management is most in need of profound knowledge
bull Quality is often determined in the boardroom
bull Problems arise when management reacts to common cause or chance variation as if it were special cause variation
bull Prediction based in theory provides a foundation for planning a course of action Plan ndash Do ndash Check ndash Act
bull The leader serves the people with clear vision and guidance to empower them To be empowered is to share ownership in the identity
bull Giving people a certain degree of control over their work fulfills the need for freedom and provides opportunity for taking joy in work
Profound Knowledge as a guide
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 67
Appreciation for a System
Theory of Knowledge
Knowledge about
Variation
Human Behavior -Psychology of Change
A
B
C
D+
Systems Approach for ErrorDeviation Management
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 68
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
Human error models and management J Reason BMJ 320 768ndash770 (2000)
D+
Culture of Error Management परबधनbull Error strain
bull Covering upFear of Errors
bull Anticipation
bull Risk takingAwareness
bull Development QbDRFT
bull Error detection Communication
bull Analyzing errors Correction
Mastery orientation
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 69
Dots amp Connections
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 70
CoQ
1
2
3
QMS
A
B
C
D
GXP Behaviors
X
Y
Z
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 71
Culture of Quality
Normal
Rewarding
Easy
QMS
System
Knowledge
Variation
Behavior
Behavior -GXPs
Fear Removed
Mastery
Awareness
EnvironmentLeadership Emphasis
Message Credibility
Peer Involvement
Employee Empowerment
Connect to CoQ
Connect to GXPs
A Framework and a Tool (for gap analysis)
Current hot topics ndashrsquoexcipientsrsquo regulatory trends amp insights ExcipientFest on 28-29 April 2015 in Washington Organizational Changes CDERFDA and Inspectional Trendshellip(Complex Genericshellip Continuous Manufacturing)
3122015 Ajaz S Hussain PhD 16
Current experience with lsquoSupplier Qualificationrsquo
bull Recent observations are summarized in this report by ECA Academy (21012015) Areas of attention
bull Accuracy and completeness of administrative documentation
bull Evidence to justify excipient and supplier qualification
bull Risk-assessment and effective integration within in QMS
bull Quality agreements
bull Going forward I envision a need to emphasize a life-cycle approach (eg linking to CAPA change control)
3122015 Ajaz S Hussain PhD 17
FDArsquos Inactive Ingredient Database -statusbull Substance Registration System (SRS)
bull Generic listing vs Specific Grade listing for commonly used excipients ndashmax precedent levels
bull Listing of Mixtures
bull The UNII code confusing the National Library of Medicine yet to finalize standards for assigning UNII codes for polymers
bull Individual Grades vs Family Data
bull Legal status of the IID and FDA communications of changes to the IID
bull DMF Implications
bull Impact on ANDAs ndash lsquoDelaysrsquo amp lsquoRefuse to File Lettersrsquo
3122015 Ajaz S Hussain PhD 18
3122015 Ajaz S Hussain PhD 19
Inactive Ingredientsrsquo to lsquoExcipientsrsquo to lsquoFunctionalityrsquo Where are we in this journeylsquo
Status of lsquoSubstances In Regulatory Practicersquo
Clearly we need a global database with improved precision and accuracy of naming (and coding) to identify describe compare and link (to products and AERs)
INDs NDAs BLAs CFRrsquos Orphan Drug ApplicationsProducts that Contain Each Substance
Pharmacological ClassificationActive Moieties Related Moieties and Salts
LADMERMetabolites
Metabolic Enzymes Transporters and EffectsDrug target (therapeutic and other) type of interaction
Solubility and Permeability (BCS)Protein Binding
Impurities and Related Substance
ISO 11238 (ISO IDMP) some challenges
Both substances amp specified substances
Implementation in EU EMA Task force
Global Ingredients Archive System (GInAS)
3122015 Ajaz S Hussain PhD 20
The War Against Fake Medicines Update on FDASIA - Guidance and Impact on Excipient Suppliers and
Users QbD Sampling Guidelines The NSFIPECANSI 363 2014 GMP standardsexplained Good Supply Practices ndash Using Cross Industry Knowledge to Devise Pragmatic Solutions Impact
of Non-harmonized Standards and What is Needed to Achieve Harmonization Advancements in the Question Based Review approach and various other excipient specific related topics An Overview of the FDA OGD
IID EWG activities Effective Sourcing and Purchasing of Excipients
Industry Collaboration for Science Based Implementation of Elemental Impurities Challenges And Opportunities In Developing
And Modernizing Public Standards For NF Excipients Monographs For Regulated Drug
Products Marketed In The USA Future Pharma Manufacturing Efficiencies and the Role of Innovative Excipient Technologies
IPEC ExcipientFest 2015
Current Hot Topics ExcipientFest on 28-29 April 2015 in Washington
3122015 Ajaz S Hussain PhD 21
The War Against Fake Medicines Update on FDASIA - Guidance and Impact on Excipient
Suppliers and Users QbD Sampling Guidelines The NSFIPECANSI 363 2014 GMP standards explained Good Supply Practices ndash Using Cross Industry Knowledge to Devise
Pragmatic Solutions Impact of Non-harmonized Standards and What is Needed to Achieve
Harmonization Advancements in the Question Based Review approach and various other
excipient specific related topics An Overview of the FDA OGD IID EWG activities Effective
Sourcing and Purchasing of Excipients Industry Collaboration for Science Based Implementation of Elemental Impurities Challenges And
Opportunities In Developing And Modernizing Public Standards For NF ExcipientsMonographs For Regulated Drug Products Marketed In The USA Future Pharma Manufacturing Efficiencies and the Role of Innovative Excipient Technologies
IPEC ExcipientFest 2015
Inspectional trends in data integrity (Bangalore Nov
2014)
22(d)
192
100(a)
160(b)
110(a)
67(b)
68(a)
25(a)
67(a)
100(b)
Recurring 483 Observations Top 10
22(d) 192 100(a) 160(b)110(a) 67(b) 68(a) 25(a)67(a) 100(b)
Jeff Medwid NIPTE-FDA Conference 13 June 2012
International Society for Pharmaceutical Engineering (ISPE) in conjunction with McKinsey amp Co will release preliminary data and findings from its Quality Metrics Pilot Program at the ISPE Quality Metrics Summit on April 21ndash22 in Baltimore
FDA Launches New Drug Quality Office With Goal of Improving the Pharmaceutical IndustryPosted 13 January 2015By Alexander Gaffney RAC
FDArsquos New Pharma Quality
Office Will Take a Team Approach
Yu Explains
Regulatory Recon Investigations Find Major Quality Problems at Indian Pharma Companies (3 December 2014)Posted 03 December 2014By Alexander Gaffney RAC
Currently the environment is complex there is high uncertainty D
on
rsquot f
org
et
fun
ctio
na
lity
o
f e
xcip
ien
ts i
s im
po
rta
nt
3122015 Ajaz S Hussain PhD 22
Need for urgent progress lsquoInactive Ingredientsrsquo to lsquoExcipientsrsquo to lsquoFunctional Excipientsrsquo
Importance of assuring quality and controlling
variability of excipients
including their lsquofunctionalityrsquo has
long been recognized
bull Increasing complexity of drugs their delivery and failure modes
bull Patient (eg pediatric) relevant failure modes
bull Simple generics to complex generics amp biosimilars
Urgent need to address gaps in the FDArsquos Inactive Ingredient Database
3122015 Ajaz S Hussain PhD 23
Trends Lab amp Manufacturing
ldquoDeletion of Datardquo
ldquoTesting Into Compliancerdquo
ldquoBMR manipulation is a slippery sloperdquo
ldquoSuggestive of faulty manufacturing process or practices even if this is not the caserdquo
ldquoIt is top managementrsquos responsibility to ensure the training program is robust and effectiverdquo
Inspectional trends in data integrity (Bangalore Nov 13 2014 - Nov 14 2014)
Growing concern some
companies ldquodata looks too good
to be truerdquo
3122015 Ajaz S Hussain PhD 24
GMP Compliance amp Remediation
Jeff Medwid NIPTE-FDA Conference 13 June 2012
QbD amp QbR Clarity on Critical Functionality
FDArsquos New Pharma Quality
Office Will Take a Team
Approach Yu Explains
Carmelo Rosa MS PsyD November 2014
Urgent Need amp Opportunity
To align amp ensure sound scientific basis of these critical regulatory decisions
FDA CDER OPQ Plans for Surveillance of Pharmaceutical Quality
Teresa Mullin PhD December 2014
3122015 Ajaz S Hussain PhD 25
Need for a comprehensive (excipient) knowledge base
Teresa Mullin PhD December 2014
3122015 Ajaz S Hussain PhD 26
Why attention to (excipient) knowledge management is criticalSpecifically for physical attributes functionality performance
3122015 Ajaz S Hussain PhD 27
3122015 Ajaz S Hussain PhD 28
Today there are several product categories (eg controlled release inhalation products DPIrsquos topical transdermal liposomal products etc) which requires an exquisite control of complex physical material and product attributes (functionality)
Many of our current measurement systems need improvement
We depend on these to ensure control of lot-lot variability
Measurement system capability must be confirmed to be able to assess process capability (calibration amp Gauge RampR)
Life-cycle approach to quality continued process verification (FDArsquos Process Validation 2011) is a safety net
Supplier amp Excipient Qualification amp Process Validation
Measurement System Analysis
bull From lsquocalibrationrsquo to lsquoGauge RampRrsquoParticularly for physical
attributes destructive analysis
bull Many (including regulators) have not yet understood its importance
Gauge RampR well established but not commonly practiced
bull Measurement system in a state of control effective CAPA quality metrics Culture of Quality
With the move towards Statistical Process Control
bull Demonstrate equivalent in vitro performance more exacting criteria
Development of complex generic products (ER
Injectable Inhalation etc)
3122015 Ajaz S Hussain PhD 29
Process Validation (2011) Statistical Confidence Continued Process Verificationhellip
3122015 Ajaz S Hussain PhD 30
httpwwwslideshareneta2zpharmsciperformance-testing-pharmaceutical-quality-2004(accessed 6 December 2014)
3122015 Ajaz S Hussain PhD 31
Supplier amp Excipient Qualification amp CAPA
Out of Specification events are difficult to resolve
Excipient functionality can be a significant contributing factor
Sometimes reluctantly have to settle with - ldquoRoot cause unknown
600 days
I have inserted the ldquo600 daysrsquo on the figure ndash this is based on cases I have seen while at FDA)
3122015 Ajaz S Hussain PhD 32
Prevention of OOS and Effective CAPA needs a focus on critical functional attributes
Out of Specification events are difficult to resolve
Excipient functionality can be a significant contributing factor
Sometimes reluctantly have to settle with - ldquoRoot cause unknown
Compendial standards and manufacturing
3122015 Ajaz S Hussain PhD 33
Practice Control Process Maturity
Initial
bull Unpredictable
Managed
bull Characterized but reactive
Defined
bull Characterized proactive
Measured amp Controlled
bull In control
Optimizing
bull Focus on improvement
3122015 Ajaz S Hussain PhD 34
Capability Maturity Model Integration Carnegie Mellon University
A validated process
Maturity Level amp Assurance of Quality
Managed Characterized but reactive
High perceived risk of
lsquoCheating by Designrsquo
ldquoTrial Injectionsrdquo
ldquoTesting in to Compliancerdquo
Defined Characterized proactive
Lower level of assurance
Stopping amp Correcting
Batch Rejection
Measured amp
ControlledIn control
Quality by Design
Quality Assured
Improvement Opportunities
3122015 Ajaz S Hussain PhD 35
At the individual level in QC functionndash how often does this occur
attitude toward
performing the behavior
Process validation is
done so quality is good
test prone to error
ldquoBatch failure means I made
a mistakerdquo
subjective norm
documentation not critical
Compendial testing
sufficient
Indian regulators
collect amp test samples ndash no issue there
3122015 Ajaz S Hussain PhD 36
ldquoTesting into compliancerdquo
In general ndash low empowerment is a significant challenge (low perceived behavioral control) plus reasons to rationalizehellip
Excipient Functionality Can be critical for safety efficacy and quality
3122015 Ajaz S Hussain PhD 37
July 15 2005 FDA Public Health Advisory Safety Warnings Regarding Use of Fentanyl Transdermal (Skin) Patches
A pattern of failure Pharmaceutical Equivalence by Design (2004)
3122015 Ajaz S Hussain PhD 38
httpwwwnihsgojpdrugPhForumdocuments041122Hussain041122pdf
An attempt to correct
3122015 Ajaz S Hussain PhD 39
httpipecamericasorgsystemfilesKeyNoteEF13May11LawrenceYu(FDA)pdf
Recent challenges
3122015 Ajaz S Hussain PhD 40
Th
e V
oic
e o
f th
eA
mer
ican
P
sych
iatr
ic A
sso
ciat
ion
and
th
e P
sych
iatr
ic C
om
mu
nit
y
Physicians Question FDAs Confidence in Generic Drugs Safety Efficacy (OCTOBER 24 2014)
bull ldquomost patientsrdquo is not the same asldquo all patientsrdquo and whether the 24 to 36 normal subjects used in the agencys bioequivalency tests represents the full range of individual variation in the way drugs are absorbed across the pharmaceutical using population is uncertain
bull Individuals can sometimes be allergic and react differently to whatever substance goes into making up the capsule or the tablet
FDA Flags Generic Versions of ADHD Medication(NOVEMBER 14 2014)
bull FDA changed the therapeutic equivalence (TE) rating from AB to BXmdashmeaning that the products are still approved and can be prescribed but are no longer recommended as automatic substitutes
RLD Variability Can be a block-buster opportunityFocus on lsquocontrol strategyrsquo
bull Overcoming CP amp IP provide FDA a submission they need to address CP
bull Then begin with QTPP CQArsquos hellip skip lsquodesign spacersquo and focus on lsquocontrol strategy
bull The entire development team should read the complete package insert of RLD
bull Discuss to ensure a common understandingbull Failure modes amp intended use
bull Pharmaceutical Equivalence
bull Bioequivalence
bull Other studies
QbD Challenges
3122015 Ajaz S Hussain PhD 41
NewRegulators are not prepared to handle QbD applications
NewMisalignment of international regulatory authorities
New and Generics
RampD incentivized for lsquoshots on the goalrsquo not QbD
GenericsLack of belief in business case ndash lsquoGenerics are all about file first figure out laterrsquo
Biologics Lack of technology to execute
Ted Fuhr Mackinsey amp Company June 2010 FDA Advisory Committee
Summary
bull Excipient functionality can contribute in critical ways to product quality amp performance adequate control is necessary
bull Our databases tools and knowledge are lagging behind the rapidly increasing complexity and uncertainty
bull Risk to quality and to business is increasing and regulatory transitions pose additional difficulties
bull Effective knowledge management ndash IT and Human practices ndash is critical for organizational lsquobottom-linersquo
bull We all must come together collaboratively to address the urgent needs we owe it to the patients we serve
3122015 Ajaz S Hussain PhD 42
Knowledge Management amp Culture of Quality
Ajaz S Hussain PhD
Insight Advice amp Solutions LLCMaryland USA
Executive Director the National Institute for Pharmaceutical Technology amp Education
3122015 Ajaz S Hussain PhD 43
3122015 Ajaz S Hussain PhD 44
Life-cycle approach needed for knowledge management
Investigational ProductscGMPs
DevelopmentTechnology
TransferCommercial
ManufacturingDiscontinuation
Management Responsibility
Process Performance amp Product Quality Monitoring SystemCAPA Change Management Management Review
PQS Elements
Knowledge ManagementQuality Risk ManagementEnablers
ICH Q10 KM is a systematic approach to acquiring analyzing storing and disseminating information related to products manufacturing processes and components
Based on ICH Q10
ldquowe can be blind to the obvious and we are also blind to our blindnessrdquo
Daniel Kahneman Thinking Fast and Slow
3142015 Ajazajazhussaincom 45
httpwebmiteduperscipeopleadelsoncheckershadow_proofhtml
3122015 Ajaz S Hussain PhD 46
1938 The Federal Food Drug and Cosmetic (FDC)
bull 1937 Elixir of Sulfanilamide
1962 Kefauver-Harris Drug Amendments
bull 1962 Thalidomide
bull 1960 Color Additive Amendment
bull 1958 Food Additives Amendment GRAS
bull 1960 Color Additive Amendment
bull 1958 Food Additives Amendment GRAS
1992 Generic Drug Enforcement Act
bull1989 L-Tryptophan
bull 1989 Generic Drug Scandal
bull 1988 Food and Drug Administration Act
bull 1984 Fines Enhancement Laws Drug Price Competition and Patent Term Restoration Act
2012 Food and Drug Administration Safety and Innovation Act (FDASIA)
bull 2007 Heparin Disaster
2013 Pandemic and All-Hazards Preparedness Reauthorization Act (PAHPRA) Drug Quality and Security Act
bull 2012 The Deadly Meningitis Outbreak
Past 70 years 1937 ndash 2007 The diethylene glycol (DEG) narrative
3122015 Ajaz S Hussain PhD 47
0
5
10
15
20
25
30
35
Yea
rs
DEG Years since the previous incident
0
50
100
150
200
250
300
350
Number of Reported Deaths
1937
Eli
xir
of
Sulf
anil
amid
e
2007T
ootp
aste
conta
min
atio
n
0 70 years 0 70 years
Frequent reports
Mumbai Mumbai
Data from Excipient Fest Janeen Skutnik Chair ndashIPECAmericas 2009
Past 70+ years DEG contamination or economically motivated adulteration
3122015 Ajaz S Hussain PhD 48
Reported cases underestimate the real tragedy rapid intervention may not occur
Epidemic of Pediatric Deaths From Acute Renal Failure Caused by
Diethylene Glycol Poisoning JAMA 1998279(15)1175-1180
doi101001jama279151175
Month of hospital admission for children with
acute renal failure Haiti
October 1995-October 1996
Diethylene glycol poisoning in Gurgaon India 1998Bulletin of the World Health Organization 2001 79 88ndash95
We report a second episode of poisoning occurring in 1998 in
India as a result of children ingesting diethylene glycol at
least 33 children are known to have died
At the beginning of the investigation we never imagined that
contaminated medicine was causing acute renal failure in
children
A brand of cough expectorant manufactured by a local
pharmaceutical company was found by the Central Drugs
Laboratory Calcutta to contain 175 (vv) diethylene
glycol
The district and state drug controller had tested many
samples using thin layer chromatography before a sample of
medicine tested positive for diethylene glycol at the Central
Drugs Laboratory None of the earlier samples was found to
be contaminated
3122015 Ajaz S Hussain PhD 49
Guidance for Industry Testing of
Glycerin for Diethylene Glycol
CDER May 2007 Compliance
1 Manufacturers did not perform full
identity testing on the glycerin raw
material including tests to quantify
the amount of DEG
2 Relied on the certificate of analysis
(COA)
3 The origin of the glycerin was not
easily apparent from the COA
4 The COA was often a copy of a COA
on the letterhead of the distributor
5 The chain of custody or distribution
history of the glycerin was also not
readily known
USP Glycerin Monograph
Type of Posting Revision Bulletin
Posting Date 04ndashFebndash2009
Official Date 01ndashMayndash2009
Because of the serious hazards
associated withhellip and in response to
recommendations set forth in the
FDA Guidance for Industry Testing
of Glycerin for Diethylene Glycol
published in May 2007 USP has
revised the USP Glycerin monograph
Because diethylene glycol and
ethylene glycol are considered
unacceptable toxic substances the
testing of USP Glycerin should
demonstrate the absence of these
substances
April 2007 FDA request to
USP to revise the Glycerin
monographrsquos
IDENTIFICATION section
Revision includes adding ndash
Identification test B LIMIT OF
DIETHYLENE GLYCOL AND
ETHYLENE GLYCOL to detect
and quantify DEGEG in Glycerin
minus Is no longer part of the impurity
testing
ldquoLimit of DEG and Related
Compoundsrdquo minus Introduces a
capillary gas-chromatographic
(GC) method with flame ionization
detection (FID) minus Limit of NMT
010 each for diethylene glycol
and ethylene glycol is found
70+ years to get here how difficult will it be to change habits such as lsquoblind reliance of COArsquo
3122015 Ajaz S Hussain PhD 50
Personality and Habitual Frame Biases
Myers Brigs ENTJ (first tested at FDA)
S
TF
Expanded frame
future
possibilities
objective lsquocause
and effectrsquo
Expanded frame
future
possibilities
people and
relationships
Narrow frame
the present
individuals and
relationships
Narrow frame
the present
objective
cause and
effect
N
Based on Stanford Webinar - How to Overcome the Top 3 MegaBiases in Decision-Making
Stanford Universityrsquos Strategic Decision and Risk Management certificate program
From Mapping a Managers Brain on Incentives
Social
influences
Relative
thinking
UncertaintyComplexity
By Design Intention to act consciously
bull In the interest of patients and to continually improve this ability bull To provide a healing touch ndash one life at a time in what we do and how we
do it
1292014 Ajazajazhussaincom 51
Consciously
Scientific methodology
Engineering Design
Plan-Do-Check-Act
Subconsciously
Habits (work to get rid of bad ones)
Habits (work to cultivate good one)
Keystone habits (Safety Alcoa ALCOA of data integrity)
The Power of Habit Why We Do What We Do in Life and Business Charles Duhigg (2012)
httpwwwslideshareneta2zpharmscipharmaceutical-culture-of-quality
What does it take to come out of the cGMP crisis
Persuasive demonstration of
(1) Ability to face facts
(2) Legal amp regulatory requirements
3) Systems approach to quality
4) Changing behavior amp culture
What is often missed or is unconvincing is how you will strengthen culture of quality
ldquoLet one who wants to move and convince others first be convinced and moved themselvesrdquo Thomas Carlyle
Signals that question the competence motivation andor integrity of company personnel
Do not defend the plainly indefensible it adds further serious credibility costs
3142015 Ajazajazhussaincom 52
Quality is everyones responsibility
Lack of knowledge that is
the problem
If you do not know how to ask the
right question you discover nothing
If you cant describe what you
are doing as a process you dont know what youre
doing
Rational behavior requires theory
Reactive behavior requires only reflex
action
Whenever there is fear you will get wrong figures
3142015 Ajazajazhussaincom 53
Selected quotes W Edwards Deming
3142015 Ajazajazhussaincom 54
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
ldquoWE CANNOT CHANGE THE HUMAN CONDITION BUThellipWE CAN CHANGE THE CONDITIONS UNDER WHICH HUMANS WORKrdquo JAMES REASON
Disregard to Malice
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 55
ldquohelliprecords not completed
contemporaneouslyrdquo
ldquohellipobserved analyst back-date logbooksrdquo
ldquohelliptrial injectionshelliprdquo
ldquohellipresults failing specifications are
retested until acceptable results are obtainedhelliprdquo
ldquohellipover-writing electronic raw datahelliprdquo
ldquohellipOOS not investigates per XYZ SOPrdquo
ldquohellipappropriate controls not establishedhelliprdquo
Each additional observation adds
reasons to confirm that this is very likely a system
with intentional lsquoholesrsquo in its
defenses
Preconditions
Rationalization amp Attitude
Pressure amp Incentive
Opportunity ndashlsquoholes in the QMSrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 56
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 57
Attitude towards the behavior
Subjective norm
Perceived behavioral
control
IntentionFuture
Behavior
usually found to predict behavioral intentions with a high degree of accuracy
intentions in combination with perceived behavioral control can account for a considerable proportion of variance in behavior
PastBehavior
Ajen I The theory of planned behavior ORGANIZATIONAL BEHAVIOR AND HUMAN DECISION PROCESSES 50 179-211 (1991)
Heparin tragedy 2007 and 2008
FDA reports 149 deaths with allergic or hypersensitivity symptoms during that period
bull Contaminated heparin from China
QC Testing
bull Initial testing failed to detect the contaminant
Pharmacovigilence
bull Signals in the pharmacovigilence systems responded slowly and
Eventually the severity of reactions associated made it likely that the contamination would be detected
bull too late for those who died or were injured
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 58
Congressman Shimkus When the drug safety system fails people get sick Some die
bull Some of these people are already very vulnerable and proving the cause of harm from impurities adulteration and counterfeits can be elusive
It is hard to detect harm
bull Certainly the companies are obligated to ensure a culture of quality and maintain vigilance as well This reflects a systems approach to safety
FDA inspectors look for a culture of quality at
manufacturing facilities
bull FDA policies led to the failure to inspect the Chinese plantThis system approach wasnt at
play here
bull While it doesnt deny the counterfeit source tries to say that counterfeits didnt cause the reaction as if the adulteration itself was no big deal Is this an acceptable mindset helliphelliphellip
This brings me to China and its quality culture or lack thereof
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 59
ONE HUNDRED TENTH CONGRESS SECOND SESSION APRIL 29 2008 Serial No 110-109
21 CFR PART 211 SUBPARTS -Deviations signal gaps in CoQ
bullGENERAL PROVISIONSA
bullORGANIZATION AND PERSONNELB
bullBUILDINGS AND FACILITIESC
bullEQUIPMENTD
bullCONTROL OF COMPONENTS AND DRUG PRODUCT CONTAINERS AND CLOSURESE
bullPRODUCTION AND PROCESS CONTROLSF
bullPACKAGING AND LABELING CONTROLG
bullHOLDING AND DISTRIBUTIONH
bullLABORATORY CONTROLSI
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 60
For example the combinationhellip
The Power of Habit Why We Do What We Do in Life and Business Charles Duhigg (2012)
bull Scientific methodology
bull Engineering Design
bull Plan-Do-Check-ActConsciously
bull Habits (work to get rid of bad ones)
bull Habits (work to cultivate good one)
bull Keystone habits (Safety Alcoa ALCOA of data integrity)
Subconsciously
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 61
CoQ How
bull What are the predictors of CoQCoQ Manifests by Design -
lsquoquality by designrsquo the foundation
bull 1 2 3When do people change their behaviors
bull A B C D (any body can dance)What makes a QMS effective
bull X Y ZWhen proactive compliance occurs
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 62
Going beyond rules pays
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 63
Human behavior Connecting the Dots With the Right Connectors
GXPs ndash rational behaviors
How proactive compliance is achieved X Y Z
Quality Management System
What makes a QMS reliable A B C D
Culture of Quality
Why people change their behavior 1 2 3
Human Behaviors Beyond GXPs
Predictors of Culture of Quality
Why What and How of Culture of Quality
9192014 copy Ajaz S Hussain | INSIGHT ADVICE amp SOLUTIONS LLC 64
Predictors of CoQ Act consciously in the interest of patients ndash when no one is looking
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 65
Only four attributes
actually predict a culture of
quality
Leadership Emphasis
Message Credibility
Peer Involvement
Employee Empower-ment
People will change their
behavior if they see the new behavior as
Normal
(1)
Rewarding
(2)
Easy
(3)
Dr W Edwards Demingrsquos - ldquoOut of the crisisrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 66
The journey requires leadership
with Profound Knowledge as a
guide
bull As leaders responsible for system change top management is most in need of profound knowledge
bull Quality is often determined in the boardroom
bull Problems arise when management reacts to common cause or chance variation as if it were special cause variation
bull Prediction based in theory provides a foundation for planning a course of action Plan ndash Do ndash Check ndash Act
bull The leader serves the people with clear vision and guidance to empower them To be empowered is to share ownership in the identity
bull Giving people a certain degree of control over their work fulfills the need for freedom and provides opportunity for taking joy in work
Profound Knowledge as a guide
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 67
Appreciation for a System
Theory of Knowledge
Knowledge about
Variation
Human Behavior -Psychology of Change
A
B
C
D+
Systems Approach for ErrorDeviation Management
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 68
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
Human error models and management J Reason BMJ 320 768ndash770 (2000)
D+
Culture of Error Management परबधनbull Error strain
bull Covering upFear of Errors
bull Anticipation
bull Risk takingAwareness
bull Development QbDRFT
bull Error detection Communication
bull Analyzing errors Correction
Mastery orientation
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 69
Dots amp Connections
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 70
CoQ
1
2
3
QMS
A
B
C
D
GXP Behaviors
X
Y
Z
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 71
Culture of Quality
Normal
Rewarding
Easy
QMS
System
Knowledge
Variation
Behavior
Behavior -GXPs
Fear Removed
Mastery
Awareness
EnvironmentLeadership Emphasis
Message Credibility
Peer Involvement
Employee Empowerment
Connect to CoQ
Connect to GXPs
A Framework and a Tool (for gap analysis)
Current experience with lsquoSupplier Qualificationrsquo
bull Recent observations are summarized in this report by ECA Academy (21012015) Areas of attention
bull Accuracy and completeness of administrative documentation
bull Evidence to justify excipient and supplier qualification
bull Risk-assessment and effective integration within in QMS
bull Quality agreements
bull Going forward I envision a need to emphasize a life-cycle approach (eg linking to CAPA change control)
3122015 Ajaz S Hussain PhD 17
FDArsquos Inactive Ingredient Database -statusbull Substance Registration System (SRS)
bull Generic listing vs Specific Grade listing for commonly used excipients ndashmax precedent levels
bull Listing of Mixtures
bull The UNII code confusing the National Library of Medicine yet to finalize standards for assigning UNII codes for polymers
bull Individual Grades vs Family Data
bull Legal status of the IID and FDA communications of changes to the IID
bull DMF Implications
bull Impact on ANDAs ndash lsquoDelaysrsquo amp lsquoRefuse to File Lettersrsquo
3122015 Ajaz S Hussain PhD 18
3122015 Ajaz S Hussain PhD 19
Inactive Ingredientsrsquo to lsquoExcipientsrsquo to lsquoFunctionalityrsquo Where are we in this journeylsquo
Status of lsquoSubstances In Regulatory Practicersquo
Clearly we need a global database with improved precision and accuracy of naming (and coding) to identify describe compare and link (to products and AERs)
INDs NDAs BLAs CFRrsquos Orphan Drug ApplicationsProducts that Contain Each Substance
Pharmacological ClassificationActive Moieties Related Moieties and Salts
LADMERMetabolites
Metabolic Enzymes Transporters and EffectsDrug target (therapeutic and other) type of interaction
Solubility and Permeability (BCS)Protein Binding
Impurities and Related Substance
ISO 11238 (ISO IDMP) some challenges
Both substances amp specified substances
Implementation in EU EMA Task force
Global Ingredients Archive System (GInAS)
3122015 Ajaz S Hussain PhD 20
The War Against Fake Medicines Update on FDASIA - Guidance and Impact on Excipient Suppliers and
Users QbD Sampling Guidelines The NSFIPECANSI 363 2014 GMP standardsexplained Good Supply Practices ndash Using Cross Industry Knowledge to Devise Pragmatic Solutions Impact
of Non-harmonized Standards and What is Needed to Achieve Harmonization Advancements in the Question Based Review approach and various other excipient specific related topics An Overview of the FDA OGD
IID EWG activities Effective Sourcing and Purchasing of Excipients
Industry Collaboration for Science Based Implementation of Elemental Impurities Challenges And Opportunities In Developing
And Modernizing Public Standards For NF Excipients Monographs For Regulated Drug
Products Marketed In The USA Future Pharma Manufacturing Efficiencies and the Role of Innovative Excipient Technologies
IPEC ExcipientFest 2015
Current Hot Topics ExcipientFest on 28-29 April 2015 in Washington
3122015 Ajaz S Hussain PhD 21
The War Against Fake Medicines Update on FDASIA - Guidance and Impact on Excipient
Suppliers and Users QbD Sampling Guidelines The NSFIPECANSI 363 2014 GMP standards explained Good Supply Practices ndash Using Cross Industry Knowledge to Devise
Pragmatic Solutions Impact of Non-harmonized Standards and What is Needed to Achieve
Harmonization Advancements in the Question Based Review approach and various other
excipient specific related topics An Overview of the FDA OGD IID EWG activities Effective
Sourcing and Purchasing of Excipients Industry Collaboration for Science Based Implementation of Elemental Impurities Challenges And
Opportunities In Developing And Modernizing Public Standards For NF ExcipientsMonographs For Regulated Drug Products Marketed In The USA Future Pharma Manufacturing Efficiencies and the Role of Innovative Excipient Technologies
IPEC ExcipientFest 2015
Inspectional trends in data integrity (Bangalore Nov
2014)
22(d)
192
100(a)
160(b)
110(a)
67(b)
68(a)
25(a)
67(a)
100(b)
Recurring 483 Observations Top 10
22(d) 192 100(a) 160(b)110(a) 67(b) 68(a) 25(a)67(a) 100(b)
Jeff Medwid NIPTE-FDA Conference 13 June 2012
International Society for Pharmaceutical Engineering (ISPE) in conjunction with McKinsey amp Co will release preliminary data and findings from its Quality Metrics Pilot Program at the ISPE Quality Metrics Summit on April 21ndash22 in Baltimore
FDA Launches New Drug Quality Office With Goal of Improving the Pharmaceutical IndustryPosted 13 January 2015By Alexander Gaffney RAC
FDArsquos New Pharma Quality
Office Will Take a Team Approach
Yu Explains
Regulatory Recon Investigations Find Major Quality Problems at Indian Pharma Companies (3 December 2014)Posted 03 December 2014By Alexander Gaffney RAC
Currently the environment is complex there is high uncertainty D
on
rsquot f
org
et
fun
ctio
na
lity
o
f e
xcip
ien
ts i
s im
po
rta
nt
3122015 Ajaz S Hussain PhD 22
Need for urgent progress lsquoInactive Ingredientsrsquo to lsquoExcipientsrsquo to lsquoFunctional Excipientsrsquo
Importance of assuring quality and controlling
variability of excipients
including their lsquofunctionalityrsquo has
long been recognized
bull Increasing complexity of drugs their delivery and failure modes
bull Patient (eg pediatric) relevant failure modes
bull Simple generics to complex generics amp biosimilars
Urgent need to address gaps in the FDArsquos Inactive Ingredient Database
3122015 Ajaz S Hussain PhD 23
Trends Lab amp Manufacturing
ldquoDeletion of Datardquo
ldquoTesting Into Compliancerdquo
ldquoBMR manipulation is a slippery sloperdquo
ldquoSuggestive of faulty manufacturing process or practices even if this is not the caserdquo
ldquoIt is top managementrsquos responsibility to ensure the training program is robust and effectiverdquo
Inspectional trends in data integrity (Bangalore Nov 13 2014 - Nov 14 2014)
Growing concern some
companies ldquodata looks too good
to be truerdquo
3122015 Ajaz S Hussain PhD 24
GMP Compliance amp Remediation
Jeff Medwid NIPTE-FDA Conference 13 June 2012
QbD amp QbR Clarity on Critical Functionality
FDArsquos New Pharma Quality
Office Will Take a Team
Approach Yu Explains
Carmelo Rosa MS PsyD November 2014
Urgent Need amp Opportunity
To align amp ensure sound scientific basis of these critical regulatory decisions
FDA CDER OPQ Plans for Surveillance of Pharmaceutical Quality
Teresa Mullin PhD December 2014
3122015 Ajaz S Hussain PhD 25
Need for a comprehensive (excipient) knowledge base
Teresa Mullin PhD December 2014
3122015 Ajaz S Hussain PhD 26
Why attention to (excipient) knowledge management is criticalSpecifically for physical attributes functionality performance
3122015 Ajaz S Hussain PhD 27
3122015 Ajaz S Hussain PhD 28
Today there are several product categories (eg controlled release inhalation products DPIrsquos topical transdermal liposomal products etc) which requires an exquisite control of complex physical material and product attributes (functionality)
Many of our current measurement systems need improvement
We depend on these to ensure control of lot-lot variability
Measurement system capability must be confirmed to be able to assess process capability (calibration amp Gauge RampR)
Life-cycle approach to quality continued process verification (FDArsquos Process Validation 2011) is a safety net
Supplier amp Excipient Qualification amp Process Validation
Measurement System Analysis
bull From lsquocalibrationrsquo to lsquoGauge RampRrsquoParticularly for physical
attributes destructive analysis
bull Many (including regulators) have not yet understood its importance
Gauge RampR well established but not commonly practiced
bull Measurement system in a state of control effective CAPA quality metrics Culture of Quality
With the move towards Statistical Process Control
bull Demonstrate equivalent in vitro performance more exacting criteria
Development of complex generic products (ER
Injectable Inhalation etc)
3122015 Ajaz S Hussain PhD 29
Process Validation (2011) Statistical Confidence Continued Process Verificationhellip
3122015 Ajaz S Hussain PhD 30
httpwwwslideshareneta2zpharmsciperformance-testing-pharmaceutical-quality-2004(accessed 6 December 2014)
3122015 Ajaz S Hussain PhD 31
Supplier amp Excipient Qualification amp CAPA
Out of Specification events are difficult to resolve
Excipient functionality can be a significant contributing factor
Sometimes reluctantly have to settle with - ldquoRoot cause unknown
600 days
I have inserted the ldquo600 daysrsquo on the figure ndash this is based on cases I have seen while at FDA)
3122015 Ajaz S Hussain PhD 32
Prevention of OOS and Effective CAPA needs a focus on critical functional attributes
Out of Specification events are difficult to resolve
Excipient functionality can be a significant contributing factor
Sometimes reluctantly have to settle with - ldquoRoot cause unknown
Compendial standards and manufacturing
3122015 Ajaz S Hussain PhD 33
Practice Control Process Maturity
Initial
bull Unpredictable
Managed
bull Characterized but reactive
Defined
bull Characterized proactive
Measured amp Controlled
bull In control
Optimizing
bull Focus on improvement
3122015 Ajaz S Hussain PhD 34
Capability Maturity Model Integration Carnegie Mellon University
A validated process
Maturity Level amp Assurance of Quality
Managed Characterized but reactive
High perceived risk of
lsquoCheating by Designrsquo
ldquoTrial Injectionsrdquo
ldquoTesting in to Compliancerdquo
Defined Characterized proactive
Lower level of assurance
Stopping amp Correcting
Batch Rejection
Measured amp
ControlledIn control
Quality by Design
Quality Assured
Improvement Opportunities
3122015 Ajaz S Hussain PhD 35
At the individual level in QC functionndash how often does this occur
attitude toward
performing the behavior
Process validation is
done so quality is good
test prone to error
ldquoBatch failure means I made
a mistakerdquo
subjective norm
documentation not critical
Compendial testing
sufficient
Indian regulators
collect amp test samples ndash no issue there
3122015 Ajaz S Hussain PhD 36
ldquoTesting into compliancerdquo
In general ndash low empowerment is a significant challenge (low perceived behavioral control) plus reasons to rationalizehellip
Excipient Functionality Can be critical for safety efficacy and quality
3122015 Ajaz S Hussain PhD 37
July 15 2005 FDA Public Health Advisory Safety Warnings Regarding Use of Fentanyl Transdermal (Skin) Patches
A pattern of failure Pharmaceutical Equivalence by Design (2004)
3122015 Ajaz S Hussain PhD 38
httpwwwnihsgojpdrugPhForumdocuments041122Hussain041122pdf
An attempt to correct
3122015 Ajaz S Hussain PhD 39
httpipecamericasorgsystemfilesKeyNoteEF13May11LawrenceYu(FDA)pdf
Recent challenges
3122015 Ajaz S Hussain PhD 40
Th
e V
oic
e o
f th
eA
mer
ican
P
sych
iatr
ic A
sso
ciat
ion
and
th
e P
sych
iatr
ic C
om
mu
nit
y
Physicians Question FDAs Confidence in Generic Drugs Safety Efficacy (OCTOBER 24 2014)
bull ldquomost patientsrdquo is not the same asldquo all patientsrdquo and whether the 24 to 36 normal subjects used in the agencys bioequivalency tests represents the full range of individual variation in the way drugs are absorbed across the pharmaceutical using population is uncertain
bull Individuals can sometimes be allergic and react differently to whatever substance goes into making up the capsule or the tablet
FDA Flags Generic Versions of ADHD Medication(NOVEMBER 14 2014)
bull FDA changed the therapeutic equivalence (TE) rating from AB to BXmdashmeaning that the products are still approved and can be prescribed but are no longer recommended as automatic substitutes
RLD Variability Can be a block-buster opportunityFocus on lsquocontrol strategyrsquo
bull Overcoming CP amp IP provide FDA a submission they need to address CP
bull Then begin with QTPP CQArsquos hellip skip lsquodesign spacersquo and focus on lsquocontrol strategy
bull The entire development team should read the complete package insert of RLD
bull Discuss to ensure a common understandingbull Failure modes amp intended use
bull Pharmaceutical Equivalence
bull Bioequivalence
bull Other studies
QbD Challenges
3122015 Ajaz S Hussain PhD 41
NewRegulators are not prepared to handle QbD applications
NewMisalignment of international regulatory authorities
New and Generics
RampD incentivized for lsquoshots on the goalrsquo not QbD
GenericsLack of belief in business case ndash lsquoGenerics are all about file first figure out laterrsquo
Biologics Lack of technology to execute
Ted Fuhr Mackinsey amp Company June 2010 FDA Advisory Committee
Summary
bull Excipient functionality can contribute in critical ways to product quality amp performance adequate control is necessary
bull Our databases tools and knowledge are lagging behind the rapidly increasing complexity and uncertainty
bull Risk to quality and to business is increasing and regulatory transitions pose additional difficulties
bull Effective knowledge management ndash IT and Human practices ndash is critical for organizational lsquobottom-linersquo
bull We all must come together collaboratively to address the urgent needs we owe it to the patients we serve
3122015 Ajaz S Hussain PhD 42
Knowledge Management amp Culture of Quality
Ajaz S Hussain PhD
Insight Advice amp Solutions LLCMaryland USA
Executive Director the National Institute for Pharmaceutical Technology amp Education
3122015 Ajaz S Hussain PhD 43
3122015 Ajaz S Hussain PhD 44
Life-cycle approach needed for knowledge management
Investigational ProductscGMPs
DevelopmentTechnology
TransferCommercial
ManufacturingDiscontinuation
Management Responsibility
Process Performance amp Product Quality Monitoring SystemCAPA Change Management Management Review
PQS Elements
Knowledge ManagementQuality Risk ManagementEnablers
ICH Q10 KM is a systematic approach to acquiring analyzing storing and disseminating information related to products manufacturing processes and components
Based on ICH Q10
ldquowe can be blind to the obvious and we are also blind to our blindnessrdquo
Daniel Kahneman Thinking Fast and Slow
3142015 Ajazajazhussaincom 45
httpwebmiteduperscipeopleadelsoncheckershadow_proofhtml
3122015 Ajaz S Hussain PhD 46
1938 The Federal Food Drug and Cosmetic (FDC)
bull 1937 Elixir of Sulfanilamide
1962 Kefauver-Harris Drug Amendments
bull 1962 Thalidomide
bull 1960 Color Additive Amendment
bull 1958 Food Additives Amendment GRAS
bull 1960 Color Additive Amendment
bull 1958 Food Additives Amendment GRAS
1992 Generic Drug Enforcement Act
bull1989 L-Tryptophan
bull 1989 Generic Drug Scandal
bull 1988 Food and Drug Administration Act
bull 1984 Fines Enhancement Laws Drug Price Competition and Patent Term Restoration Act
2012 Food and Drug Administration Safety and Innovation Act (FDASIA)
bull 2007 Heparin Disaster
2013 Pandemic and All-Hazards Preparedness Reauthorization Act (PAHPRA) Drug Quality and Security Act
bull 2012 The Deadly Meningitis Outbreak
Past 70 years 1937 ndash 2007 The diethylene glycol (DEG) narrative
3122015 Ajaz S Hussain PhD 47
0
5
10
15
20
25
30
35
Yea
rs
DEG Years since the previous incident
0
50
100
150
200
250
300
350
Number of Reported Deaths
1937
Eli
xir
of
Sulf
anil
amid
e
2007T
ootp
aste
conta
min
atio
n
0 70 years 0 70 years
Frequent reports
Mumbai Mumbai
Data from Excipient Fest Janeen Skutnik Chair ndashIPECAmericas 2009
Past 70+ years DEG contamination or economically motivated adulteration
3122015 Ajaz S Hussain PhD 48
Reported cases underestimate the real tragedy rapid intervention may not occur
Epidemic of Pediatric Deaths From Acute Renal Failure Caused by
Diethylene Glycol Poisoning JAMA 1998279(15)1175-1180
doi101001jama279151175
Month of hospital admission for children with
acute renal failure Haiti
October 1995-October 1996
Diethylene glycol poisoning in Gurgaon India 1998Bulletin of the World Health Organization 2001 79 88ndash95
We report a second episode of poisoning occurring in 1998 in
India as a result of children ingesting diethylene glycol at
least 33 children are known to have died
At the beginning of the investigation we never imagined that
contaminated medicine was causing acute renal failure in
children
A brand of cough expectorant manufactured by a local
pharmaceutical company was found by the Central Drugs
Laboratory Calcutta to contain 175 (vv) diethylene
glycol
The district and state drug controller had tested many
samples using thin layer chromatography before a sample of
medicine tested positive for diethylene glycol at the Central
Drugs Laboratory None of the earlier samples was found to
be contaminated
3122015 Ajaz S Hussain PhD 49
Guidance for Industry Testing of
Glycerin for Diethylene Glycol
CDER May 2007 Compliance
1 Manufacturers did not perform full
identity testing on the glycerin raw
material including tests to quantify
the amount of DEG
2 Relied on the certificate of analysis
(COA)
3 The origin of the glycerin was not
easily apparent from the COA
4 The COA was often a copy of a COA
on the letterhead of the distributor
5 The chain of custody or distribution
history of the glycerin was also not
readily known
USP Glycerin Monograph
Type of Posting Revision Bulletin
Posting Date 04ndashFebndash2009
Official Date 01ndashMayndash2009
Because of the serious hazards
associated withhellip and in response to
recommendations set forth in the
FDA Guidance for Industry Testing
of Glycerin for Diethylene Glycol
published in May 2007 USP has
revised the USP Glycerin monograph
Because diethylene glycol and
ethylene glycol are considered
unacceptable toxic substances the
testing of USP Glycerin should
demonstrate the absence of these
substances
April 2007 FDA request to
USP to revise the Glycerin
monographrsquos
IDENTIFICATION section
Revision includes adding ndash
Identification test B LIMIT OF
DIETHYLENE GLYCOL AND
ETHYLENE GLYCOL to detect
and quantify DEGEG in Glycerin
minus Is no longer part of the impurity
testing
ldquoLimit of DEG and Related
Compoundsrdquo minus Introduces a
capillary gas-chromatographic
(GC) method with flame ionization
detection (FID) minus Limit of NMT
010 each for diethylene glycol
and ethylene glycol is found
70+ years to get here how difficult will it be to change habits such as lsquoblind reliance of COArsquo
3122015 Ajaz S Hussain PhD 50
Personality and Habitual Frame Biases
Myers Brigs ENTJ (first tested at FDA)
S
TF
Expanded frame
future
possibilities
objective lsquocause
and effectrsquo
Expanded frame
future
possibilities
people and
relationships
Narrow frame
the present
individuals and
relationships
Narrow frame
the present
objective
cause and
effect
N
Based on Stanford Webinar - How to Overcome the Top 3 MegaBiases in Decision-Making
Stanford Universityrsquos Strategic Decision and Risk Management certificate program
From Mapping a Managers Brain on Incentives
Social
influences
Relative
thinking
UncertaintyComplexity
By Design Intention to act consciously
bull In the interest of patients and to continually improve this ability bull To provide a healing touch ndash one life at a time in what we do and how we
do it
1292014 Ajazajazhussaincom 51
Consciously
Scientific methodology
Engineering Design
Plan-Do-Check-Act
Subconsciously
Habits (work to get rid of bad ones)
Habits (work to cultivate good one)
Keystone habits (Safety Alcoa ALCOA of data integrity)
The Power of Habit Why We Do What We Do in Life and Business Charles Duhigg (2012)
httpwwwslideshareneta2zpharmscipharmaceutical-culture-of-quality
What does it take to come out of the cGMP crisis
Persuasive demonstration of
(1) Ability to face facts
(2) Legal amp regulatory requirements
3) Systems approach to quality
4) Changing behavior amp culture
What is often missed or is unconvincing is how you will strengthen culture of quality
ldquoLet one who wants to move and convince others first be convinced and moved themselvesrdquo Thomas Carlyle
Signals that question the competence motivation andor integrity of company personnel
Do not defend the plainly indefensible it adds further serious credibility costs
3142015 Ajazajazhussaincom 52
Quality is everyones responsibility
Lack of knowledge that is
the problem
If you do not know how to ask the
right question you discover nothing
If you cant describe what you
are doing as a process you dont know what youre
doing
Rational behavior requires theory
Reactive behavior requires only reflex
action
Whenever there is fear you will get wrong figures
3142015 Ajazajazhussaincom 53
Selected quotes W Edwards Deming
3142015 Ajazajazhussaincom 54
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
ldquoWE CANNOT CHANGE THE HUMAN CONDITION BUThellipWE CAN CHANGE THE CONDITIONS UNDER WHICH HUMANS WORKrdquo JAMES REASON
Disregard to Malice
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 55
ldquohelliprecords not completed
contemporaneouslyrdquo
ldquohellipobserved analyst back-date logbooksrdquo
ldquohelliptrial injectionshelliprdquo
ldquohellipresults failing specifications are
retested until acceptable results are obtainedhelliprdquo
ldquohellipover-writing electronic raw datahelliprdquo
ldquohellipOOS not investigates per XYZ SOPrdquo
ldquohellipappropriate controls not establishedhelliprdquo
Each additional observation adds
reasons to confirm that this is very likely a system
with intentional lsquoholesrsquo in its
defenses
Preconditions
Rationalization amp Attitude
Pressure amp Incentive
Opportunity ndashlsquoholes in the QMSrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 56
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 57
Attitude towards the behavior
Subjective norm
Perceived behavioral
control
IntentionFuture
Behavior
usually found to predict behavioral intentions with a high degree of accuracy
intentions in combination with perceived behavioral control can account for a considerable proportion of variance in behavior
PastBehavior
Ajen I The theory of planned behavior ORGANIZATIONAL BEHAVIOR AND HUMAN DECISION PROCESSES 50 179-211 (1991)
Heparin tragedy 2007 and 2008
FDA reports 149 deaths with allergic or hypersensitivity symptoms during that period
bull Contaminated heparin from China
QC Testing
bull Initial testing failed to detect the contaminant
Pharmacovigilence
bull Signals in the pharmacovigilence systems responded slowly and
Eventually the severity of reactions associated made it likely that the contamination would be detected
bull too late for those who died or were injured
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 58
Congressman Shimkus When the drug safety system fails people get sick Some die
bull Some of these people are already very vulnerable and proving the cause of harm from impurities adulteration and counterfeits can be elusive
It is hard to detect harm
bull Certainly the companies are obligated to ensure a culture of quality and maintain vigilance as well This reflects a systems approach to safety
FDA inspectors look for a culture of quality at
manufacturing facilities
bull FDA policies led to the failure to inspect the Chinese plantThis system approach wasnt at
play here
bull While it doesnt deny the counterfeit source tries to say that counterfeits didnt cause the reaction as if the adulteration itself was no big deal Is this an acceptable mindset helliphelliphellip
This brings me to China and its quality culture or lack thereof
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 59
ONE HUNDRED TENTH CONGRESS SECOND SESSION APRIL 29 2008 Serial No 110-109
21 CFR PART 211 SUBPARTS -Deviations signal gaps in CoQ
bullGENERAL PROVISIONSA
bullORGANIZATION AND PERSONNELB
bullBUILDINGS AND FACILITIESC
bullEQUIPMENTD
bullCONTROL OF COMPONENTS AND DRUG PRODUCT CONTAINERS AND CLOSURESE
bullPRODUCTION AND PROCESS CONTROLSF
bullPACKAGING AND LABELING CONTROLG
bullHOLDING AND DISTRIBUTIONH
bullLABORATORY CONTROLSI
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 60
For example the combinationhellip
The Power of Habit Why We Do What We Do in Life and Business Charles Duhigg (2012)
bull Scientific methodology
bull Engineering Design
bull Plan-Do-Check-ActConsciously
bull Habits (work to get rid of bad ones)
bull Habits (work to cultivate good one)
bull Keystone habits (Safety Alcoa ALCOA of data integrity)
Subconsciously
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 61
CoQ How
bull What are the predictors of CoQCoQ Manifests by Design -
lsquoquality by designrsquo the foundation
bull 1 2 3When do people change their behaviors
bull A B C D (any body can dance)What makes a QMS effective
bull X Y ZWhen proactive compliance occurs
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 62
Going beyond rules pays
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 63
Human behavior Connecting the Dots With the Right Connectors
GXPs ndash rational behaviors
How proactive compliance is achieved X Y Z
Quality Management System
What makes a QMS reliable A B C D
Culture of Quality
Why people change their behavior 1 2 3
Human Behaviors Beyond GXPs
Predictors of Culture of Quality
Why What and How of Culture of Quality
9192014 copy Ajaz S Hussain | INSIGHT ADVICE amp SOLUTIONS LLC 64
Predictors of CoQ Act consciously in the interest of patients ndash when no one is looking
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 65
Only four attributes
actually predict a culture of
quality
Leadership Emphasis
Message Credibility
Peer Involvement
Employee Empower-ment
People will change their
behavior if they see the new behavior as
Normal
(1)
Rewarding
(2)
Easy
(3)
Dr W Edwards Demingrsquos - ldquoOut of the crisisrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 66
The journey requires leadership
with Profound Knowledge as a
guide
bull As leaders responsible for system change top management is most in need of profound knowledge
bull Quality is often determined in the boardroom
bull Problems arise when management reacts to common cause or chance variation as if it were special cause variation
bull Prediction based in theory provides a foundation for planning a course of action Plan ndash Do ndash Check ndash Act
bull The leader serves the people with clear vision and guidance to empower them To be empowered is to share ownership in the identity
bull Giving people a certain degree of control over their work fulfills the need for freedom and provides opportunity for taking joy in work
Profound Knowledge as a guide
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 67
Appreciation for a System
Theory of Knowledge
Knowledge about
Variation
Human Behavior -Psychology of Change
A
B
C
D+
Systems Approach for ErrorDeviation Management
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 68
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
Human error models and management J Reason BMJ 320 768ndash770 (2000)
D+
Culture of Error Management परबधनbull Error strain
bull Covering upFear of Errors
bull Anticipation
bull Risk takingAwareness
bull Development QbDRFT
bull Error detection Communication
bull Analyzing errors Correction
Mastery orientation
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 69
Dots amp Connections
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 70
CoQ
1
2
3
QMS
A
B
C
D
GXP Behaviors
X
Y
Z
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 71
Culture of Quality
Normal
Rewarding
Easy
QMS
System
Knowledge
Variation
Behavior
Behavior -GXPs
Fear Removed
Mastery
Awareness
EnvironmentLeadership Emphasis
Message Credibility
Peer Involvement
Employee Empowerment
Connect to CoQ
Connect to GXPs
A Framework and a Tool (for gap analysis)
FDArsquos Inactive Ingredient Database -statusbull Substance Registration System (SRS)
bull Generic listing vs Specific Grade listing for commonly used excipients ndashmax precedent levels
bull Listing of Mixtures
bull The UNII code confusing the National Library of Medicine yet to finalize standards for assigning UNII codes for polymers
bull Individual Grades vs Family Data
bull Legal status of the IID and FDA communications of changes to the IID
bull DMF Implications
bull Impact on ANDAs ndash lsquoDelaysrsquo amp lsquoRefuse to File Lettersrsquo
3122015 Ajaz S Hussain PhD 18
3122015 Ajaz S Hussain PhD 19
Inactive Ingredientsrsquo to lsquoExcipientsrsquo to lsquoFunctionalityrsquo Where are we in this journeylsquo
Status of lsquoSubstances In Regulatory Practicersquo
Clearly we need a global database with improved precision and accuracy of naming (and coding) to identify describe compare and link (to products and AERs)
INDs NDAs BLAs CFRrsquos Orphan Drug ApplicationsProducts that Contain Each Substance
Pharmacological ClassificationActive Moieties Related Moieties and Salts
LADMERMetabolites
Metabolic Enzymes Transporters and EffectsDrug target (therapeutic and other) type of interaction
Solubility and Permeability (BCS)Protein Binding
Impurities and Related Substance
ISO 11238 (ISO IDMP) some challenges
Both substances amp specified substances
Implementation in EU EMA Task force
Global Ingredients Archive System (GInAS)
3122015 Ajaz S Hussain PhD 20
The War Against Fake Medicines Update on FDASIA - Guidance and Impact on Excipient Suppliers and
Users QbD Sampling Guidelines The NSFIPECANSI 363 2014 GMP standardsexplained Good Supply Practices ndash Using Cross Industry Knowledge to Devise Pragmatic Solutions Impact
of Non-harmonized Standards and What is Needed to Achieve Harmonization Advancements in the Question Based Review approach and various other excipient specific related topics An Overview of the FDA OGD
IID EWG activities Effective Sourcing and Purchasing of Excipients
Industry Collaboration for Science Based Implementation of Elemental Impurities Challenges And Opportunities In Developing
And Modernizing Public Standards For NF Excipients Monographs For Regulated Drug
Products Marketed In The USA Future Pharma Manufacturing Efficiencies and the Role of Innovative Excipient Technologies
IPEC ExcipientFest 2015
Current Hot Topics ExcipientFest on 28-29 April 2015 in Washington
3122015 Ajaz S Hussain PhD 21
The War Against Fake Medicines Update on FDASIA - Guidance and Impact on Excipient
Suppliers and Users QbD Sampling Guidelines The NSFIPECANSI 363 2014 GMP standards explained Good Supply Practices ndash Using Cross Industry Knowledge to Devise
Pragmatic Solutions Impact of Non-harmonized Standards and What is Needed to Achieve
Harmonization Advancements in the Question Based Review approach and various other
excipient specific related topics An Overview of the FDA OGD IID EWG activities Effective
Sourcing and Purchasing of Excipients Industry Collaboration for Science Based Implementation of Elemental Impurities Challenges And
Opportunities In Developing And Modernizing Public Standards For NF ExcipientsMonographs For Regulated Drug Products Marketed In The USA Future Pharma Manufacturing Efficiencies and the Role of Innovative Excipient Technologies
IPEC ExcipientFest 2015
Inspectional trends in data integrity (Bangalore Nov
2014)
22(d)
192
100(a)
160(b)
110(a)
67(b)
68(a)
25(a)
67(a)
100(b)
Recurring 483 Observations Top 10
22(d) 192 100(a) 160(b)110(a) 67(b) 68(a) 25(a)67(a) 100(b)
Jeff Medwid NIPTE-FDA Conference 13 June 2012
International Society for Pharmaceutical Engineering (ISPE) in conjunction with McKinsey amp Co will release preliminary data and findings from its Quality Metrics Pilot Program at the ISPE Quality Metrics Summit on April 21ndash22 in Baltimore
FDA Launches New Drug Quality Office With Goal of Improving the Pharmaceutical IndustryPosted 13 January 2015By Alexander Gaffney RAC
FDArsquos New Pharma Quality
Office Will Take a Team Approach
Yu Explains
Regulatory Recon Investigations Find Major Quality Problems at Indian Pharma Companies (3 December 2014)Posted 03 December 2014By Alexander Gaffney RAC
Currently the environment is complex there is high uncertainty D
on
rsquot f
org
et
fun
ctio
na
lity
o
f e
xcip
ien
ts i
s im
po
rta
nt
3122015 Ajaz S Hussain PhD 22
Need for urgent progress lsquoInactive Ingredientsrsquo to lsquoExcipientsrsquo to lsquoFunctional Excipientsrsquo
Importance of assuring quality and controlling
variability of excipients
including their lsquofunctionalityrsquo has
long been recognized
bull Increasing complexity of drugs their delivery and failure modes
bull Patient (eg pediatric) relevant failure modes
bull Simple generics to complex generics amp biosimilars
Urgent need to address gaps in the FDArsquos Inactive Ingredient Database
3122015 Ajaz S Hussain PhD 23
Trends Lab amp Manufacturing
ldquoDeletion of Datardquo
ldquoTesting Into Compliancerdquo
ldquoBMR manipulation is a slippery sloperdquo
ldquoSuggestive of faulty manufacturing process or practices even if this is not the caserdquo
ldquoIt is top managementrsquos responsibility to ensure the training program is robust and effectiverdquo
Inspectional trends in data integrity (Bangalore Nov 13 2014 - Nov 14 2014)
Growing concern some
companies ldquodata looks too good
to be truerdquo
3122015 Ajaz S Hussain PhD 24
GMP Compliance amp Remediation
Jeff Medwid NIPTE-FDA Conference 13 June 2012
QbD amp QbR Clarity on Critical Functionality
FDArsquos New Pharma Quality
Office Will Take a Team
Approach Yu Explains
Carmelo Rosa MS PsyD November 2014
Urgent Need amp Opportunity
To align amp ensure sound scientific basis of these critical regulatory decisions
FDA CDER OPQ Plans for Surveillance of Pharmaceutical Quality
Teresa Mullin PhD December 2014
3122015 Ajaz S Hussain PhD 25
Need for a comprehensive (excipient) knowledge base
Teresa Mullin PhD December 2014
3122015 Ajaz S Hussain PhD 26
Why attention to (excipient) knowledge management is criticalSpecifically for physical attributes functionality performance
3122015 Ajaz S Hussain PhD 27
3122015 Ajaz S Hussain PhD 28
Today there are several product categories (eg controlled release inhalation products DPIrsquos topical transdermal liposomal products etc) which requires an exquisite control of complex physical material and product attributes (functionality)
Many of our current measurement systems need improvement
We depend on these to ensure control of lot-lot variability
Measurement system capability must be confirmed to be able to assess process capability (calibration amp Gauge RampR)
Life-cycle approach to quality continued process verification (FDArsquos Process Validation 2011) is a safety net
Supplier amp Excipient Qualification amp Process Validation
Measurement System Analysis
bull From lsquocalibrationrsquo to lsquoGauge RampRrsquoParticularly for physical
attributes destructive analysis
bull Many (including regulators) have not yet understood its importance
Gauge RampR well established but not commonly practiced
bull Measurement system in a state of control effective CAPA quality metrics Culture of Quality
With the move towards Statistical Process Control
bull Demonstrate equivalent in vitro performance more exacting criteria
Development of complex generic products (ER
Injectable Inhalation etc)
3122015 Ajaz S Hussain PhD 29
Process Validation (2011) Statistical Confidence Continued Process Verificationhellip
3122015 Ajaz S Hussain PhD 30
httpwwwslideshareneta2zpharmsciperformance-testing-pharmaceutical-quality-2004(accessed 6 December 2014)
3122015 Ajaz S Hussain PhD 31
Supplier amp Excipient Qualification amp CAPA
Out of Specification events are difficult to resolve
Excipient functionality can be a significant contributing factor
Sometimes reluctantly have to settle with - ldquoRoot cause unknown
600 days
I have inserted the ldquo600 daysrsquo on the figure ndash this is based on cases I have seen while at FDA)
3122015 Ajaz S Hussain PhD 32
Prevention of OOS and Effective CAPA needs a focus on critical functional attributes
Out of Specification events are difficult to resolve
Excipient functionality can be a significant contributing factor
Sometimes reluctantly have to settle with - ldquoRoot cause unknown
Compendial standards and manufacturing
3122015 Ajaz S Hussain PhD 33
Practice Control Process Maturity
Initial
bull Unpredictable
Managed
bull Characterized but reactive
Defined
bull Characterized proactive
Measured amp Controlled
bull In control
Optimizing
bull Focus on improvement
3122015 Ajaz S Hussain PhD 34
Capability Maturity Model Integration Carnegie Mellon University
A validated process
Maturity Level amp Assurance of Quality
Managed Characterized but reactive
High perceived risk of
lsquoCheating by Designrsquo
ldquoTrial Injectionsrdquo
ldquoTesting in to Compliancerdquo
Defined Characterized proactive
Lower level of assurance
Stopping amp Correcting
Batch Rejection
Measured amp
ControlledIn control
Quality by Design
Quality Assured
Improvement Opportunities
3122015 Ajaz S Hussain PhD 35
At the individual level in QC functionndash how often does this occur
attitude toward
performing the behavior
Process validation is
done so quality is good
test prone to error
ldquoBatch failure means I made
a mistakerdquo
subjective norm
documentation not critical
Compendial testing
sufficient
Indian regulators
collect amp test samples ndash no issue there
3122015 Ajaz S Hussain PhD 36
ldquoTesting into compliancerdquo
In general ndash low empowerment is a significant challenge (low perceived behavioral control) plus reasons to rationalizehellip
Excipient Functionality Can be critical for safety efficacy and quality
3122015 Ajaz S Hussain PhD 37
July 15 2005 FDA Public Health Advisory Safety Warnings Regarding Use of Fentanyl Transdermal (Skin) Patches
A pattern of failure Pharmaceutical Equivalence by Design (2004)
3122015 Ajaz S Hussain PhD 38
httpwwwnihsgojpdrugPhForumdocuments041122Hussain041122pdf
An attempt to correct
3122015 Ajaz S Hussain PhD 39
httpipecamericasorgsystemfilesKeyNoteEF13May11LawrenceYu(FDA)pdf
Recent challenges
3122015 Ajaz S Hussain PhD 40
Th
e V
oic
e o
f th
eA
mer
ican
P
sych
iatr
ic A
sso
ciat
ion
and
th
e P
sych
iatr
ic C
om
mu
nit
y
Physicians Question FDAs Confidence in Generic Drugs Safety Efficacy (OCTOBER 24 2014)
bull ldquomost patientsrdquo is not the same asldquo all patientsrdquo and whether the 24 to 36 normal subjects used in the agencys bioequivalency tests represents the full range of individual variation in the way drugs are absorbed across the pharmaceutical using population is uncertain
bull Individuals can sometimes be allergic and react differently to whatever substance goes into making up the capsule or the tablet
FDA Flags Generic Versions of ADHD Medication(NOVEMBER 14 2014)
bull FDA changed the therapeutic equivalence (TE) rating from AB to BXmdashmeaning that the products are still approved and can be prescribed but are no longer recommended as automatic substitutes
RLD Variability Can be a block-buster opportunityFocus on lsquocontrol strategyrsquo
bull Overcoming CP amp IP provide FDA a submission they need to address CP
bull Then begin with QTPP CQArsquos hellip skip lsquodesign spacersquo and focus on lsquocontrol strategy
bull The entire development team should read the complete package insert of RLD
bull Discuss to ensure a common understandingbull Failure modes amp intended use
bull Pharmaceutical Equivalence
bull Bioequivalence
bull Other studies
QbD Challenges
3122015 Ajaz S Hussain PhD 41
NewRegulators are not prepared to handle QbD applications
NewMisalignment of international regulatory authorities
New and Generics
RampD incentivized for lsquoshots on the goalrsquo not QbD
GenericsLack of belief in business case ndash lsquoGenerics are all about file first figure out laterrsquo
Biologics Lack of technology to execute
Ted Fuhr Mackinsey amp Company June 2010 FDA Advisory Committee
Summary
bull Excipient functionality can contribute in critical ways to product quality amp performance adequate control is necessary
bull Our databases tools and knowledge are lagging behind the rapidly increasing complexity and uncertainty
bull Risk to quality and to business is increasing and regulatory transitions pose additional difficulties
bull Effective knowledge management ndash IT and Human practices ndash is critical for organizational lsquobottom-linersquo
bull We all must come together collaboratively to address the urgent needs we owe it to the patients we serve
3122015 Ajaz S Hussain PhD 42
Knowledge Management amp Culture of Quality
Ajaz S Hussain PhD
Insight Advice amp Solutions LLCMaryland USA
Executive Director the National Institute for Pharmaceutical Technology amp Education
3122015 Ajaz S Hussain PhD 43
3122015 Ajaz S Hussain PhD 44
Life-cycle approach needed for knowledge management
Investigational ProductscGMPs
DevelopmentTechnology
TransferCommercial
ManufacturingDiscontinuation
Management Responsibility
Process Performance amp Product Quality Monitoring SystemCAPA Change Management Management Review
PQS Elements
Knowledge ManagementQuality Risk ManagementEnablers
ICH Q10 KM is a systematic approach to acquiring analyzing storing and disseminating information related to products manufacturing processes and components
Based on ICH Q10
ldquowe can be blind to the obvious and we are also blind to our blindnessrdquo
Daniel Kahneman Thinking Fast and Slow
3142015 Ajazajazhussaincom 45
httpwebmiteduperscipeopleadelsoncheckershadow_proofhtml
3122015 Ajaz S Hussain PhD 46
1938 The Federal Food Drug and Cosmetic (FDC)
bull 1937 Elixir of Sulfanilamide
1962 Kefauver-Harris Drug Amendments
bull 1962 Thalidomide
bull 1960 Color Additive Amendment
bull 1958 Food Additives Amendment GRAS
bull 1960 Color Additive Amendment
bull 1958 Food Additives Amendment GRAS
1992 Generic Drug Enforcement Act
bull1989 L-Tryptophan
bull 1989 Generic Drug Scandal
bull 1988 Food and Drug Administration Act
bull 1984 Fines Enhancement Laws Drug Price Competition and Patent Term Restoration Act
2012 Food and Drug Administration Safety and Innovation Act (FDASIA)
bull 2007 Heparin Disaster
2013 Pandemic and All-Hazards Preparedness Reauthorization Act (PAHPRA) Drug Quality and Security Act
bull 2012 The Deadly Meningitis Outbreak
Past 70 years 1937 ndash 2007 The diethylene glycol (DEG) narrative
3122015 Ajaz S Hussain PhD 47
0
5
10
15
20
25
30
35
Yea
rs
DEG Years since the previous incident
0
50
100
150
200
250
300
350
Number of Reported Deaths
1937
Eli
xir
of
Sulf
anil
amid
e
2007T
ootp
aste
conta
min
atio
n
0 70 years 0 70 years
Frequent reports
Mumbai Mumbai
Data from Excipient Fest Janeen Skutnik Chair ndashIPECAmericas 2009
Past 70+ years DEG contamination or economically motivated adulteration
3122015 Ajaz S Hussain PhD 48
Reported cases underestimate the real tragedy rapid intervention may not occur
Epidemic of Pediatric Deaths From Acute Renal Failure Caused by
Diethylene Glycol Poisoning JAMA 1998279(15)1175-1180
doi101001jama279151175
Month of hospital admission for children with
acute renal failure Haiti
October 1995-October 1996
Diethylene glycol poisoning in Gurgaon India 1998Bulletin of the World Health Organization 2001 79 88ndash95
We report a second episode of poisoning occurring in 1998 in
India as a result of children ingesting diethylene glycol at
least 33 children are known to have died
At the beginning of the investigation we never imagined that
contaminated medicine was causing acute renal failure in
children
A brand of cough expectorant manufactured by a local
pharmaceutical company was found by the Central Drugs
Laboratory Calcutta to contain 175 (vv) diethylene
glycol
The district and state drug controller had tested many
samples using thin layer chromatography before a sample of
medicine tested positive for diethylene glycol at the Central
Drugs Laboratory None of the earlier samples was found to
be contaminated
3122015 Ajaz S Hussain PhD 49
Guidance for Industry Testing of
Glycerin for Diethylene Glycol
CDER May 2007 Compliance
1 Manufacturers did not perform full
identity testing on the glycerin raw
material including tests to quantify
the amount of DEG
2 Relied on the certificate of analysis
(COA)
3 The origin of the glycerin was not
easily apparent from the COA
4 The COA was often a copy of a COA
on the letterhead of the distributor
5 The chain of custody or distribution
history of the glycerin was also not
readily known
USP Glycerin Monograph
Type of Posting Revision Bulletin
Posting Date 04ndashFebndash2009
Official Date 01ndashMayndash2009
Because of the serious hazards
associated withhellip and in response to
recommendations set forth in the
FDA Guidance for Industry Testing
of Glycerin for Diethylene Glycol
published in May 2007 USP has
revised the USP Glycerin monograph
Because diethylene glycol and
ethylene glycol are considered
unacceptable toxic substances the
testing of USP Glycerin should
demonstrate the absence of these
substances
April 2007 FDA request to
USP to revise the Glycerin
monographrsquos
IDENTIFICATION section
Revision includes adding ndash
Identification test B LIMIT OF
DIETHYLENE GLYCOL AND
ETHYLENE GLYCOL to detect
and quantify DEGEG in Glycerin
minus Is no longer part of the impurity
testing
ldquoLimit of DEG and Related
Compoundsrdquo minus Introduces a
capillary gas-chromatographic
(GC) method with flame ionization
detection (FID) minus Limit of NMT
010 each for diethylene glycol
and ethylene glycol is found
70+ years to get here how difficult will it be to change habits such as lsquoblind reliance of COArsquo
3122015 Ajaz S Hussain PhD 50
Personality and Habitual Frame Biases
Myers Brigs ENTJ (first tested at FDA)
S
TF
Expanded frame
future
possibilities
objective lsquocause
and effectrsquo
Expanded frame
future
possibilities
people and
relationships
Narrow frame
the present
individuals and
relationships
Narrow frame
the present
objective
cause and
effect
N
Based on Stanford Webinar - How to Overcome the Top 3 MegaBiases in Decision-Making
Stanford Universityrsquos Strategic Decision and Risk Management certificate program
From Mapping a Managers Brain on Incentives
Social
influences
Relative
thinking
UncertaintyComplexity
By Design Intention to act consciously
bull In the interest of patients and to continually improve this ability bull To provide a healing touch ndash one life at a time in what we do and how we
do it
1292014 Ajazajazhussaincom 51
Consciously
Scientific methodology
Engineering Design
Plan-Do-Check-Act
Subconsciously
Habits (work to get rid of bad ones)
Habits (work to cultivate good one)
Keystone habits (Safety Alcoa ALCOA of data integrity)
The Power of Habit Why We Do What We Do in Life and Business Charles Duhigg (2012)
httpwwwslideshareneta2zpharmscipharmaceutical-culture-of-quality
What does it take to come out of the cGMP crisis
Persuasive demonstration of
(1) Ability to face facts
(2) Legal amp regulatory requirements
3) Systems approach to quality
4) Changing behavior amp culture
What is often missed or is unconvincing is how you will strengthen culture of quality
ldquoLet one who wants to move and convince others first be convinced and moved themselvesrdquo Thomas Carlyle
Signals that question the competence motivation andor integrity of company personnel
Do not defend the plainly indefensible it adds further serious credibility costs
3142015 Ajazajazhussaincom 52
Quality is everyones responsibility
Lack of knowledge that is
the problem
If you do not know how to ask the
right question you discover nothing
If you cant describe what you
are doing as a process you dont know what youre
doing
Rational behavior requires theory
Reactive behavior requires only reflex
action
Whenever there is fear you will get wrong figures
3142015 Ajazajazhussaincom 53
Selected quotes W Edwards Deming
3142015 Ajazajazhussaincom 54
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
ldquoWE CANNOT CHANGE THE HUMAN CONDITION BUThellipWE CAN CHANGE THE CONDITIONS UNDER WHICH HUMANS WORKrdquo JAMES REASON
Disregard to Malice
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 55
ldquohelliprecords not completed
contemporaneouslyrdquo
ldquohellipobserved analyst back-date logbooksrdquo
ldquohelliptrial injectionshelliprdquo
ldquohellipresults failing specifications are
retested until acceptable results are obtainedhelliprdquo
ldquohellipover-writing electronic raw datahelliprdquo
ldquohellipOOS not investigates per XYZ SOPrdquo
ldquohellipappropriate controls not establishedhelliprdquo
Each additional observation adds
reasons to confirm that this is very likely a system
with intentional lsquoholesrsquo in its
defenses
Preconditions
Rationalization amp Attitude
Pressure amp Incentive
Opportunity ndashlsquoholes in the QMSrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 56
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 57
Attitude towards the behavior
Subjective norm
Perceived behavioral
control
IntentionFuture
Behavior
usually found to predict behavioral intentions with a high degree of accuracy
intentions in combination with perceived behavioral control can account for a considerable proportion of variance in behavior
PastBehavior
Ajen I The theory of planned behavior ORGANIZATIONAL BEHAVIOR AND HUMAN DECISION PROCESSES 50 179-211 (1991)
Heparin tragedy 2007 and 2008
FDA reports 149 deaths with allergic or hypersensitivity symptoms during that period
bull Contaminated heparin from China
QC Testing
bull Initial testing failed to detect the contaminant
Pharmacovigilence
bull Signals in the pharmacovigilence systems responded slowly and
Eventually the severity of reactions associated made it likely that the contamination would be detected
bull too late for those who died or were injured
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 58
Congressman Shimkus When the drug safety system fails people get sick Some die
bull Some of these people are already very vulnerable and proving the cause of harm from impurities adulteration and counterfeits can be elusive
It is hard to detect harm
bull Certainly the companies are obligated to ensure a culture of quality and maintain vigilance as well This reflects a systems approach to safety
FDA inspectors look for a culture of quality at
manufacturing facilities
bull FDA policies led to the failure to inspect the Chinese plantThis system approach wasnt at
play here
bull While it doesnt deny the counterfeit source tries to say that counterfeits didnt cause the reaction as if the adulteration itself was no big deal Is this an acceptable mindset helliphelliphellip
This brings me to China and its quality culture or lack thereof
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 59
ONE HUNDRED TENTH CONGRESS SECOND SESSION APRIL 29 2008 Serial No 110-109
21 CFR PART 211 SUBPARTS -Deviations signal gaps in CoQ
bullGENERAL PROVISIONSA
bullORGANIZATION AND PERSONNELB
bullBUILDINGS AND FACILITIESC
bullEQUIPMENTD
bullCONTROL OF COMPONENTS AND DRUG PRODUCT CONTAINERS AND CLOSURESE
bullPRODUCTION AND PROCESS CONTROLSF
bullPACKAGING AND LABELING CONTROLG
bullHOLDING AND DISTRIBUTIONH
bullLABORATORY CONTROLSI
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 60
For example the combinationhellip
The Power of Habit Why We Do What We Do in Life and Business Charles Duhigg (2012)
bull Scientific methodology
bull Engineering Design
bull Plan-Do-Check-ActConsciously
bull Habits (work to get rid of bad ones)
bull Habits (work to cultivate good one)
bull Keystone habits (Safety Alcoa ALCOA of data integrity)
Subconsciously
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 61
CoQ How
bull What are the predictors of CoQCoQ Manifests by Design -
lsquoquality by designrsquo the foundation
bull 1 2 3When do people change their behaviors
bull A B C D (any body can dance)What makes a QMS effective
bull X Y ZWhen proactive compliance occurs
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 62
Going beyond rules pays
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 63
Human behavior Connecting the Dots With the Right Connectors
GXPs ndash rational behaviors
How proactive compliance is achieved X Y Z
Quality Management System
What makes a QMS reliable A B C D
Culture of Quality
Why people change their behavior 1 2 3
Human Behaviors Beyond GXPs
Predictors of Culture of Quality
Why What and How of Culture of Quality
9192014 copy Ajaz S Hussain | INSIGHT ADVICE amp SOLUTIONS LLC 64
Predictors of CoQ Act consciously in the interest of patients ndash when no one is looking
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 65
Only four attributes
actually predict a culture of
quality
Leadership Emphasis
Message Credibility
Peer Involvement
Employee Empower-ment
People will change their
behavior if they see the new behavior as
Normal
(1)
Rewarding
(2)
Easy
(3)
Dr W Edwards Demingrsquos - ldquoOut of the crisisrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 66
The journey requires leadership
with Profound Knowledge as a
guide
bull As leaders responsible for system change top management is most in need of profound knowledge
bull Quality is often determined in the boardroom
bull Problems arise when management reacts to common cause or chance variation as if it were special cause variation
bull Prediction based in theory provides a foundation for planning a course of action Plan ndash Do ndash Check ndash Act
bull The leader serves the people with clear vision and guidance to empower them To be empowered is to share ownership in the identity
bull Giving people a certain degree of control over their work fulfills the need for freedom and provides opportunity for taking joy in work
Profound Knowledge as a guide
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 67
Appreciation for a System
Theory of Knowledge
Knowledge about
Variation
Human Behavior -Psychology of Change
A
B
C
D+
Systems Approach for ErrorDeviation Management
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 68
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
Human error models and management J Reason BMJ 320 768ndash770 (2000)
D+
Culture of Error Management परबधनbull Error strain
bull Covering upFear of Errors
bull Anticipation
bull Risk takingAwareness
bull Development QbDRFT
bull Error detection Communication
bull Analyzing errors Correction
Mastery orientation
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 69
Dots amp Connections
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 70
CoQ
1
2
3
QMS
A
B
C
D
GXP Behaviors
X
Y
Z
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 71
Culture of Quality
Normal
Rewarding
Easy
QMS
System
Knowledge
Variation
Behavior
Behavior -GXPs
Fear Removed
Mastery
Awareness
EnvironmentLeadership Emphasis
Message Credibility
Peer Involvement
Employee Empowerment
Connect to CoQ
Connect to GXPs
A Framework and a Tool (for gap analysis)
3122015 Ajaz S Hussain PhD 19
Inactive Ingredientsrsquo to lsquoExcipientsrsquo to lsquoFunctionalityrsquo Where are we in this journeylsquo
Status of lsquoSubstances In Regulatory Practicersquo
Clearly we need a global database with improved precision and accuracy of naming (and coding) to identify describe compare and link (to products and AERs)
INDs NDAs BLAs CFRrsquos Orphan Drug ApplicationsProducts that Contain Each Substance
Pharmacological ClassificationActive Moieties Related Moieties and Salts
LADMERMetabolites
Metabolic Enzymes Transporters and EffectsDrug target (therapeutic and other) type of interaction
Solubility and Permeability (BCS)Protein Binding
Impurities and Related Substance
ISO 11238 (ISO IDMP) some challenges
Both substances amp specified substances
Implementation in EU EMA Task force
Global Ingredients Archive System (GInAS)
3122015 Ajaz S Hussain PhD 20
The War Against Fake Medicines Update on FDASIA - Guidance and Impact on Excipient Suppliers and
Users QbD Sampling Guidelines The NSFIPECANSI 363 2014 GMP standardsexplained Good Supply Practices ndash Using Cross Industry Knowledge to Devise Pragmatic Solutions Impact
of Non-harmonized Standards and What is Needed to Achieve Harmonization Advancements in the Question Based Review approach and various other excipient specific related topics An Overview of the FDA OGD
IID EWG activities Effective Sourcing and Purchasing of Excipients
Industry Collaboration for Science Based Implementation of Elemental Impurities Challenges And Opportunities In Developing
And Modernizing Public Standards For NF Excipients Monographs For Regulated Drug
Products Marketed In The USA Future Pharma Manufacturing Efficiencies and the Role of Innovative Excipient Technologies
IPEC ExcipientFest 2015
Current Hot Topics ExcipientFest on 28-29 April 2015 in Washington
3122015 Ajaz S Hussain PhD 21
The War Against Fake Medicines Update on FDASIA - Guidance and Impact on Excipient
Suppliers and Users QbD Sampling Guidelines The NSFIPECANSI 363 2014 GMP standards explained Good Supply Practices ndash Using Cross Industry Knowledge to Devise
Pragmatic Solutions Impact of Non-harmonized Standards and What is Needed to Achieve
Harmonization Advancements in the Question Based Review approach and various other
excipient specific related topics An Overview of the FDA OGD IID EWG activities Effective
Sourcing and Purchasing of Excipients Industry Collaboration for Science Based Implementation of Elemental Impurities Challenges And
Opportunities In Developing And Modernizing Public Standards For NF ExcipientsMonographs For Regulated Drug Products Marketed In The USA Future Pharma Manufacturing Efficiencies and the Role of Innovative Excipient Technologies
IPEC ExcipientFest 2015
Inspectional trends in data integrity (Bangalore Nov
2014)
22(d)
192
100(a)
160(b)
110(a)
67(b)
68(a)
25(a)
67(a)
100(b)
Recurring 483 Observations Top 10
22(d) 192 100(a) 160(b)110(a) 67(b) 68(a) 25(a)67(a) 100(b)
Jeff Medwid NIPTE-FDA Conference 13 June 2012
International Society for Pharmaceutical Engineering (ISPE) in conjunction with McKinsey amp Co will release preliminary data and findings from its Quality Metrics Pilot Program at the ISPE Quality Metrics Summit on April 21ndash22 in Baltimore
FDA Launches New Drug Quality Office With Goal of Improving the Pharmaceutical IndustryPosted 13 January 2015By Alexander Gaffney RAC
FDArsquos New Pharma Quality
Office Will Take a Team Approach
Yu Explains
Regulatory Recon Investigations Find Major Quality Problems at Indian Pharma Companies (3 December 2014)Posted 03 December 2014By Alexander Gaffney RAC
Currently the environment is complex there is high uncertainty D
on
rsquot f
org
et
fun
ctio
na
lity
o
f e
xcip
ien
ts i
s im
po
rta
nt
3122015 Ajaz S Hussain PhD 22
Need for urgent progress lsquoInactive Ingredientsrsquo to lsquoExcipientsrsquo to lsquoFunctional Excipientsrsquo
Importance of assuring quality and controlling
variability of excipients
including their lsquofunctionalityrsquo has
long been recognized
bull Increasing complexity of drugs their delivery and failure modes
bull Patient (eg pediatric) relevant failure modes
bull Simple generics to complex generics amp biosimilars
Urgent need to address gaps in the FDArsquos Inactive Ingredient Database
3122015 Ajaz S Hussain PhD 23
Trends Lab amp Manufacturing
ldquoDeletion of Datardquo
ldquoTesting Into Compliancerdquo
ldquoBMR manipulation is a slippery sloperdquo
ldquoSuggestive of faulty manufacturing process or practices even if this is not the caserdquo
ldquoIt is top managementrsquos responsibility to ensure the training program is robust and effectiverdquo
Inspectional trends in data integrity (Bangalore Nov 13 2014 - Nov 14 2014)
Growing concern some
companies ldquodata looks too good
to be truerdquo
3122015 Ajaz S Hussain PhD 24
GMP Compliance amp Remediation
Jeff Medwid NIPTE-FDA Conference 13 June 2012
QbD amp QbR Clarity on Critical Functionality
FDArsquos New Pharma Quality
Office Will Take a Team
Approach Yu Explains
Carmelo Rosa MS PsyD November 2014
Urgent Need amp Opportunity
To align amp ensure sound scientific basis of these critical regulatory decisions
FDA CDER OPQ Plans for Surveillance of Pharmaceutical Quality
Teresa Mullin PhD December 2014
3122015 Ajaz S Hussain PhD 25
Need for a comprehensive (excipient) knowledge base
Teresa Mullin PhD December 2014
3122015 Ajaz S Hussain PhD 26
Why attention to (excipient) knowledge management is criticalSpecifically for physical attributes functionality performance
3122015 Ajaz S Hussain PhD 27
3122015 Ajaz S Hussain PhD 28
Today there are several product categories (eg controlled release inhalation products DPIrsquos topical transdermal liposomal products etc) which requires an exquisite control of complex physical material and product attributes (functionality)
Many of our current measurement systems need improvement
We depend on these to ensure control of lot-lot variability
Measurement system capability must be confirmed to be able to assess process capability (calibration amp Gauge RampR)
Life-cycle approach to quality continued process verification (FDArsquos Process Validation 2011) is a safety net
Supplier amp Excipient Qualification amp Process Validation
Measurement System Analysis
bull From lsquocalibrationrsquo to lsquoGauge RampRrsquoParticularly for physical
attributes destructive analysis
bull Many (including regulators) have not yet understood its importance
Gauge RampR well established but not commonly practiced
bull Measurement system in a state of control effective CAPA quality metrics Culture of Quality
With the move towards Statistical Process Control
bull Demonstrate equivalent in vitro performance more exacting criteria
Development of complex generic products (ER
Injectable Inhalation etc)
3122015 Ajaz S Hussain PhD 29
Process Validation (2011) Statistical Confidence Continued Process Verificationhellip
3122015 Ajaz S Hussain PhD 30
httpwwwslideshareneta2zpharmsciperformance-testing-pharmaceutical-quality-2004(accessed 6 December 2014)
3122015 Ajaz S Hussain PhD 31
Supplier amp Excipient Qualification amp CAPA
Out of Specification events are difficult to resolve
Excipient functionality can be a significant contributing factor
Sometimes reluctantly have to settle with - ldquoRoot cause unknown
600 days
I have inserted the ldquo600 daysrsquo on the figure ndash this is based on cases I have seen while at FDA)
3122015 Ajaz S Hussain PhD 32
Prevention of OOS and Effective CAPA needs a focus on critical functional attributes
Out of Specification events are difficult to resolve
Excipient functionality can be a significant contributing factor
Sometimes reluctantly have to settle with - ldquoRoot cause unknown
Compendial standards and manufacturing
3122015 Ajaz S Hussain PhD 33
Practice Control Process Maturity
Initial
bull Unpredictable
Managed
bull Characterized but reactive
Defined
bull Characterized proactive
Measured amp Controlled
bull In control
Optimizing
bull Focus on improvement
3122015 Ajaz S Hussain PhD 34
Capability Maturity Model Integration Carnegie Mellon University
A validated process
Maturity Level amp Assurance of Quality
Managed Characterized but reactive
High perceived risk of
lsquoCheating by Designrsquo
ldquoTrial Injectionsrdquo
ldquoTesting in to Compliancerdquo
Defined Characterized proactive
Lower level of assurance
Stopping amp Correcting
Batch Rejection
Measured amp
ControlledIn control
Quality by Design
Quality Assured
Improvement Opportunities
3122015 Ajaz S Hussain PhD 35
At the individual level in QC functionndash how often does this occur
attitude toward
performing the behavior
Process validation is
done so quality is good
test prone to error
ldquoBatch failure means I made
a mistakerdquo
subjective norm
documentation not critical
Compendial testing
sufficient
Indian regulators
collect amp test samples ndash no issue there
3122015 Ajaz S Hussain PhD 36
ldquoTesting into compliancerdquo
In general ndash low empowerment is a significant challenge (low perceived behavioral control) plus reasons to rationalizehellip
Excipient Functionality Can be critical for safety efficacy and quality
3122015 Ajaz S Hussain PhD 37
July 15 2005 FDA Public Health Advisory Safety Warnings Regarding Use of Fentanyl Transdermal (Skin) Patches
A pattern of failure Pharmaceutical Equivalence by Design (2004)
3122015 Ajaz S Hussain PhD 38
httpwwwnihsgojpdrugPhForumdocuments041122Hussain041122pdf
An attempt to correct
3122015 Ajaz S Hussain PhD 39
httpipecamericasorgsystemfilesKeyNoteEF13May11LawrenceYu(FDA)pdf
Recent challenges
3122015 Ajaz S Hussain PhD 40
Th
e V
oic
e o
f th
eA
mer
ican
P
sych
iatr
ic A
sso
ciat
ion
and
th
e P
sych
iatr
ic C
om
mu
nit
y
Physicians Question FDAs Confidence in Generic Drugs Safety Efficacy (OCTOBER 24 2014)
bull ldquomost patientsrdquo is not the same asldquo all patientsrdquo and whether the 24 to 36 normal subjects used in the agencys bioequivalency tests represents the full range of individual variation in the way drugs are absorbed across the pharmaceutical using population is uncertain
bull Individuals can sometimes be allergic and react differently to whatever substance goes into making up the capsule or the tablet
FDA Flags Generic Versions of ADHD Medication(NOVEMBER 14 2014)
bull FDA changed the therapeutic equivalence (TE) rating from AB to BXmdashmeaning that the products are still approved and can be prescribed but are no longer recommended as automatic substitutes
RLD Variability Can be a block-buster opportunityFocus on lsquocontrol strategyrsquo
bull Overcoming CP amp IP provide FDA a submission they need to address CP
bull Then begin with QTPP CQArsquos hellip skip lsquodesign spacersquo and focus on lsquocontrol strategy
bull The entire development team should read the complete package insert of RLD
bull Discuss to ensure a common understandingbull Failure modes amp intended use
bull Pharmaceutical Equivalence
bull Bioequivalence
bull Other studies
QbD Challenges
3122015 Ajaz S Hussain PhD 41
NewRegulators are not prepared to handle QbD applications
NewMisalignment of international regulatory authorities
New and Generics
RampD incentivized for lsquoshots on the goalrsquo not QbD
GenericsLack of belief in business case ndash lsquoGenerics are all about file first figure out laterrsquo
Biologics Lack of technology to execute
Ted Fuhr Mackinsey amp Company June 2010 FDA Advisory Committee
Summary
bull Excipient functionality can contribute in critical ways to product quality amp performance adequate control is necessary
bull Our databases tools and knowledge are lagging behind the rapidly increasing complexity and uncertainty
bull Risk to quality and to business is increasing and regulatory transitions pose additional difficulties
bull Effective knowledge management ndash IT and Human practices ndash is critical for organizational lsquobottom-linersquo
bull We all must come together collaboratively to address the urgent needs we owe it to the patients we serve
3122015 Ajaz S Hussain PhD 42
Knowledge Management amp Culture of Quality
Ajaz S Hussain PhD
Insight Advice amp Solutions LLCMaryland USA
Executive Director the National Institute for Pharmaceutical Technology amp Education
3122015 Ajaz S Hussain PhD 43
3122015 Ajaz S Hussain PhD 44
Life-cycle approach needed for knowledge management
Investigational ProductscGMPs
DevelopmentTechnology
TransferCommercial
ManufacturingDiscontinuation
Management Responsibility
Process Performance amp Product Quality Monitoring SystemCAPA Change Management Management Review
PQS Elements
Knowledge ManagementQuality Risk ManagementEnablers
ICH Q10 KM is a systematic approach to acquiring analyzing storing and disseminating information related to products manufacturing processes and components
Based on ICH Q10
ldquowe can be blind to the obvious and we are also blind to our blindnessrdquo
Daniel Kahneman Thinking Fast and Slow
3142015 Ajazajazhussaincom 45
httpwebmiteduperscipeopleadelsoncheckershadow_proofhtml
3122015 Ajaz S Hussain PhD 46
1938 The Federal Food Drug and Cosmetic (FDC)
bull 1937 Elixir of Sulfanilamide
1962 Kefauver-Harris Drug Amendments
bull 1962 Thalidomide
bull 1960 Color Additive Amendment
bull 1958 Food Additives Amendment GRAS
bull 1960 Color Additive Amendment
bull 1958 Food Additives Amendment GRAS
1992 Generic Drug Enforcement Act
bull1989 L-Tryptophan
bull 1989 Generic Drug Scandal
bull 1988 Food and Drug Administration Act
bull 1984 Fines Enhancement Laws Drug Price Competition and Patent Term Restoration Act
2012 Food and Drug Administration Safety and Innovation Act (FDASIA)
bull 2007 Heparin Disaster
2013 Pandemic and All-Hazards Preparedness Reauthorization Act (PAHPRA) Drug Quality and Security Act
bull 2012 The Deadly Meningitis Outbreak
Past 70 years 1937 ndash 2007 The diethylene glycol (DEG) narrative
3122015 Ajaz S Hussain PhD 47
0
5
10
15
20
25
30
35
Yea
rs
DEG Years since the previous incident
0
50
100
150
200
250
300
350
Number of Reported Deaths
1937
Eli
xir
of
Sulf
anil
amid
e
2007T
ootp
aste
conta
min
atio
n
0 70 years 0 70 years
Frequent reports
Mumbai Mumbai
Data from Excipient Fest Janeen Skutnik Chair ndashIPECAmericas 2009
Past 70+ years DEG contamination or economically motivated adulteration
3122015 Ajaz S Hussain PhD 48
Reported cases underestimate the real tragedy rapid intervention may not occur
Epidemic of Pediatric Deaths From Acute Renal Failure Caused by
Diethylene Glycol Poisoning JAMA 1998279(15)1175-1180
doi101001jama279151175
Month of hospital admission for children with
acute renal failure Haiti
October 1995-October 1996
Diethylene glycol poisoning in Gurgaon India 1998Bulletin of the World Health Organization 2001 79 88ndash95
We report a second episode of poisoning occurring in 1998 in
India as a result of children ingesting diethylene glycol at
least 33 children are known to have died
At the beginning of the investigation we never imagined that
contaminated medicine was causing acute renal failure in
children
A brand of cough expectorant manufactured by a local
pharmaceutical company was found by the Central Drugs
Laboratory Calcutta to contain 175 (vv) diethylene
glycol
The district and state drug controller had tested many
samples using thin layer chromatography before a sample of
medicine tested positive for diethylene glycol at the Central
Drugs Laboratory None of the earlier samples was found to
be contaminated
3122015 Ajaz S Hussain PhD 49
Guidance for Industry Testing of
Glycerin for Diethylene Glycol
CDER May 2007 Compliance
1 Manufacturers did not perform full
identity testing on the glycerin raw
material including tests to quantify
the amount of DEG
2 Relied on the certificate of analysis
(COA)
3 The origin of the glycerin was not
easily apparent from the COA
4 The COA was often a copy of a COA
on the letterhead of the distributor
5 The chain of custody or distribution
history of the glycerin was also not
readily known
USP Glycerin Monograph
Type of Posting Revision Bulletin
Posting Date 04ndashFebndash2009
Official Date 01ndashMayndash2009
Because of the serious hazards
associated withhellip and in response to
recommendations set forth in the
FDA Guidance for Industry Testing
of Glycerin for Diethylene Glycol
published in May 2007 USP has
revised the USP Glycerin monograph
Because diethylene glycol and
ethylene glycol are considered
unacceptable toxic substances the
testing of USP Glycerin should
demonstrate the absence of these
substances
April 2007 FDA request to
USP to revise the Glycerin
monographrsquos
IDENTIFICATION section
Revision includes adding ndash
Identification test B LIMIT OF
DIETHYLENE GLYCOL AND
ETHYLENE GLYCOL to detect
and quantify DEGEG in Glycerin
minus Is no longer part of the impurity
testing
ldquoLimit of DEG and Related
Compoundsrdquo minus Introduces a
capillary gas-chromatographic
(GC) method with flame ionization
detection (FID) minus Limit of NMT
010 each for diethylene glycol
and ethylene glycol is found
70+ years to get here how difficult will it be to change habits such as lsquoblind reliance of COArsquo
3122015 Ajaz S Hussain PhD 50
Personality and Habitual Frame Biases
Myers Brigs ENTJ (first tested at FDA)
S
TF
Expanded frame
future
possibilities
objective lsquocause
and effectrsquo
Expanded frame
future
possibilities
people and
relationships
Narrow frame
the present
individuals and
relationships
Narrow frame
the present
objective
cause and
effect
N
Based on Stanford Webinar - How to Overcome the Top 3 MegaBiases in Decision-Making
Stanford Universityrsquos Strategic Decision and Risk Management certificate program
From Mapping a Managers Brain on Incentives
Social
influences
Relative
thinking
UncertaintyComplexity
By Design Intention to act consciously
bull In the interest of patients and to continually improve this ability bull To provide a healing touch ndash one life at a time in what we do and how we
do it
1292014 Ajazajazhussaincom 51
Consciously
Scientific methodology
Engineering Design
Plan-Do-Check-Act
Subconsciously
Habits (work to get rid of bad ones)
Habits (work to cultivate good one)
Keystone habits (Safety Alcoa ALCOA of data integrity)
The Power of Habit Why We Do What We Do in Life and Business Charles Duhigg (2012)
httpwwwslideshareneta2zpharmscipharmaceutical-culture-of-quality
What does it take to come out of the cGMP crisis
Persuasive demonstration of
(1) Ability to face facts
(2) Legal amp regulatory requirements
3) Systems approach to quality
4) Changing behavior amp culture
What is often missed or is unconvincing is how you will strengthen culture of quality
ldquoLet one who wants to move and convince others first be convinced and moved themselvesrdquo Thomas Carlyle
Signals that question the competence motivation andor integrity of company personnel
Do not defend the plainly indefensible it adds further serious credibility costs
3142015 Ajazajazhussaincom 52
Quality is everyones responsibility
Lack of knowledge that is
the problem
If you do not know how to ask the
right question you discover nothing
If you cant describe what you
are doing as a process you dont know what youre
doing
Rational behavior requires theory
Reactive behavior requires only reflex
action
Whenever there is fear you will get wrong figures
3142015 Ajazajazhussaincom 53
Selected quotes W Edwards Deming
3142015 Ajazajazhussaincom 54
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
ldquoWE CANNOT CHANGE THE HUMAN CONDITION BUThellipWE CAN CHANGE THE CONDITIONS UNDER WHICH HUMANS WORKrdquo JAMES REASON
Disregard to Malice
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 55
ldquohelliprecords not completed
contemporaneouslyrdquo
ldquohellipobserved analyst back-date logbooksrdquo
ldquohelliptrial injectionshelliprdquo
ldquohellipresults failing specifications are
retested until acceptable results are obtainedhelliprdquo
ldquohellipover-writing electronic raw datahelliprdquo
ldquohellipOOS not investigates per XYZ SOPrdquo
ldquohellipappropriate controls not establishedhelliprdquo
Each additional observation adds
reasons to confirm that this is very likely a system
with intentional lsquoholesrsquo in its
defenses
Preconditions
Rationalization amp Attitude
Pressure amp Incentive
Opportunity ndashlsquoholes in the QMSrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 56
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 57
Attitude towards the behavior
Subjective norm
Perceived behavioral
control
IntentionFuture
Behavior
usually found to predict behavioral intentions with a high degree of accuracy
intentions in combination with perceived behavioral control can account for a considerable proportion of variance in behavior
PastBehavior
Ajen I The theory of planned behavior ORGANIZATIONAL BEHAVIOR AND HUMAN DECISION PROCESSES 50 179-211 (1991)
Heparin tragedy 2007 and 2008
FDA reports 149 deaths with allergic or hypersensitivity symptoms during that period
bull Contaminated heparin from China
QC Testing
bull Initial testing failed to detect the contaminant
Pharmacovigilence
bull Signals in the pharmacovigilence systems responded slowly and
Eventually the severity of reactions associated made it likely that the contamination would be detected
bull too late for those who died or were injured
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 58
Congressman Shimkus When the drug safety system fails people get sick Some die
bull Some of these people are already very vulnerable and proving the cause of harm from impurities adulteration and counterfeits can be elusive
It is hard to detect harm
bull Certainly the companies are obligated to ensure a culture of quality and maintain vigilance as well This reflects a systems approach to safety
FDA inspectors look for a culture of quality at
manufacturing facilities
bull FDA policies led to the failure to inspect the Chinese plantThis system approach wasnt at
play here
bull While it doesnt deny the counterfeit source tries to say that counterfeits didnt cause the reaction as if the adulteration itself was no big deal Is this an acceptable mindset helliphelliphellip
This brings me to China and its quality culture or lack thereof
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 59
ONE HUNDRED TENTH CONGRESS SECOND SESSION APRIL 29 2008 Serial No 110-109
21 CFR PART 211 SUBPARTS -Deviations signal gaps in CoQ
bullGENERAL PROVISIONSA
bullORGANIZATION AND PERSONNELB
bullBUILDINGS AND FACILITIESC
bullEQUIPMENTD
bullCONTROL OF COMPONENTS AND DRUG PRODUCT CONTAINERS AND CLOSURESE
bullPRODUCTION AND PROCESS CONTROLSF
bullPACKAGING AND LABELING CONTROLG
bullHOLDING AND DISTRIBUTIONH
bullLABORATORY CONTROLSI
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 60
For example the combinationhellip
The Power of Habit Why We Do What We Do in Life and Business Charles Duhigg (2012)
bull Scientific methodology
bull Engineering Design
bull Plan-Do-Check-ActConsciously
bull Habits (work to get rid of bad ones)
bull Habits (work to cultivate good one)
bull Keystone habits (Safety Alcoa ALCOA of data integrity)
Subconsciously
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 61
CoQ How
bull What are the predictors of CoQCoQ Manifests by Design -
lsquoquality by designrsquo the foundation
bull 1 2 3When do people change their behaviors
bull A B C D (any body can dance)What makes a QMS effective
bull X Y ZWhen proactive compliance occurs
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 62
Going beyond rules pays
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 63
Human behavior Connecting the Dots With the Right Connectors
GXPs ndash rational behaviors
How proactive compliance is achieved X Y Z
Quality Management System
What makes a QMS reliable A B C D
Culture of Quality
Why people change their behavior 1 2 3
Human Behaviors Beyond GXPs
Predictors of Culture of Quality
Why What and How of Culture of Quality
9192014 copy Ajaz S Hussain | INSIGHT ADVICE amp SOLUTIONS LLC 64
Predictors of CoQ Act consciously in the interest of patients ndash when no one is looking
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 65
Only four attributes
actually predict a culture of
quality
Leadership Emphasis
Message Credibility
Peer Involvement
Employee Empower-ment
People will change their
behavior if they see the new behavior as
Normal
(1)
Rewarding
(2)
Easy
(3)
Dr W Edwards Demingrsquos - ldquoOut of the crisisrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 66
The journey requires leadership
with Profound Knowledge as a
guide
bull As leaders responsible for system change top management is most in need of profound knowledge
bull Quality is often determined in the boardroom
bull Problems arise when management reacts to common cause or chance variation as if it were special cause variation
bull Prediction based in theory provides a foundation for planning a course of action Plan ndash Do ndash Check ndash Act
bull The leader serves the people with clear vision and guidance to empower them To be empowered is to share ownership in the identity
bull Giving people a certain degree of control over their work fulfills the need for freedom and provides opportunity for taking joy in work
Profound Knowledge as a guide
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 67
Appreciation for a System
Theory of Knowledge
Knowledge about
Variation
Human Behavior -Psychology of Change
A
B
C
D+
Systems Approach for ErrorDeviation Management
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 68
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
Human error models and management J Reason BMJ 320 768ndash770 (2000)
D+
Culture of Error Management परबधनbull Error strain
bull Covering upFear of Errors
bull Anticipation
bull Risk takingAwareness
bull Development QbDRFT
bull Error detection Communication
bull Analyzing errors Correction
Mastery orientation
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 69
Dots amp Connections
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 70
CoQ
1
2
3
QMS
A
B
C
D
GXP Behaviors
X
Y
Z
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 71
Culture of Quality
Normal
Rewarding
Easy
QMS
System
Knowledge
Variation
Behavior
Behavior -GXPs
Fear Removed
Mastery
Awareness
EnvironmentLeadership Emphasis
Message Credibility
Peer Involvement
Employee Empowerment
Connect to CoQ
Connect to GXPs
A Framework and a Tool (for gap analysis)
3122015 Ajaz S Hussain PhD 20
The War Against Fake Medicines Update on FDASIA - Guidance and Impact on Excipient Suppliers and
Users QbD Sampling Guidelines The NSFIPECANSI 363 2014 GMP standardsexplained Good Supply Practices ndash Using Cross Industry Knowledge to Devise Pragmatic Solutions Impact
of Non-harmonized Standards and What is Needed to Achieve Harmonization Advancements in the Question Based Review approach and various other excipient specific related topics An Overview of the FDA OGD
IID EWG activities Effective Sourcing and Purchasing of Excipients
Industry Collaboration for Science Based Implementation of Elemental Impurities Challenges And Opportunities In Developing
And Modernizing Public Standards For NF Excipients Monographs For Regulated Drug
Products Marketed In The USA Future Pharma Manufacturing Efficiencies and the Role of Innovative Excipient Technologies
IPEC ExcipientFest 2015
Current Hot Topics ExcipientFest on 28-29 April 2015 in Washington
3122015 Ajaz S Hussain PhD 21
The War Against Fake Medicines Update on FDASIA - Guidance and Impact on Excipient
Suppliers and Users QbD Sampling Guidelines The NSFIPECANSI 363 2014 GMP standards explained Good Supply Practices ndash Using Cross Industry Knowledge to Devise
Pragmatic Solutions Impact of Non-harmonized Standards and What is Needed to Achieve
Harmonization Advancements in the Question Based Review approach and various other
excipient specific related topics An Overview of the FDA OGD IID EWG activities Effective
Sourcing and Purchasing of Excipients Industry Collaboration for Science Based Implementation of Elemental Impurities Challenges And
Opportunities In Developing And Modernizing Public Standards For NF ExcipientsMonographs For Regulated Drug Products Marketed In The USA Future Pharma Manufacturing Efficiencies and the Role of Innovative Excipient Technologies
IPEC ExcipientFest 2015
Inspectional trends in data integrity (Bangalore Nov
2014)
22(d)
192
100(a)
160(b)
110(a)
67(b)
68(a)
25(a)
67(a)
100(b)
Recurring 483 Observations Top 10
22(d) 192 100(a) 160(b)110(a) 67(b) 68(a) 25(a)67(a) 100(b)
Jeff Medwid NIPTE-FDA Conference 13 June 2012
International Society for Pharmaceutical Engineering (ISPE) in conjunction with McKinsey amp Co will release preliminary data and findings from its Quality Metrics Pilot Program at the ISPE Quality Metrics Summit on April 21ndash22 in Baltimore
FDA Launches New Drug Quality Office With Goal of Improving the Pharmaceutical IndustryPosted 13 January 2015By Alexander Gaffney RAC
FDArsquos New Pharma Quality
Office Will Take a Team Approach
Yu Explains
Regulatory Recon Investigations Find Major Quality Problems at Indian Pharma Companies (3 December 2014)Posted 03 December 2014By Alexander Gaffney RAC
Currently the environment is complex there is high uncertainty D
on
rsquot f
org
et
fun
ctio
na
lity
o
f e
xcip
ien
ts i
s im
po
rta
nt
3122015 Ajaz S Hussain PhD 22
Need for urgent progress lsquoInactive Ingredientsrsquo to lsquoExcipientsrsquo to lsquoFunctional Excipientsrsquo
Importance of assuring quality and controlling
variability of excipients
including their lsquofunctionalityrsquo has
long been recognized
bull Increasing complexity of drugs their delivery and failure modes
bull Patient (eg pediatric) relevant failure modes
bull Simple generics to complex generics amp biosimilars
Urgent need to address gaps in the FDArsquos Inactive Ingredient Database
3122015 Ajaz S Hussain PhD 23
Trends Lab amp Manufacturing
ldquoDeletion of Datardquo
ldquoTesting Into Compliancerdquo
ldquoBMR manipulation is a slippery sloperdquo
ldquoSuggestive of faulty manufacturing process or practices even if this is not the caserdquo
ldquoIt is top managementrsquos responsibility to ensure the training program is robust and effectiverdquo
Inspectional trends in data integrity (Bangalore Nov 13 2014 - Nov 14 2014)
Growing concern some
companies ldquodata looks too good
to be truerdquo
3122015 Ajaz S Hussain PhD 24
GMP Compliance amp Remediation
Jeff Medwid NIPTE-FDA Conference 13 June 2012
QbD amp QbR Clarity on Critical Functionality
FDArsquos New Pharma Quality
Office Will Take a Team
Approach Yu Explains
Carmelo Rosa MS PsyD November 2014
Urgent Need amp Opportunity
To align amp ensure sound scientific basis of these critical regulatory decisions
FDA CDER OPQ Plans for Surveillance of Pharmaceutical Quality
Teresa Mullin PhD December 2014
3122015 Ajaz S Hussain PhD 25
Need for a comprehensive (excipient) knowledge base
Teresa Mullin PhD December 2014
3122015 Ajaz S Hussain PhD 26
Why attention to (excipient) knowledge management is criticalSpecifically for physical attributes functionality performance
3122015 Ajaz S Hussain PhD 27
3122015 Ajaz S Hussain PhD 28
Today there are several product categories (eg controlled release inhalation products DPIrsquos topical transdermal liposomal products etc) which requires an exquisite control of complex physical material and product attributes (functionality)
Many of our current measurement systems need improvement
We depend on these to ensure control of lot-lot variability
Measurement system capability must be confirmed to be able to assess process capability (calibration amp Gauge RampR)
Life-cycle approach to quality continued process verification (FDArsquos Process Validation 2011) is a safety net
Supplier amp Excipient Qualification amp Process Validation
Measurement System Analysis
bull From lsquocalibrationrsquo to lsquoGauge RampRrsquoParticularly for physical
attributes destructive analysis
bull Many (including regulators) have not yet understood its importance
Gauge RampR well established but not commonly practiced
bull Measurement system in a state of control effective CAPA quality metrics Culture of Quality
With the move towards Statistical Process Control
bull Demonstrate equivalent in vitro performance more exacting criteria
Development of complex generic products (ER
Injectable Inhalation etc)
3122015 Ajaz S Hussain PhD 29
Process Validation (2011) Statistical Confidence Continued Process Verificationhellip
3122015 Ajaz S Hussain PhD 30
httpwwwslideshareneta2zpharmsciperformance-testing-pharmaceutical-quality-2004(accessed 6 December 2014)
3122015 Ajaz S Hussain PhD 31
Supplier amp Excipient Qualification amp CAPA
Out of Specification events are difficult to resolve
Excipient functionality can be a significant contributing factor
Sometimes reluctantly have to settle with - ldquoRoot cause unknown
600 days
I have inserted the ldquo600 daysrsquo on the figure ndash this is based on cases I have seen while at FDA)
3122015 Ajaz S Hussain PhD 32
Prevention of OOS and Effective CAPA needs a focus on critical functional attributes
Out of Specification events are difficult to resolve
Excipient functionality can be a significant contributing factor
Sometimes reluctantly have to settle with - ldquoRoot cause unknown
Compendial standards and manufacturing
3122015 Ajaz S Hussain PhD 33
Practice Control Process Maturity
Initial
bull Unpredictable
Managed
bull Characterized but reactive
Defined
bull Characterized proactive
Measured amp Controlled
bull In control
Optimizing
bull Focus on improvement
3122015 Ajaz S Hussain PhD 34
Capability Maturity Model Integration Carnegie Mellon University
A validated process
Maturity Level amp Assurance of Quality
Managed Characterized but reactive
High perceived risk of
lsquoCheating by Designrsquo
ldquoTrial Injectionsrdquo
ldquoTesting in to Compliancerdquo
Defined Characterized proactive
Lower level of assurance
Stopping amp Correcting
Batch Rejection
Measured amp
ControlledIn control
Quality by Design
Quality Assured
Improvement Opportunities
3122015 Ajaz S Hussain PhD 35
At the individual level in QC functionndash how often does this occur
attitude toward
performing the behavior
Process validation is
done so quality is good
test prone to error
ldquoBatch failure means I made
a mistakerdquo
subjective norm
documentation not critical
Compendial testing
sufficient
Indian regulators
collect amp test samples ndash no issue there
3122015 Ajaz S Hussain PhD 36
ldquoTesting into compliancerdquo
In general ndash low empowerment is a significant challenge (low perceived behavioral control) plus reasons to rationalizehellip
Excipient Functionality Can be critical for safety efficacy and quality
3122015 Ajaz S Hussain PhD 37
July 15 2005 FDA Public Health Advisory Safety Warnings Regarding Use of Fentanyl Transdermal (Skin) Patches
A pattern of failure Pharmaceutical Equivalence by Design (2004)
3122015 Ajaz S Hussain PhD 38
httpwwwnihsgojpdrugPhForumdocuments041122Hussain041122pdf
An attempt to correct
3122015 Ajaz S Hussain PhD 39
httpipecamericasorgsystemfilesKeyNoteEF13May11LawrenceYu(FDA)pdf
Recent challenges
3122015 Ajaz S Hussain PhD 40
Th
e V
oic
e o
f th
eA
mer
ican
P
sych
iatr
ic A
sso
ciat
ion
and
th
e P
sych
iatr
ic C
om
mu
nit
y
Physicians Question FDAs Confidence in Generic Drugs Safety Efficacy (OCTOBER 24 2014)
bull ldquomost patientsrdquo is not the same asldquo all patientsrdquo and whether the 24 to 36 normal subjects used in the agencys bioequivalency tests represents the full range of individual variation in the way drugs are absorbed across the pharmaceutical using population is uncertain
bull Individuals can sometimes be allergic and react differently to whatever substance goes into making up the capsule or the tablet
FDA Flags Generic Versions of ADHD Medication(NOVEMBER 14 2014)
bull FDA changed the therapeutic equivalence (TE) rating from AB to BXmdashmeaning that the products are still approved and can be prescribed but are no longer recommended as automatic substitutes
RLD Variability Can be a block-buster opportunityFocus on lsquocontrol strategyrsquo
bull Overcoming CP amp IP provide FDA a submission they need to address CP
bull Then begin with QTPP CQArsquos hellip skip lsquodesign spacersquo and focus on lsquocontrol strategy
bull The entire development team should read the complete package insert of RLD
bull Discuss to ensure a common understandingbull Failure modes amp intended use
bull Pharmaceutical Equivalence
bull Bioequivalence
bull Other studies
QbD Challenges
3122015 Ajaz S Hussain PhD 41
NewRegulators are not prepared to handle QbD applications
NewMisalignment of international regulatory authorities
New and Generics
RampD incentivized for lsquoshots on the goalrsquo not QbD
GenericsLack of belief in business case ndash lsquoGenerics are all about file first figure out laterrsquo
Biologics Lack of technology to execute
Ted Fuhr Mackinsey amp Company June 2010 FDA Advisory Committee
Summary
bull Excipient functionality can contribute in critical ways to product quality amp performance adequate control is necessary
bull Our databases tools and knowledge are lagging behind the rapidly increasing complexity and uncertainty
bull Risk to quality and to business is increasing and regulatory transitions pose additional difficulties
bull Effective knowledge management ndash IT and Human practices ndash is critical for organizational lsquobottom-linersquo
bull We all must come together collaboratively to address the urgent needs we owe it to the patients we serve
3122015 Ajaz S Hussain PhD 42
Knowledge Management amp Culture of Quality
Ajaz S Hussain PhD
Insight Advice amp Solutions LLCMaryland USA
Executive Director the National Institute for Pharmaceutical Technology amp Education
3122015 Ajaz S Hussain PhD 43
3122015 Ajaz S Hussain PhD 44
Life-cycle approach needed for knowledge management
Investigational ProductscGMPs
DevelopmentTechnology
TransferCommercial
ManufacturingDiscontinuation
Management Responsibility
Process Performance amp Product Quality Monitoring SystemCAPA Change Management Management Review
PQS Elements
Knowledge ManagementQuality Risk ManagementEnablers
ICH Q10 KM is a systematic approach to acquiring analyzing storing and disseminating information related to products manufacturing processes and components
Based on ICH Q10
ldquowe can be blind to the obvious and we are also blind to our blindnessrdquo
Daniel Kahneman Thinking Fast and Slow
3142015 Ajazajazhussaincom 45
httpwebmiteduperscipeopleadelsoncheckershadow_proofhtml
3122015 Ajaz S Hussain PhD 46
1938 The Federal Food Drug and Cosmetic (FDC)
bull 1937 Elixir of Sulfanilamide
1962 Kefauver-Harris Drug Amendments
bull 1962 Thalidomide
bull 1960 Color Additive Amendment
bull 1958 Food Additives Amendment GRAS
bull 1960 Color Additive Amendment
bull 1958 Food Additives Amendment GRAS
1992 Generic Drug Enforcement Act
bull1989 L-Tryptophan
bull 1989 Generic Drug Scandal
bull 1988 Food and Drug Administration Act
bull 1984 Fines Enhancement Laws Drug Price Competition and Patent Term Restoration Act
2012 Food and Drug Administration Safety and Innovation Act (FDASIA)
bull 2007 Heparin Disaster
2013 Pandemic and All-Hazards Preparedness Reauthorization Act (PAHPRA) Drug Quality and Security Act
bull 2012 The Deadly Meningitis Outbreak
Past 70 years 1937 ndash 2007 The diethylene glycol (DEG) narrative
3122015 Ajaz S Hussain PhD 47
0
5
10
15
20
25
30
35
Yea
rs
DEG Years since the previous incident
0
50
100
150
200
250
300
350
Number of Reported Deaths
1937
Eli
xir
of
Sulf
anil
amid
e
2007T
ootp
aste
conta
min
atio
n
0 70 years 0 70 years
Frequent reports
Mumbai Mumbai
Data from Excipient Fest Janeen Skutnik Chair ndashIPECAmericas 2009
Past 70+ years DEG contamination or economically motivated adulteration
3122015 Ajaz S Hussain PhD 48
Reported cases underestimate the real tragedy rapid intervention may not occur
Epidemic of Pediatric Deaths From Acute Renal Failure Caused by
Diethylene Glycol Poisoning JAMA 1998279(15)1175-1180
doi101001jama279151175
Month of hospital admission for children with
acute renal failure Haiti
October 1995-October 1996
Diethylene glycol poisoning in Gurgaon India 1998Bulletin of the World Health Organization 2001 79 88ndash95
We report a second episode of poisoning occurring in 1998 in
India as a result of children ingesting diethylene glycol at
least 33 children are known to have died
At the beginning of the investigation we never imagined that
contaminated medicine was causing acute renal failure in
children
A brand of cough expectorant manufactured by a local
pharmaceutical company was found by the Central Drugs
Laboratory Calcutta to contain 175 (vv) diethylene
glycol
The district and state drug controller had tested many
samples using thin layer chromatography before a sample of
medicine tested positive for diethylene glycol at the Central
Drugs Laboratory None of the earlier samples was found to
be contaminated
3122015 Ajaz S Hussain PhD 49
Guidance for Industry Testing of
Glycerin for Diethylene Glycol
CDER May 2007 Compliance
1 Manufacturers did not perform full
identity testing on the glycerin raw
material including tests to quantify
the amount of DEG
2 Relied on the certificate of analysis
(COA)
3 The origin of the glycerin was not
easily apparent from the COA
4 The COA was often a copy of a COA
on the letterhead of the distributor
5 The chain of custody or distribution
history of the glycerin was also not
readily known
USP Glycerin Monograph
Type of Posting Revision Bulletin
Posting Date 04ndashFebndash2009
Official Date 01ndashMayndash2009
Because of the serious hazards
associated withhellip and in response to
recommendations set forth in the
FDA Guidance for Industry Testing
of Glycerin for Diethylene Glycol
published in May 2007 USP has
revised the USP Glycerin monograph
Because diethylene glycol and
ethylene glycol are considered
unacceptable toxic substances the
testing of USP Glycerin should
demonstrate the absence of these
substances
April 2007 FDA request to
USP to revise the Glycerin
monographrsquos
IDENTIFICATION section
Revision includes adding ndash
Identification test B LIMIT OF
DIETHYLENE GLYCOL AND
ETHYLENE GLYCOL to detect
and quantify DEGEG in Glycerin
minus Is no longer part of the impurity
testing
ldquoLimit of DEG and Related
Compoundsrdquo minus Introduces a
capillary gas-chromatographic
(GC) method with flame ionization
detection (FID) minus Limit of NMT
010 each for diethylene glycol
and ethylene glycol is found
70+ years to get here how difficult will it be to change habits such as lsquoblind reliance of COArsquo
3122015 Ajaz S Hussain PhD 50
Personality and Habitual Frame Biases
Myers Brigs ENTJ (first tested at FDA)
S
TF
Expanded frame
future
possibilities
objective lsquocause
and effectrsquo
Expanded frame
future
possibilities
people and
relationships
Narrow frame
the present
individuals and
relationships
Narrow frame
the present
objective
cause and
effect
N
Based on Stanford Webinar - How to Overcome the Top 3 MegaBiases in Decision-Making
Stanford Universityrsquos Strategic Decision and Risk Management certificate program
From Mapping a Managers Brain on Incentives
Social
influences
Relative
thinking
UncertaintyComplexity
By Design Intention to act consciously
bull In the interest of patients and to continually improve this ability bull To provide a healing touch ndash one life at a time in what we do and how we
do it
1292014 Ajazajazhussaincom 51
Consciously
Scientific methodology
Engineering Design
Plan-Do-Check-Act
Subconsciously
Habits (work to get rid of bad ones)
Habits (work to cultivate good one)
Keystone habits (Safety Alcoa ALCOA of data integrity)
The Power of Habit Why We Do What We Do in Life and Business Charles Duhigg (2012)
httpwwwslideshareneta2zpharmscipharmaceutical-culture-of-quality
What does it take to come out of the cGMP crisis
Persuasive demonstration of
(1) Ability to face facts
(2) Legal amp regulatory requirements
3) Systems approach to quality
4) Changing behavior amp culture
What is often missed or is unconvincing is how you will strengthen culture of quality
ldquoLet one who wants to move and convince others first be convinced and moved themselvesrdquo Thomas Carlyle
Signals that question the competence motivation andor integrity of company personnel
Do not defend the plainly indefensible it adds further serious credibility costs
3142015 Ajazajazhussaincom 52
Quality is everyones responsibility
Lack of knowledge that is
the problem
If you do not know how to ask the
right question you discover nothing
If you cant describe what you
are doing as a process you dont know what youre
doing
Rational behavior requires theory
Reactive behavior requires only reflex
action
Whenever there is fear you will get wrong figures
3142015 Ajazajazhussaincom 53
Selected quotes W Edwards Deming
3142015 Ajazajazhussaincom 54
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
ldquoWE CANNOT CHANGE THE HUMAN CONDITION BUThellipWE CAN CHANGE THE CONDITIONS UNDER WHICH HUMANS WORKrdquo JAMES REASON
Disregard to Malice
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 55
ldquohelliprecords not completed
contemporaneouslyrdquo
ldquohellipobserved analyst back-date logbooksrdquo
ldquohelliptrial injectionshelliprdquo
ldquohellipresults failing specifications are
retested until acceptable results are obtainedhelliprdquo
ldquohellipover-writing electronic raw datahelliprdquo
ldquohellipOOS not investigates per XYZ SOPrdquo
ldquohellipappropriate controls not establishedhelliprdquo
Each additional observation adds
reasons to confirm that this is very likely a system
with intentional lsquoholesrsquo in its
defenses
Preconditions
Rationalization amp Attitude
Pressure amp Incentive
Opportunity ndashlsquoholes in the QMSrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 56
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 57
Attitude towards the behavior
Subjective norm
Perceived behavioral
control
IntentionFuture
Behavior
usually found to predict behavioral intentions with a high degree of accuracy
intentions in combination with perceived behavioral control can account for a considerable proportion of variance in behavior
PastBehavior
Ajen I The theory of planned behavior ORGANIZATIONAL BEHAVIOR AND HUMAN DECISION PROCESSES 50 179-211 (1991)
Heparin tragedy 2007 and 2008
FDA reports 149 deaths with allergic or hypersensitivity symptoms during that period
bull Contaminated heparin from China
QC Testing
bull Initial testing failed to detect the contaminant
Pharmacovigilence
bull Signals in the pharmacovigilence systems responded slowly and
Eventually the severity of reactions associated made it likely that the contamination would be detected
bull too late for those who died or were injured
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 58
Congressman Shimkus When the drug safety system fails people get sick Some die
bull Some of these people are already very vulnerable and proving the cause of harm from impurities adulteration and counterfeits can be elusive
It is hard to detect harm
bull Certainly the companies are obligated to ensure a culture of quality and maintain vigilance as well This reflects a systems approach to safety
FDA inspectors look for a culture of quality at
manufacturing facilities
bull FDA policies led to the failure to inspect the Chinese plantThis system approach wasnt at
play here
bull While it doesnt deny the counterfeit source tries to say that counterfeits didnt cause the reaction as if the adulteration itself was no big deal Is this an acceptable mindset helliphelliphellip
This brings me to China and its quality culture or lack thereof
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 59
ONE HUNDRED TENTH CONGRESS SECOND SESSION APRIL 29 2008 Serial No 110-109
21 CFR PART 211 SUBPARTS -Deviations signal gaps in CoQ
bullGENERAL PROVISIONSA
bullORGANIZATION AND PERSONNELB
bullBUILDINGS AND FACILITIESC
bullEQUIPMENTD
bullCONTROL OF COMPONENTS AND DRUG PRODUCT CONTAINERS AND CLOSURESE
bullPRODUCTION AND PROCESS CONTROLSF
bullPACKAGING AND LABELING CONTROLG
bullHOLDING AND DISTRIBUTIONH
bullLABORATORY CONTROLSI
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 60
For example the combinationhellip
The Power of Habit Why We Do What We Do in Life and Business Charles Duhigg (2012)
bull Scientific methodology
bull Engineering Design
bull Plan-Do-Check-ActConsciously
bull Habits (work to get rid of bad ones)
bull Habits (work to cultivate good one)
bull Keystone habits (Safety Alcoa ALCOA of data integrity)
Subconsciously
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 61
CoQ How
bull What are the predictors of CoQCoQ Manifests by Design -
lsquoquality by designrsquo the foundation
bull 1 2 3When do people change their behaviors
bull A B C D (any body can dance)What makes a QMS effective
bull X Y ZWhen proactive compliance occurs
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 62
Going beyond rules pays
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 63
Human behavior Connecting the Dots With the Right Connectors
GXPs ndash rational behaviors
How proactive compliance is achieved X Y Z
Quality Management System
What makes a QMS reliable A B C D
Culture of Quality
Why people change their behavior 1 2 3
Human Behaviors Beyond GXPs
Predictors of Culture of Quality
Why What and How of Culture of Quality
9192014 copy Ajaz S Hussain | INSIGHT ADVICE amp SOLUTIONS LLC 64
Predictors of CoQ Act consciously in the interest of patients ndash when no one is looking
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 65
Only four attributes
actually predict a culture of
quality
Leadership Emphasis
Message Credibility
Peer Involvement
Employee Empower-ment
People will change their
behavior if they see the new behavior as
Normal
(1)
Rewarding
(2)
Easy
(3)
Dr W Edwards Demingrsquos - ldquoOut of the crisisrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 66
The journey requires leadership
with Profound Knowledge as a
guide
bull As leaders responsible for system change top management is most in need of profound knowledge
bull Quality is often determined in the boardroom
bull Problems arise when management reacts to common cause or chance variation as if it were special cause variation
bull Prediction based in theory provides a foundation for planning a course of action Plan ndash Do ndash Check ndash Act
bull The leader serves the people with clear vision and guidance to empower them To be empowered is to share ownership in the identity
bull Giving people a certain degree of control over their work fulfills the need for freedom and provides opportunity for taking joy in work
Profound Knowledge as a guide
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 67
Appreciation for a System
Theory of Knowledge
Knowledge about
Variation
Human Behavior -Psychology of Change
A
B
C
D+
Systems Approach for ErrorDeviation Management
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 68
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
Human error models and management J Reason BMJ 320 768ndash770 (2000)
D+
Culture of Error Management परबधनbull Error strain
bull Covering upFear of Errors
bull Anticipation
bull Risk takingAwareness
bull Development QbDRFT
bull Error detection Communication
bull Analyzing errors Correction
Mastery orientation
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 69
Dots amp Connections
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 70
CoQ
1
2
3
QMS
A
B
C
D
GXP Behaviors
X
Y
Z
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 71
Culture of Quality
Normal
Rewarding
Easy
QMS
System
Knowledge
Variation
Behavior
Behavior -GXPs
Fear Removed
Mastery
Awareness
EnvironmentLeadership Emphasis
Message Credibility
Peer Involvement
Employee Empowerment
Connect to CoQ
Connect to GXPs
A Framework and a Tool (for gap analysis)
3122015 Ajaz S Hussain PhD 21
The War Against Fake Medicines Update on FDASIA - Guidance and Impact on Excipient
Suppliers and Users QbD Sampling Guidelines The NSFIPECANSI 363 2014 GMP standards explained Good Supply Practices ndash Using Cross Industry Knowledge to Devise
Pragmatic Solutions Impact of Non-harmonized Standards and What is Needed to Achieve
Harmonization Advancements in the Question Based Review approach and various other
excipient specific related topics An Overview of the FDA OGD IID EWG activities Effective
Sourcing and Purchasing of Excipients Industry Collaboration for Science Based Implementation of Elemental Impurities Challenges And
Opportunities In Developing And Modernizing Public Standards For NF ExcipientsMonographs For Regulated Drug Products Marketed In The USA Future Pharma Manufacturing Efficiencies and the Role of Innovative Excipient Technologies
IPEC ExcipientFest 2015
Inspectional trends in data integrity (Bangalore Nov
2014)
22(d)
192
100(a)
160(b)
110(a)
67(b)
68(a)
25(a)
67(a)
100(b)
Recurring 483 Observations Top 10
22(d) 192 100(a) 160(b)110(a) 67(b) 68(a) 25(a)67(a) 100(b)
Jeff Medwid NIPTE-FDA Conference 13 June 2012
International Society for Pharmaceutical Engineering (ISPE) in conjunction with McKinsey amp Co will release preliminary data and findings from its Quality Metrics Pilot Program at the ISPE Quality Metrics Summit on April 21ndash22 in Baltimore
FDA Launches New Drug Quality Office With Goal of Improving the Pharmaceutical IndustryPosted 13 January 2015By Alexander Gaffney RAC
FDArsquos New Pharma Quality
Office Will Take a Team Approach
Yu Explains
Regulatory Recon Investigations Find Major Quality Problems at Indian Pharma Companies (3 December 2014)Posted 03 December 2014By Alexander Gaffney RAC
Currently the environment is complex there is high uncertainty D
on
rsquot f
org
et
fun
ctio
na
lity
o
f e
xcip
ien
ts i
s im
po
rta
nt
3122015 Ajaz S Hussain PhD 22
Need for urgent progress lsquoInactive Ingredientsrsquo to lsquoExcipientsrsquo to lsquoFunctional Excipientsrsquo
Importance of assuring quality and controlling
variability of excipients
including their lsquofunctionalityrsquo has
long been recognized
bull Increasing complexity of drugs their delivery and failure modes
bull Patient (eg pediatric) relevant failure modes
bull Simple generics to complex generics amp biosimilars
Urgent need to address gaps in the FDArsquos Inactive Ingredient Database
3122015 Ajaz S Hussain PhD 23
Trends Lab amp Manufacturing
ldquoDeletion of Datardquo
ldquoTesting Into Compliancerdquo
ldquoBMR manipulation is a slippery sloperdquo
ldquoSuggestive of faulty manufacturing process or practices even if this is not the caserdquo
ldquoIt is top managementrsquos responsibility to ensure the training program is robust and effectiverdquo
Inspectional trends in data integrity (Bangalore Nov 13 2014 - Nov 14 2014)
Growing concern some
companies ldquodata looks too good
to be truerdquo
3122015 Ajaz S Hussain PhD 24
GMP Compliance amp Remediation
Jeff Medwid NIPTE-FDA Conference 13 June 2012
QbD amp QbR Clarity on Critical Functionality
FDArsquos New Pharma Quality
Office Will Take a Team
Approach Yu Explains
Carmelo Rosa MS PsyD November 2014
Urgent Need amp Opportunity
To align amp ensure sound scientific basis of these critical regulatory decisions
FDA CDER OPQ Plans for Surveillance of Pharmaceutical Quality
Teresa Mullin PhD December 2014
3122015 Ajaz S Hussain PhD 25
Need for a comprehensive (excipient) knowledge base
Teresa Mullin PhD December 2014
3122015 Ajaz S Hussain PhD 26
Why attention to (excipient) knowledge management is criticalSpecifically for physical attributes functionality performance
3122015 Ajaz S Hussain PhD 27
3122015 Ajaz S Hussain PhD 28
Today there are several product categories (eg controlled release inhalation products DPIrsquos topical transdermal liposomal products etc) which requires an exquisite control of complex physical material and product attributes (functionality)
Many of our current measurement systems need improvement
We depend on these to ensure control of lot-lot variability
Measurement system capability must be confirmed to be able to assess process capability (calibration amp Gauge RampR)
Life-cycle approach to quality continued process verification (FDArsquos Process Validation 2011) is a safety net
Supplier amp Excipient Qualification amp Process Validation
Measurement System Analysis
bull From lsquocalibrationrsquo to lsquoGauge RampRrsquoParticularly for physical
attributes destructive analysis
bull Many (including regulators) have not yet understood its importance
Gauge RampR well established but not commonly practiced
bull Measurement system in a state of control effective CAPA quality metrics Culture of Quality
With the move towards Statistical Process Control
bull Demonstrate equivalent in vitro performance more exacting criteria
Development of complex generic products (ER
Injectable Inhalation etc)
3122015 Ajaz S Hussain PhD 29
Process Validation (2011) Statistical Confidence Continued Process Verificationhellip
3122015 Ajaz S Hussain PhD 30
httpwwwslideshareneta2zpharmsciperformance-testing-pharmaceutical-quality-2004(accessed 6 December 2014)
3122015 Ajaz S Hussain PhD 31
Supplier amp Excipient Qualification amp CAPA
Out of Specification events are difficult to resolve
Excipient functionality can be a significant contributing factor
Sometimes reluctantly have to settle with - ldquoRoot cause unknown
600 days
I have inserted the ldquo600 daysrsquo on the figure ndash this is based on cases I have seen while at FDA)
3122015 Ajaz S Hussain PhD 32
Prevention of OOS and Effective CAPA needs a focus on critical functional attributes
Out of Specification events are difficult to resolve
Excipient functionality can be a significant contributing factor
Sometimes reluctantly have to settle with - ldquoRoot cause unknown
Compendial standards and manufacturing
3122015 Ajaz S Hussain PhD 33
Practice Control Process Maturity
Initial
bull Unpredictable
Managed
bull Characterized but reactive
Defined
bull Characterized proactive
Measured amp Controlled
bull In control
Optimizing
bull Focus on improvement
3122015 Ajaz S Hussain PhD 34
Capability Maturity Model Integration Carnegie Mellon University
A validated process
Maturity Level amp Assurance of Quality
Managed Characterized but reactive
High perceived risk of
lsquoCheating by Designrsquo
ldquoTrial Injectionsrdquo
ldquoTesting in to Compliancerdquo
Defined Characterized proactive
Lower level of assurance
Stopping amp Correcting
Batch Rejection
Measured amp
ControlledIn control
Quality by Design
Quality Assured
Improvement Opportunities
3122015 Ajaz S Hussain PhD 35
At the individual level in QC functionndash how often does this occur
attitude toward
performing the behavior
Process validation is
done so quality is good
test prone to error
ldquoBatch failure means I made
a mistakerdquo
subjective norm
documentation not critical
Compendial testing
sufficient
Indian regulators
collect amp test samples ndash no issue there
3122015 Ajaz S Hussain PhD 36
ldquoTesting into compliancerdquo
In general ndash low empowerment is a significant challenge (low perceived behavioral control) plus reasons to rationalizehellip
Excipient Functionality Can be critical for safety efficacy and quality
3122015 Ajaz S Hussain PhD 37
July 15 2005 FDA Public Health Advisory Safety Warnings Regarding Use of Fentanyl Transdermal (Skin) Patches
A pattern of failure Pharmaceutical Equivalence by Design (2004)
3122015 Ajaz S Hussain PhD 38
httpwwwnihsgojpdrugPhForumdocuments041122Hussain041122pdf
An attempt to correct
3122015 Ajaz S Hussain PhD 39
httpipecamericasorgsystemfilesKeyNoteEF13May11LawrenceYu(FDA)pdf
Recent challenges
3122015 Ajaz S Hussain PhD 40
Th
e V
oic
e o
f th
eA
mer
ican
P
sych
iatr
ic A
sso
ciat
ion
and
th
e P
sych
iatr
ic C
om
mu
nit
y
Physicians Question FDAs Confidence in Generic Drugs Safety Efficacy (OCTOBER 24 2014)
bull ldquomost patientsrdquo is not the same asldquo all patientsrdquo and whether the 24 to 36 normal subjects used in the agencys bioequivalency tests represents the full range of individual variation in the way drugs are absorbed across the pharmaceutical using population is uncertain
bull Individuals can sometimes be allergic and react differently to whatever substance goes into making up the capsule or the tablet
FDA Flags Generic Versions of ADHD Medication(NOVEMBER 14 2014)
bull FDA changed the therapeutic equivalence (TE) rating from AB to BXmdashmeaning that the products are still approved and can be prescribed but are no longer recommended as automatic substitutes
RLD Variability Can be a block-buster opportunityFocus on lsquocontrol strategyrsquo
bull Overcoming CP amp IP provide FDA a submission they need to address CP
bull Then begin with QTPP CQArsquos hellip skip lsquodesign spacersquo and focus on lsquocontrol strategy
bull The entire development team should read the complete package insert of RLD
bull Discuss to ensure a common understandingbull Failure modes amp intended use
bull Pharmaceutical Equivalence
bull Bioequivalence
bull Other studies
QbD Challenges
3122015 Ajaz S Hussain PhD 41
NewRegulators are not prepared to handle QbD applications
NewMisalignment of international regulatory authorities
New and Generics
RampD incentivized for lsquoshots on the goalrsquo not QbD
GenericsLack of belief in business case ndash lsquoGenerics are all about file first figure out laterrsquo
Biologics Lack of technology to execute
Ted Fuhr Mackinsey amp Company June 2010 FDA Advisory Committee
Summary
bull Excipient functionality can contribute in critical ways to product quality amp performance adequate control is necessary
bull Our databases tools and knowledge are lagging behind the rapidly increasing complexity and uncertainty
bull Risk to quality and to business is increasing and regulatory transitions pose additional difficulties
bull Effective knowledge management ndash IT and Human practices ndash is critical for organizational lsquobottom-linersquo
bull We all must come together collaboratively to address the urgent needs we owe it to the patients we serve
3122015 Ajaz S Hussain PhD 42
Knowledge Management amp Culture of Quality
Ajaz S Hussain PhD
Insight Advice amp Solutions LLCMaryland USA
Executive Director the National Institute for Pharmaceutical Technology amp Education
3122015 Ajaz S Hussain PhD 43
3122015 Ajaz S Hussain PhD 44
Life-cycle approach needed for knowledge management
Investigational ProductscGMPs
DevelopmentTechnology
TransferCommercial
ManufacturingDiscontinuation
Management Responsibility
Process Performance amp Product Quality Monitoring SystemCAPA Change Management Management Review
PQS Elements
Knowledge ManagementQuality Risk ManagementEnablers
ICH Q10 KM is a systematic approach to acquiring analyzing storing and disseminating information related to products manufacturing processes and components
Based on ICH Q10
ldquowe can be blind to the obvious and we are also blind to our blindnessrdquo
Daniel Kahneman Thinking Fast and Slow
3142015 Ajazajazhussaincom 45
httpwebmiteduperscipeopleadelsoncheckershadow_proofhtml
3122015 Ajaz S Hussain PhD 46
1938 The Federal Food Drug and Cosmetic (FDC)
bull 1937 Elixir of Sulfanilamide
1962 Kefauver-Harris Drug Amendments
bull 1962 Thalidomide
bull 1960 Color Additive Amendment
bull 1958 Food Additives Amendment GRAS
bull 1960 Color Additive Amendment
bull 1958 Food Additives Amendment GRAS
1992 Generic Drug Enforcement Act
bull1989 L-Tryptophan
bull 1989 Generic Drug Scandal
bull 1988 Food and Drug Administration Act
bull 1984 Fines Enhancement Laws Drug Price Competition and Patent Term Restoration Act
2012 Food and Drug Administration Safety and Innovation Act (FDASIA)
bull 2007 Heparin Disaster
2013 Pandemic and All-Hazards Preparedness Reauthorization Act (PAHPRA) Drug Quality and Security Act
bull 2012 The Deadly Meningitis Outbreak
Past 70 years 1937 ndash 2007 The diethylene glycol (DEG) narrative
3122015 Ajaz S Hussain PhD 47
0
5
10
15
20
25
30
35
Yea
rs
DEG Years since the previous incident
0
50
100
150
200
250
300
350
Number of Reported Deaths
1937
Eli
xir
of
Sulf
anil
amid
e
2007T
ootp
aste
conta
min
atio
n
0 70 years 0 70 years
Frequent reports
Mumbai Mumbai
Data from Excipient Fest Janeen Skutnik Chair ndashIPECAmericas 2009
Past 70+ years DEG contamination or economically motivated adulteration
3122015 Ajaz S Hussain PhD 48
Reported cases underestimate the real tragedy rapid intervention may not occur
Epidemic of Pediatric Deaths From Acute Renal Failure Caused by
Diethylene Glycol Poisoning JAMA 1998279(15)1175-1180
doi101001jama279151175
Month of hospital admission for children with
acute renal failure Haiti
October 1995-October 1996
Diethylene glycol poisoning in Gurgaon India 1998Bulletin of the World Health Organization 2001 79 88ndash95
We report a second episode of poisoning occurring in 1998 in
India as a result of children ingesting diethylene glycol at
least 33 children are known to have died
At the beginning of the investigation we never imagined that
contaminated medicine was causing acute renal failure in
children
A brand of cough expectorant manufactured by a local
pharmaceutical company was found by the Central Drugs
Laboratory Calcutta to contain 175 (vv) diethylene
glycol
The district and state drug controller had tested many
samples using thin layer chromatography before a sample of
medicine tested positive for diethylene glycol at the Central
Drugs Laboratory None of the earlier samples was found to
be contaminated
3122015 Ajaz S Hussain PhD 49
Guidance for Industry Testing of
Glycerin for Diethylene Glycol
CDER May 2007 Compliance
1 Manufacturers did not perform full
identity testing on the glycerin raw
material including tests to quantify
the amount of DEG
2 Relied on the certificate of analysis
(COA)
3 The origin of the glycerin was not
easily apparent from the COA
4 The COA was often a copy of a COA
on the letterhead of the distributor
5 The chain of custody or distribution
history of the glycerin was also not
readily known
USP Glycerin Monograph
Type of Posting Revision Bulletin
Posting Date 04ndashFebndash2009
Official Date 01ndashMayndash2009
Because of the serious hazards
associated withhellip and in response to
recommendations set forth in the
FDA Guidance for Industry Testing
of Glycerin for Diethylene Glycol
published in May 2007 USP has
revised the USP Glycerin monograph
Because diethylene glycol and
ethylene glycol are considered
unacceptable toxic substances the
testing of USP Glycerin should
demonstrate the absence of these
substances
April 2007 FDA request to
USP to revise the Glycerin
monographrsquos
IDENTIFICATION section
Revision includes adding ndash
Identification test B LIMIT OF
DIETHYLENE GLYCOL AND
ETHYLENE GLYCOL to detect
and quantify DEGEG in Glycerin
minus Is no longer part of the impurity
testing
ldquoLimit of DEG and Related
Compoundsrdquo minus Introduces a
capillary gas-chromatographic
(GC) method with flame ionization
detection (FID) minus Limit of NMT
010 each for diethylene glycol
and ethylene glycol is found
70+ years to get here how difficult will it be to change habits such as lsquoblind reliance of COArsquo
3122015 Ajaz S Hussain PhD 50
Personality and Habitual Frame Biases
Myers Brigs ENTJ (first tested at FDA)
S
TF
Expanded frame
future
possibilities
objective lsquocause
and effectrsquo
Expanded frame
future
possibilities
people and
relationships
Narrow frame
the present
individuals and
relationships
Narrow frame
the present
objective
cause and
effect
N
Based on Stanford Webinar - How to Overcome the Top 3 MegaBiases in Decision-Making
Stanford Universityrsquos Strategic Decision and Risk Management certificate program
From Mapping a Managers Brain on Incentives
Social
influences
Relative
thinking
UncertaintyComplexity
By Design Intention to act consciously
bull In the interest of patients and to continually improve this ability bull To provide a healing touch ndash one life at a time in what we do and how we
do it
1292014 Ajazajazhussaincom 51
Consciously
Scientific methodology
Engineering Design
Plan-Do-Check-Act
Subconsciously
Habits (work to get rid of bad ones)
Habits (work to cultivate good one)
Keystone habits (Safety Alcoa ALCOA of data integrity)
The Power of Habit Why We Do What We Do in Life and Business Charles Duhigg (2012)
httpwwwslideshareneta2zpharmscipharmaceutical-culture-of-quality
What does it take to come out of the cGMP crisis
Persuasive demonstration of
(1) Ability to face facts
(2) Legal amp regulatory requirements
3) Systems approach to quality
4) Changing behavior amp culture
What is often missed or is unconvincing is how you will strengthen culture of quality
ldquoLet one who wants to move and convince others first be convinced and moved themselvesrdquo Thomas Carlyle
Signals that question the competence motivation andor integrity of company personnel
Do not defend the plainly indefensible it adds further serious credibility costs
3142015 Ajazajazhussaincom 52
Quality is everyones responsibility
Lack of knowledge that is
the problem
If you do not know how to ask the
right question you discover nothing
If you cant describe what you
are doing as a process you dont know what youre
doing
Rational behavior requires theory
Reactive behavior requires only reflex
action
Whenever there is fear you will get wrong figures
3142015 Ajazajazhussaincom 53
Selected quotes W Edwards Deming
3142015 Ajazajazhussaincom 54
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
ldquoWE CANNOT CHANGE THE HUMAN CONDITION BUThellipWE CAN CHANGE THE CONDITIONS UNDER WHICH HUMANS WORKrdquo JAMES REASON
Disregard to Malice
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 55
ldquohelliprecords not completed
contemporaneouslyrdquo
ldquohellipobserved analyst back-date logbooksrdquo
ldquohelliptrial injectionshelliprdquo
ldquohellipresults failing specifications are
retested until acceptable results are obtainedhelliprdquo
ldquohellipover-writing electronic raw datahelliprdquo
ldquohellipOOS not investigates per XYZ SOPrdquo
ldquohellipappropriate controls not establishedhelliprdquo
Each additional observation adds
reasons to confirm that this is very likely a system
with intentional lsquoholesrsquo in its
defenses
Preconditions
Rationalization amp Attitude
Pressure amp Incentive
Opportunity ndashlsquoholes in the QMSrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 56
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 57
Attitude towards the behavior
Subjective norm
Perceived behavioral
control
IntentionFuture
Behavior
usually found to predict behavioral intentions with a high degree of accuracy
intentions in combination with perceived behavioral control can account for a considerable proportion of variance in behavior
PastBehavior
Ajen I The theory of planned behavior ORGANIZATIONAL BEHAVIOR AND HUMAN DECISION PROCESSES 50 179-211 (1991)
Heparin tragedy 2007 and 2008
FDA reports 149 deaths with allergic or hypersensitivity symptoms during that period
bull Contaminated heparin from China
QC Testing
bull Initial testing failed to detect the contaminant
Pharmacovigilence
bull Signals in the pharmacovigilence systems responded slowly and
Eventually the severity of reactions associated made it likely that the contamination would be detected
bull too late for those who died or were injured
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 58
Congressman Shimkus When the drug safety system fails people get sick Some die
bull Some of these people are already very vulnerable and proving the cause of harm from impurities adulteration and counterfeits can be elusive
It is hard to detect harm
bull Certainly the companies are obligated to ensure a culture of quality and maintain vigilance as well This reflects a systems approach to safety
FDA inspectors look for a culture of quality at
manufacturing facilities
bull FDA policies led to the failure to inspect the Chinese plantThis system approach wasnt at
play here
bull While it doesnt deny the counterfeit source tries to say that counterfeits didnt cause the reaction as if the adulteration itself was no big deal Is this an acceptable mindset helliphelliphellip
This brings me to China and its quality culture or lack thereof
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 59
ONE HUNDRED TENTH CONGRESS SECOND SESSION APRIL 29 2008 Serial No 110-109
21 CFR PART 211 SUBPARTS -Deviations signal gaps in CoQ
bullGENERAL PROVISIONSA
bullORGANIZATION AND PERSONNELB
bullBUILDINGS AND FACILITIESC
bullEQUIPMENTD
bullCONTROL OF COMPONENTS AND DRUG PRODUCT CONTAINERS AND CLOSURESE
bullPRODUCTION AND PROCESS CONTROLSF
bullPACKAGING AND LABELING CONTROLG
bullHOLDING AND DISTRIBUTIONH
bullLABORATORY CONTROLSI
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 60
For example the combinationhellip
The Power of Habit Why We Do What We Do in Life and Business Charles Duhigg (2012)
bull Scientific methodology
bull Engineering Design
bull Plan-Do-Check-ActConsciously
bull Habits (work to get rid of bad ones)
bull Habits (work to cultivate good one)
bull Keystone habits (Safety Alcoa ALCOA of data integrity)
Subconsciously
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 61
CoQ How
bull What are the predictors of CoQCoQ Manifests by Design -
lsquoquality by designrsquo the foundation
bull 1 2 3When do people change their behaviors
bull A B C D (any body can dance)What makes a QMS effective
bull X Y ZWhen proactive compliance occurs
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 62
Going beyond rules pays
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 63
Human behavior Connecting the Dots With the Right Connectors
GXPs ndash rational behaviors
How proactive compliance is achieved X Y Z
Quality Management System
What makes a QMS reliable A B C D
Culture of Quality
Why people change their behavior 1 2 3
Human Behaviors Beyond GXPs
Predictors of Culture of Quality
Why What and How of Culture of Quality
9192014 copy Ajaz S Hussain | INSIGHT ADVICE amp SOLUTIONS LLC 64
Predictors of CoQ Act consciously in the interest of patients ndash when no one is looking
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 65
Only four attributes
actually predict a culture of
quality
Leadership Emphasis
Message Credibility
Peer Involvement
Employee Empower-ment
People will change their
behavior if they see the new behavior as
Normal
(1)
Rewarding
(2)
Easy
(3)
Dr W Edwards Demingrsquos - ldquoOut of the crisisrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 66
The journey requires leadership
with Profound Knowledge as a
guide
bull As leaders responsible for system change top management is most in need of profound knowledge
bull Quality is often determined in the boardroom
bull Problems arise when management reacts to common cause or chance variation as if it were special cause variation
bull Prediction based in theory provides a foundation for planning a course of action Plan ndash Do ndash Check ndash Act
bull The leader serves the people with clear vision and guidance to empower them To be empowered is to share ownership in the identity
bull Giving people a certain degree of control over their work fulfills the need for freedom and provides opportunity for taking joy in work
Profound Knowledge as a guide
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 67
Appreciation for a System
Theory of Knowledge
Knowledge about
Variation
Human Behavior -Psychology of Change
A
B
C
D+
Systems Approach for ErrorDeviation Management
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 68
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
Human error models and management J Reason BMJ 320 768ndash770 (2000)
D+
Culture of Error Management परबधनbull Error strain
bull Covering upFear of Errors
bull Anticipation
bull Risk takingAwareness
bull Development QbDRFT
bull Error detection Communication
bull Analyzing errors Correction
Mastery orientation
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 69
Dots amp Connections
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 70
CoQ
1
2
3
QMS
A
B
C
D
GXP Behaviors
X
Y
Z
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 71
Culture of Quality
Normal
Rewarding
Easy
QMS
System
Knowledge
Variation
Behavior
Behavior -GXPs
Fear Removed
Mastery
Awareness
EnvironmentLeadership Emphasis
Message Credibility
Peer Involvement
Employee Empowerment
Connect to CoQ
Connect to GXPs
A Framework and a Tool (for gap analysis)
3122015 Ajaz S Hussain PhD 22
Need for urgent progress lsquoInactive Ingredientsrsquo to lsquoExcipientsrsquo to lsquoFunctional Excipientsrsquo
Importance of assuring quality and controlling
variability of excipients
including their lsquofunctionalityrsquo has
long been recognized
bull Increasing complexity of drugs their delivery and failure modes
bull Patient (eg pediatric) relevant failure modes
bull Simple generics to complex generics amp biosimilars
Urgent need to address gaps in the FDArsquos Inactive Ingredient Database
3122015 Ajaz S Hussain PhD 23
Trends Lab amp Manufacturing
ldquoDeletion of Datardquo
ldquoTesting Into Compliancerdquo
ldquoBMR manipulation is a slippery sloperdquo
ldquoSuggestive of faulty manufacturing process or practices even if this is not the caserdquo
ldquoIt is top managementrsquos responsibility to ensure the training program is robust and effectiverdquo
Inspectional trends in data integrity (Bangalore Nov 13 2014 - Nov 14 2014)
Growing concern some
companies ldquodata looks too good
to be truerdquo
3122015 Ajaz S Hussain PhD 24
GMP Compliance amp Remediation
Jeff Medwid NIPTE-FDA Conference 13 June 2012
QbD amp QbR Clarity on Critical Functionality
FDArsquos New Pharma Quality
Office Will Take a Team
Approach Yu Explains
Carmelo Rosa MS PsyD November 2014
Urgent Need amp Opportunity
To align amp ensure sound scientific basis of these critical regulatory decisions
FDA CDER OPQ Plans for Surveillance of Pharmaceutical Quality
Teresa Mullin PhD December 2014
3122015 Ajaz S Hussain PhD 25
Need for a comprehensive (excipient) knowledge base
Teresa Mullin PhD December 2014
3122015 Ajaz S Hussain PhD 26
Why attention to (excipient) knowledge management is criticalSpecifically for physical attributes functionality performance
3122015 Ajaz S Hussain PhD 27
3122015 Ajaz S Hussain PhD 28
Today there are several product categories (eg controlled release inhalation products DPIrsquos topical transdermal liposomal products etc) which requires an exquisite control of complex physical material and product attributes (functionality)
Many of our current measurement systems need improvement
We depend on these to ensure control of lot-lot variability
Measurement system capability must be confirmed to be able to assess process capability (calibration amp Gauge RampR)
Life-cycle approach to quality continued process verification (FDArsquos Process Validation 2011) is a safety net
Supplier amp Excipient Qualification amp Process Validation
Measurement System Analysis
bull From lsquocalibrationrsquo to lsquoGauge RampRrsquoParticularly for physical
attributes destructive analysis
bull Many (including regulators) have not yet understood its importance
Gauge RampR well established but not commonly practiced
bull Measurement system in a state of control effective CAPA quality metrics Culture of Quality
With the move towards Statistical Process Control
bull Demonstrate equivalent in vitro performance more exacting criteria
Development of complex generic products (ER
Injectable Inhalation etc)
3122015 Ajaz S Hussain PhD 29
Process Validation (2011) Statistical Confidence Continued Process Verificationhellip
3122015 Ajaz S Hussain PhD 30
httpwwwslideshareneta2zpharmsciperformance-testing-pharmaceutical-quality-2004(accessed 6 December 2014)
3122015 Ajaz S Hussain PhD 31
Supplier amp Excipient Qualification amp CAPA
Out of Specification events are difficult to resolve
Excipient functionality can be a significant contributing factor
Sometimes reluctantly have to settle with - ldquoRoot cause unknown
600 days
I have inserted the ldquo600 daysrsquo on the figure ndash this is based on cases I have seen while at FDA)
3122015 Ajaz S Hussain PhD 32
Prevention of OOS and Effective CAPA needs a focus on critical functional attributes
Out of Specification events are difficult to resolve
Excipient functionality can be a significant contributing factor
Sometimes reluctantly have to settle with - ldquoRoot cause unknown
Compendial standards and manufacturing
3122015 Ajaz S Hussain PhD 33
Practice Control Process Maturity
Initial
bull Unpredictable
Managed
bull Characterized but reactive
Defined
bull Characterized proactive
Measured amp Controlled
bull In control
Optimizing
bull Focus on improvement
3122015 Ajaz S Hussain PhD 34
Capability Maturity Model Integration Carnegie Mellon University
A validated process
Maturity Level amp Assurance of Quality
Managed Characterized but reactive
High perceived risk of
lsquoCheating by Designrsquo
ldquoTrial Injectionsrdquo
ldquoTesting in to Compliancerdquo
Defined Characterized proactive
Lower level of assurance
Stopping amp Correcting
Batch Rejection
Measured amp
ControlledIn control
Quality by Design
Quality Assured
Improvement Opportunities
3122015 Ajaz S Hussain PhD 35
At the individual level in QC functionndash how often does this occur
attitude toward
performing the behavior
Process validation is
done so quality is good
test prone to error
ldquoBatch failure means I made
a mistakerdquo
subjective norm
documentation not critical
Compendial testing
sufficient
Indian regulators
collect amp test samples ndash no issue there
3122015 Ajaz S Hussain PhD 36
ldquoTesting into compliancerdquo
In general ndash low empowerment is a significant challenge (low perceived behavioral control) plus reasons to rationalizehellip
Excipient Functionality Can be critical for safety efficacy and quality
3122015 Ajaz S Hussain PhD 37
July 15 2005 FDA Public Health Advisory Safety Warnings Regarding Use of Fentanyl Transdermal (Skin) Patches
A pattern of failure Pharmaceutical Equivalence by Design (2004)
3122015 Ajaz S Hussain PhD 38
httpwwwnihsgojpdrugPhForumdocuments041122Hussain041122pdf
An attempt to correct
3122015 Ajaz S Hussain PhD 39
httpipecamericasorgsystemfilesKeyNoteEF13May11LawrenceYu(FDA)pdf
Recent challenges
3122015 Ajaz S Hussain PhD 40
Th
e V
oic
e o
f th
eA
mer
ican
P
sych
iatr
ic A
sso
ciat
ion
and
th
e P
sych
iatr
ic C
om
mu
nit
y
Physicians Question FDAs Confidence in Generic Drugs Safety Efficacy (OCTOBER 24 2014)
bull ldquomost patientsrdquo is not the same asldquo all patientsrdquo and whether the 24 to 36 normal subjects used in the agencys bioequivalency tests represents the full range of individual variation in the way drugs are absorbed across the pharmaceutical using population is uncertain
bull Individuals can sometimes be allergic and react differently to whatever substance goes into making up the capsule or the tablet
FDA Flags Generic Versions of ADHD Medication(NOVEMBER 14 2014)
bull FDA changed the therapeutic equivalence (TE) rating from AB to BXmdashmeaning that the products are still approved and can be prescribed but are no longer recommended as automatic substitutes
RLD Variability Can be a block-buster opportunityFocus on lsquocontrol strategyrsquo
bull Overcoming CP amp IP provide FDA a submission they need to address CP
bull Then begin with QTPP CQArsquos hellip skip lsquodesign spacersquo and focus on lsquocontrol strategy
bull The entire development team should read the complete package insert of RLD
bull Discuss to ensure a common understandingbull Failure modes amp intended use
bull Pharmaceutical Equivalence
bull Bioequivalence
bull Other studies
QbD Challenges
3122015 Ajaz S Hussain PhD 41
NewRegulators are not prepared to handle QbD applications
NewMisalignment of international regulatory authorities
New and Generics
RampD incentivized for lsquoshots on the goalrsquo not QbD
GenericsLack of belief in business case ndash lsquoGenerics are all about file first figure out laterrsquo
Biologics Lack of technology to execute
Ted Fuhr Mackinsey amp Company June 2010 FDA Advisory Committee
Summary
bull Excipient functionality can contribute in critical ways to product quality amp performance adequate control is necessary
bull Our databases tools and knowledge are lagging behind the rapidly increasing complexity and uncertainty
bull Risk to quality and to business is increasing and regulatory transitions pose additional difficulties
bull Effective knowledge management ndash IT and Human practices ndash is critical for organizational lsquobottom-linersquo
bull We all must come together collaboratively to address the urgent needs we owe it to the patients we serve
3122015 Ajaz S Hussain PhD 42
Knowledge Management amp Culture of Quality
Ajaz S Hussain PhD
Insight Advice amp Solutions LLCMaryland USA
Executive Director the National Institute for Pharmaceutical Technology amp Education
3122015 Ajaz S Hussain PhD 43
3122015 Ajaz S Hussain PhD 44
Life-cycle approach needed for knowledge management
Investigational ProductscGMPs
DevelopmentTechnology
TransferCommercial
ManufacturingDiscontinuation
Management Responsibility
Process Performance amp Product Quality Monitoring SystemCAPA Change Management Management Review
PQS Elements
Knowledge ManagementQuality Risk ManagementEnablers
ICH Q10 KM is a systematic approach to acquiring analyzing storing and disseminating information related to products manufacturing processes and components
Based on ICH Q10
ldquowe can be blind to the obvious and we are also blind to our blindnessrdquo
Daniel Kahneman Thinking Fast and Slow
3142015 Ajazajazhussaincom 45
httpwebmiteduperscipeopleadelsoncheckershadow_proofhtml
3122015 Ajaz S Hussain PhD 46
1938 The Federal Food Drug and Cosmetic (FDC)
bull 1937 Elixir of Sulfanilamide
1962 Kefauver-Harris Drug Amendments
bull 1962 Thalidomide
bull 1960 Color Additive Amendment
bull 1958 Food Additives Amendment GRAS
bull 1960 Color Additive Amendment
bull 1958 Food Additives Amendment GRAS
1992 Generic Drug Enforcement Act
bull1989 L-Tryptophan
bull 1989 Generic Drug Scandal
bull 1988 Food and Drug Administration Act
bull 1984 Fines Enhancement Laws Drug Price Competition and Patent Term Restoration Act
2012 Food and Drug Administration Safety and Innovation Act (FDASIA)
bull 2007 Heparin Disaster
2013 Pandemic and All-Hazards Preparedness Reauthorization Act (PAHPRA) Drug Quality and Security Act
bull 2012 The Deadly Meningitis Outbreak
Past 70 years 1937 ndash 2007 The diethylene glycol (DEG) narrative
3122015 Ajaz S Hussain PhD 47
0
5
10
15
20
25
30
35
Yea
rs
DEG Years since the previous incident
0
50
100
150
200
250
300
350
Number of Reported Deaths
1937
Eli
xir
of
Sulf
anil
amid
e
2007T
ootp
aste
conta
min
atio
n
0 70 years 0 70 years
Frequent reports
Mumbai Mumbai
Data from Excipient Fest Janeen Skutnik Chair ndashIPECAmericas 2009
Past 70+ years DEG contamination or economically motivated adulteration
3122015 Ajaz S Hussain PhD 48
Reported cases underestimate the real tragedy rapid intervention may not occur
Epidemic of Pediatric Deaths From Acute Renal Failure Caused by
Diethylene Glycol Poisoning JAMA 1998279(15)1175-1180
doi101001jama279151175
Month of hospital admission for children with
acute renal failure Haiti
October 1995-October 1996
Diethylene glycol poisoning in Gurgaon India 1998Bulletin of the World Health Organization 2001 79 88ndash95
We report a second episode of poisoning occurring in 1998 in
India as a result of children ingesting diethylene glycol at
least 33 children are known to have died
At the beginning of the investigation we never imagined that
contaminated medicine was causing acute renal failure in
children
A brand of cough expectorant manufactured by a local
pharmaceutical company was found by the Central Drugs
Laboratory Calcutta to contain 175 (vv) diethylene
glycol
The district and state drug controller had tested many
samples using thin layer chromatography before a sample of
medicine tested positive for diethylene glycol at the Central
Drugs Laboratory None of the earlier samples was found to
be contaminated
3122015 Ajaz S Hussain PhD 49
Guidance for Industry Testing of
Glycerin for Diethylene Glycol
CDER May 2007 Compliance
1 Manufacturers did not perform full
identity testing on the glycerin raw
material including tests to quantify
the amount of DEG
2 Relied on the certificate of analysis
(COA)
3 The origin of the glycerin was not
easily apparent from the COA
4 The COA was often a copy of a COA
on the letterhead of the distributor
5 The chain of custody or distribution
history of the glycerin was also not
readily known
USP Glycerin Monograph
Type of Posting Revision Bulletin
Posting Date 04ndashFebndash2009
Official Date 01ndashMayndash2009
Because of the serious hazards
associated withhellip and in response to
recommendations set forth in the
FDA Guidance for Industry Testing
of Glycerin for Diethylene Glycol
published in May 2007 USP has
revised the USP Glycerin monograph
Because diethylene glycol and
ethylene glycol are considered
unacceptable toxic substances the
testing of USP Glycerin should
demonstrate the absence of these
substances
April 2007 FDA request to
USP to revise the Glycerin
monographrsquos
IDENTIFICATION section
Revision includes adding ndash
Identification test B LIMIT OF
DIETHYLENE GLYCOL AND
ETHYLENE GLYCOL to detect
and quantify DEGEG in Glycerin
minus Is no longer part of the impurity
testing
ldquoLimit of DEG and Related
Compoundsrdquo minus Introduces a
capillary gas-chromatographic
(GC) method with flame ionization
detection (FID) minus Limit of NMT
010 each for diethylene glycol
and ethylene glycol is found
70+ years to get here how difficult will it be to change habits such as lsquoblind reliance of COArsquo
3122015 Ajaz S Hussain PhD 50
Personality and Habitual Frame Biases
Myers Brigs ENTJ (first tested at FDA)
S
TF
Expanded frame
future
possibilities
objective lsquocause
and effectrsquo
Expanded frame
future
possibilities
people and
relationships
Narrow frame
the present
individuals and
relationships
Narrow frame
the present
objective
cause and
effect
N
Based on Stanford Webinar - How to Overcome the Top 3 MegaBiases in Decision-Making
Stanford Universityrsquos Strategic Decision and Risk Management certificate program
From Mapping a Managers Brain on Incentives
Social
influences
Relative
thinking
UncertaintyComplexity
By Design Intention to act consciously
bull In the interest of patients and to continually improve this ability bull To provide a healing touch ndash one life at a time in what we do and how we
do it
1292014 Ajazajazhussaincom 51
Consciously
Scientific methodology
Engineering Design
Plan-Do-Check-Act
Subconsciously
Habits (work to get rid of bad ones)
Habits (work to cultivate good one)
Keystone habits (Safety Alcoa ALCOA of data integrity)
The Power of Habit Why We Do What We Do in Life and Business Charles Duhigg (2012)
httpwwwslideshareneta2zpharmscipharmaceutical-culture-of-quality
What does it take to come out of the cGMP crisis
Persuasive demonstration of
(1) Ability to face facts
(2) Legal amp regulatory requirements
3) Systems approach to quality
4) Changing behavior amp culture
What is often missed or is unconvincing is how you will strengthen culture of quality
ldquoLet one who wants to move and convince others first be convinced and moved themselvesrdquo Thomas Carlyle
Signals that question the competence motivation andor integrity of company personnel
Do not defend the plainly indefensible it adds further serious credibility costs
3142015 Ajazajazhussaincom 52
Quality is everyones responsibility
Lack of knowledge that is
the problem
If you do not know how to ask the
right question you discover nothing
If you cant describe what you
are doing as a process you dont know what youre
doing
Rational behavior requires theory
Reactive behavior requires only reflex
action
Whenever there is fear you will get wrong figures
3142015 Ajazajazhussaincom 53
Selected quotes W Edwards Deming
3142015 Ajazajazhussaincom 54
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
ldquoWE CANNOT CHANGE THE HUMAN CONDITION BUThellipWE CAN CHANGE THE CONDITIONS UNDER WHICH HUMANS WORKrdquo JAMES REASON
Disregard to Malice
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 55
ldquohelliprecords not completed
contemporaneouslyrdquo
ldquohellipobserved analyst back-date logbooksrdquo
ldquohelliptrial injectionshelliprdquo
ldquohellipresults failing specifications are
retested until acceptable results are obtainedhelliprdquo
ldquohellipover-writing electronic raw datahelliprdquo
ldquohellipOOS not investigates per XYZ SOPrdquo
ldquohellipappropriate controls not establishedhelliprdquo
Each additional observation adds
reasons to confirm that this is very likely a system
with intentional lsquoholesrsquo in its
defenses
Preconditions
Rationalization amp Attitude
Pressure amp Incentive
Opportunity ndashlsquoholes in the QMSrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 56
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 57
Attitude towards the behavior
Subjective norm
Perceived behavioral
control
IntentionFuture
Behavior
usually found to predict behavioral intentions with a high degree of accuracy
intentions in combination with perceived behavioral control can account for a considerable proportion of variance in behavior
PastBehavior
Ajen I The theory of planned behavior ORGANIZATIONAL BEHAVIOR AND HUMAN DECISION PROCESSES 50 179-211 (1991)
Heparin tragedy 2007 and 2008
FDA reports 149 deaths with allergic or hypersensitivity symptoms during that period
bull Contaminated heparin from China
QC Testing
bull Initial testing failed to detect the contaminant
Pharmacovigilence
bull Signals in the pharmacovigilence systems responded slowly and
Eventually the severity of reactions associated made it likely that the contamination would be detected
bull too late for those who died or were injured
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 58
Congressman Shimkus When the drug safety system fails people get sick Some die
bull Some of these people are already very vulnerable and proving the cause of harm from impurities adulteration and counterfeits can be elusive
It is hard to detect harm
bull Certainly the companies are obligated to ensure a culture of quality and maintain vigilance as well This reflects a systems approach to safety
FDA inspectors look for a culture of quality at
manufacturing facilities
bull FDA policies led to the failure to inspect the Chinese plantThis system approach wasnt at
play here
bull While it doesnt deny the counterfeit source tries to say that counterfeits didnt cause the reaction as if the adulteration itself was no big deal Is this an acceptable mindset helliphelliphellip
This brings me to China and its quality culture or lack thereof
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 59
ONE HUNDRED TENTH CONGRESS SECOND SESSION APRIL 29 2008 Serial No 110-109
21 CFR PART 211 SUBPARTS -Deviations signal gaps in CoQ
bullGENERAL PROVISIONSA
bullORGANIZATION AND PERSONNELB
bullBUILDINGS AND FACILITIESC
bullEQUIPMENTD
bullCONTROL OF COMPONENTS AND DRUG PRODUCT CONTAINERS AND CLOSURESE
bullPRODUCTION AND PROCESS CONTROLSF
bullPACKAGING AND LABELING CONTROLG
bullHOLDING AND DISTRIBUTIONH
bullLABORATORY CONTROLSI
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 60
For example the combinationhellip
The Power of Habit Why We Do What We Do in Life and Business Charles Duhigg (2012)
bull Scientific methodology
bull Engineering Design
bull Plan-Do-Check-ActConsciously
bull Habits (work to get rid of bad ones)
bull Habits (work to cultivate good one)
bull Keystone habits (Safety Alcoa ALCOA of data integrity)
Subconsciously
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 61
CoQ How
bull What are the predictors of CoQCoQ Manifests by Design -
lsquoquality by designrsquo the foundation
bull 1 2 3When do people change their behaviors
bull A B C D (any body can dance)What makes a QMS effective
bull X Y ZWhen proactive compliance occurs
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 62
Going beyond rules pays
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 63
Human behavior Connecting the Dots With the Right Connectors
GXPs ndash rational behaviors
How proactive compliance is achieved X Y Z
Quality Management System
What makes a QMS reliable A B C D
Culture of Quality
Why people change their behavior 1 2 3
Human Behaviors Beyond GXPs
Predictors of Culture of Quality
Why What and How of Culture of Quality
9192014 copy Ajaz S Hussain | INSIGHT ADVICE amp SOLUTIONS LLC 64
Predictors of CoQ Act consciously in the interest of patients ndash when no one is looking
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 65
Only four attributes
actually predict a culture of
quality
Leadership Emphasis
Message Credibility
Peer Involvement
Employee Empower-ment
People will change their
behavior if they see the new behavior as
Normal
(1)
Rewarding
(2)
Easy
(3)
Dr W Edwards Demingrsquos - ldquoOut of the crisisrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 66
The journey requires leadership
with Profound Knowledge as a
guide
bull As leaders responsible for system change top management is most in need of profound knowledge
bull Quality is often determined in the boardroom
bull Problems arise when management reacts to common cause or chance variation as if it were special cause variation
bull Prediction based in theory provides a foundation for planning a course of action Plan ndash Do ndash Check ndash Act
bull The leader serves the people with clear vision and guidance to empower them To be empowered is to share ownership in the identity
bull Giving people a certain degree of control over their work fulfills the need for freedom and provides opportunity for taking joy in work
Profound Knowledge as a guide
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 67
Appreciation for a System
Theory of Knowledge
Knowledge about
Variation
Human Behavior -Psychology of Change
A
B
C
D+
Systems Approach for ErrorDeviation Management
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 68
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
Human error models and management J Reason BMJ 320 768ndash770 (2000)
D+
Culture of Error Management परबधनbull Error strain
bull Covering upFear of Errors
bull Anticipation
bull Risk takingAwareness
bull Development QbDRFT
bull Error detection Communication
bull Analyzing errors Correction
Mastery orientation
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 69
Dots amp Connections
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 70
CoQ
1
2
3
QMS
A
B
C
D
GXP Behaviors
X
Y
Z
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 71
Culture of Quality
Normal
Rewarding
Easy
QMS
System
Knowledge
Variation
Behavior
Behavior -GXPs
Fear Removed
Mastery
Awareness
EnvironmentLeadership Emphasis
Message Credibility
Peer Involvement
Employee Empowerment
Connect to CoQ
Connect to GXPs
A Framework and a Tool (for gap analysis)
3122015 Ajaz S Hussain PhD 23
Trends Lab amp Manufacturing
ldquoDeletion of Datardquo
ldquoTesting Into Compliancerdquo
ldquoBMR manipulation is a slippery sloperdquo
ldquoSuggestive of faulty manufacturing process or practices even if this is not the caserdquo
ldquoIt is top managementrsquos responsibility to ensure the training program is robust and effectiverdquo
Inspectional trends in data integrity (Bangalore Nov 13 2014 - Nov 14 2014)
Growing concern some
companies ldquodata looks too good
to be truerdquo
3122015 Ajaz S Hussain PhD 24
GMP Compliance amp Remediation
Jeff Medwid NIPTE-FDA Conference 13 June 2012
QbD amp QbR Clarity on Critical Functionality
FDArsquos New Pharma Quality
Office Will Take a Team
Approach Yu Explains
Carmelo Rosa MS PsyD November 2014
Urgent Need amp Opportunity
To align amp ensure sound scientific basis of these critical regulatory decisions
FDA CDER OPQ Plans for Surveillance of Pharmaceutical Quality
Teresa Mullin PhD December 2014
3122015 Ajaz S Hussain PhD 25
Need for a comprehensive (excipient) knowledge base
Teresa Mullin PhD December 2014
3122015 Ajaz S Hussain PhD 26
Why attention to (excipient) knowledge management is criticalSpecifically for physical attributes functionality performance
3122015 Ajaz S Hussain PhD 27
3122015 Ajaz S Hussain PhD 28
Today there are several product categories (eg controlled release inhalation products DPIrsquos topical transdermal liposomal products etc) which requires an exquisite control of complex physical material and product attributes (functionality)
Many of our current measurement systems need improvement
We depend on these to ensure control of lot-lot variability
Measurement system capability must be confirmed to be able to assess process capability (calibration amp Gauge RampR)
Life-cycle approach to quality continued process verification (FDArsquos Process Validation 2011) is a safety net
Supplier amp Excipient Qualification amp Process Validation
Measurement System Analysis
bull From lsquocalibrationrsquo to lsquoGauge RampRrsquoParticularly for physical
attributes destructive analysis
bull Many (including regulators) have not yet understood its importance
Gauge RampR well established but not commonly practiced
bull Measurement system in a state of control effective CAPA quality metrics Culture of Quality
With the move towards Statistical Process Control
bull Demonstrate equivalent in vitro performance more exacting criteria
Development of complex generic products (ER
Injectable Inhalation etc)
3122015 Ajaz S Hussain PhD 29
Process Validation (2011) Statistical Confidence Continued Process Verificationhellip
3122015 Ajaz S Hussain PhD 30
httpwwwslideshareneta2zpharmsciperformance-testing-pharmaceutical-quality-2004(accessed 6 December 2014)
3122015 Ajaz S Hussain PhD 31
Supplier amp Excipient Qualification amp CAPA
Out of Specification events are difficult to resolve
Excipient functionality can be a significant contributing factor
Sometimes reluctantly have to settle with - ldquoRoot cause unknown
600 days
I have inserted the ldquo600 daysrsquo on the figure ndash this is based on cases I have seen while at FDA)
3122015 Ajaz S Hussain PhD 32
Prevention of OOS and Effective CAPA needs a focus on critical functional attributes
Out of Specification events are difficult to resolve
Excipient functionality can be a significant contributing factor
Sometimes reluctantly have to settle with - ldquoRoot cause unknown
Compendial standards and manufacturing
3122015 Ajaz S Hussain PhD 33
Practice Control Process Maturity
Initial
bull Unpredictable
Managed
bull Characterized but reactive
Defined
bull Characterized proactive
Measured amp Controlled
bull In control
Optimizing
bull Focus on improvement
3122015 Ajaz S Hussain PhD 34
Capability Maturity Model Integration Carnegie Mellon University
A validated process
Maturity Level amp Assurance of Quality
Managed Characterized but reactive
High perceived risk of
lsquoCheating by Designrsquo
ldquoTrial Injectionsrdquo
ldquoTesting in to Compliancerdquo
Defined Characterized proactive
Lower level of assurance
Stopping amp Correcting
Batch Rejection
Measured amp
ControlledIn control
Quality by Design
Quality Assured
Improvement Opportunities
3122015 Ajaz S Hussain PhD 35
At the individual level in QC functionndash how often does this occur
attitude toward
performing the behavior
Process validation is
done so quality is good
test prone to error
ldquoBatch failure means I made
a mistakerdquo
subjective norm
documentation not critical
Compendial testing
sufficient
Indian regulators
collect amp test samples ndash no issue there
3122015 Ajaz S Hussain PhD 36
ldquoTesting into compliancerdquo
In general ndash low empowerment is a significant challenge (low perceived behavioral control) plus reasons to rationalizehellip
Excipient Functionality Can be critical for safety efficacy and quality
3122015 Ajaz S Hussain PhD 37
July 15 2005 FDA Public Health Advisory Safety Warnings Regarding Use of Fentanyl Transdermal (Skin) Patches
A pattern of failure Pharmaceutical Equivalence by Design (2004)
3122015 Ajaz S Hussain PhD 38
httpwwwnihsgojpdrugPhForumdocuments041122Hussain041122pdf
An attempt to correct
3122015 Ajaz S Hussain PhD 39
httpipecamericasorgsystemfilesKeyNoteEF13May11LawrenceYu(FDA)pdf
Recent challenges
3122015 Ajaz S Hussain PhD 40
Th
e V
oic
e o
f th
eA
mer
ican
P
sych
iatr
ic A
sso
ciat
ion
and
th
e P
sych
iatr
ic C
om
mu
nit
y
Physicians Question FDAs Confidence in Generic Drugs Safety Efficacy (OCTOBER 24 2014)
bull ldquomost patientsrdquo is not the same asldquo all patientsrdquo and whether the 24 to 36 normal subjects used in the agencys bioequivalency tests represents the full range of individual variation in the way drugs are absorbed across the pharmaceutical using population is uncertain
bull Individuals can sometimes be allergic and react differently to whatever substance goes into making up the capsule or the tablet
FDA Flags Generic Versions of ADHD Medication(NOVEMBER 14 2014)
bull FDA changed the therapeutic equivalence (TE) rating from AB to BXmdashmeaning that the products are still approved and can be prescribed but are no longer recommended as automatic substitutes
RLD Variability Can be a block-buster opportunityFocus on lsquocontrol strategyrsquo
bull Overcoming CP amp IP provide FDA a submission they need to address CP
bull Then begin with QTPP CQArsquos hellip skip lsquodesign spacersquo and focus on lsquocontrol strategy
bull The entire development team should read the complete package insert of RLD
bull Discuss to ensure a common understandingbull Failure modes amp intended use
bull Pharmaceutical Equivalence
bull Bioequivalence
bull Other studies
QbD Challenges
3122015 Ajaz S Hussain PhD 41
NewRegulators are not prepared to handle QbD applications
NewMisalignment of international regulatory authorities
New and Generics
RampD incentivized for lsquoshots on the goalrsquo not QbD
GenericsLack of belief in business case ndash lsquoGenerics are all about file first figure out laterrsquo
Biologics Lack of technology to execute
Ted Fuhr Mackinsey amp Company June 2010 FDA Advisory Committee
Summary
bull Excipient functionality can contribute in critical ways to product quality amp performance adequate control is necessary
bull Our databases tools and knowledge are lagging behind the rapidly increasing complexity and uncertainty
bull Risk to quality and to business is increasing and regulatory transitions pose additional difficulties
bull Effective knowledge management ndash IT and Human practices ndash is critical for organizational lsquobottom-linersquo
bull We all must come together collaboratively to address the urgent needs we owe it to the patients we serve
3122015 Ajaz S Hussain PhD 42
Knowledge Management amp Culture of Quality
Ajaz S Hussain PhD
Insight Advice amp Solutions LLCMaryland USA
Executive Director the National Institute for Pharmaceutical Technology amp Education
3122015 Ajaz S Hussain PhD 43
3122015 Ajaz S Hussain PhD 44
Life-cycle approach needed for knowledge management
Investigational ProductscGMPs
DevelopmentTechnology
TransferCommercial
ManufacturingDiscontinuation
Management Responsibility
Process Performance amp Product Quality Monitoring SystemCAPA Change Management Management Review
PQS Elements
Knowledge ManagementQuality Risk ManagementEnablers
ICH Q10 KM is a systematic approach to acquiring analyzing storing and disseminating information related to products manufacturing processes and components
Based on ICH Q10
ldquowe can be blind to the obvious and we are also blind to our blindnessrdquo
Daniel Kahneman Thinking Fast and Slow
3142015 Ajazajazhussaincom 45
httpwebmiteduperscipeopleadelsoncheckershadow_proofhtml
3122015 Ajaz S Hussain PhD 46
1938 The Federal Food Drug and Cosmetic (FDC)
bull 1937 Elixir of Sulfanilamide
1962 Kefauver-Harris Drug Amendments
bull 1962 Thalidomide
bull 1960 Color Additive Amendment
bull 1958 Food Additives Amendment GRAS
bull 1960 Color Additive Amendment
bull 1958 Food Additives Amendment GRAS
1992 Generic Drug Enforcement Act
bull1989 L-Tryptophan
bull 1989 Generic Drug Scandal
bull 1988 Food and Drug Administration Act
bull 1984 Fines Enhancement Laws Drug Price Competition and Patent Term Restoration Act
2012 Food and Drug Administration Safety and Innovation Act (FDASIA)
bull 2007 Heparin Disaster
2013 Pandemic and All-Hazards Preparedness Reauthorization Act (PAHPRA) Drug Quality and Security Act
bull 2012 The Deadly Meningitis Outbreak
Past 70 years 1937 ndash 2007 The diethylene glycol (DEG) narrative
3122015 Ajaz S Hussain PhD 47
0
5
10
15
20
25
30
35
Yea
rs
DEG Years since the previous incident
0
50
100
150
200
250
300
350
Number of Reported Deaths
1937
Eli
xir
of
Sulf
anil
amid
e
2007T
ootp
aste
conta
min
atio
n
0 70 years 0 70 years
Frequent reports
Mumbai Mumbai
Data from Excipient Fest Janeen Skutnik Chair ndashIPECAmericas 2009
Past 70+ years DEG contamination or economically motivated adulteration
3122015 Ajaz S Hussain PhD 48
Reported cases underestimate the real tragedy rapid intervention may not occur
Epidemic of Pediatric Deaths From Acute Renal Failure Caused by
Diethylene Glycol Poisoning JAMA 1998279(15)1175-1180
doi101001jama279151175
Month of hospital admission for children with
acute renal failure Haiti
October 1995-October 1996
Diethylene glycol poisoning in Gurgaon India 1998Bulletin of the World Health Organization 2001 79 88ndash95
We report a second episode of poisoning occurring in 1998 in
India as a result of children ingesting diethylene glycol at
least 33 children are known to have died
At the beginning of the investigation we never imagined that
contaminated medicine was causing acute renal failure in
children
A brand of cough expectorant manufactured by a local
pharmaceutical company was found by the Central Drugs
Laboratory Calcutta to contain 175 (vv) diethylene
glycol
The district and state drug controller had tested many
samples using thin layer chromatography before a sample of
medicine tested positive for diethylene glycol at the Central
Drugs Laboratory None of the earlier samples was found to
be contaminated
3122015 Ajaz S Hussain PhD 49
Guidance for Industry Testing of
Glycerin for Diethylene Glycol
CDER May 2007 Compliance
1 Manufacturers did not perform full
identity testing on the glycerin raw
material including tests to quantify
the amount of DEG
2 Relied on the certificate of analysis
(COA)
3 The origin of the glycerin was not
easily apparent from the COA
4 The COA was often a copy of a COA
on the letterhead of the distributor
5 The chain of custody or distribution
history of the glycerin was also not
readily known
USP Glycerin Monograph
Type of Posting Revision Bulletin
Posting Date 04ndashFebndash2009
Official Date 01ndashMayndash2009
Because of the serious hazards
associated withhellip and in response to
recommendations set forth in the
FDA Guidance for Industry Testing
of Glycerin for Diethylene Glycol
published in May 2007 USP has
revised the USP Glycerin monograph
Because diethylene glycol and
ethylene glycol are considered
unacceptable toxic substances the
testing of USP Glycerin should
demonstrate the absence of these
substances
April 2007 FDA request to
USP to revise the Glycerin
monographrsquos
IDENTIFICATION section
Revision includes adding ndash
Identification test B LIMIT OF
DIETHYLENE GLYCOL AND
ETHYLENE GLYCOL to detect
and quantify DEGEG in Glycerin
minus Is no longer part of the impurity
testing
ldquoLimit of DEG and Related
Compoundsrdquo minus Introduces a
capillary gas-chromatographic
(GC) method with flame ionization
detection (FID) minus Limit of NMT
010 each for diethylene glycol
and ethylene glycol is found
70+ years to get here how difficult will it be to change habits such as lsquoblind reliance of COArsquo
3122015 Ajaz S Hussain PhD 50
Personality and Habitual Frame Biases
Myers Brigs ENTJ (first tested at FDA)
S
TF
Expanded frame
future
possibilities
objective lsquocause
and effectrsquo
Expanded frame
future
possibilities
people and
relationships
Narrow frame
the present
individuals and
relationships
Narrow frame
the present
objective
cause and
effect
N
Based on Stanford Webinar - How to Overcome the Top 3 MegaBiases in Decision-Making
Stanford Universityrsquos Strategic Decision and Risk Management certificate program
From Mapping a Managers Brain on Incentives
Social
influences
Relative
thinking
UncertaintyComplexity
By Design Intention to act consciously
bull In the interest of patients and to continually improve this ability bull To provide a healing touch ndash one life at a time in what we do and how we
do it
1292014 Ajazajazhussaincom 51
Consciously
Scientific methodology
Engineering Design
Plan-Do-Check-Act
Subconsciously
Habits (work to get rid of bad ones)
Habits (work to cultivate good one)
Keystone habits (Safety Alcoa ALCOA of data integrity)
The Power of Habit Why We Do What We Do in Life and Business Charles Duhigg (2012)
httpwwwslideshareneta2zpharmscipharmaceutical-culture-of-quality
What does it take to come out of the cGMP crisis
Persuasive demonstration of
(1) Ability to face facts
(2) Legal amp regulatory requirements
3) Systems approach to quality
4) Changing behavior amp culture
What is often missed or is unconvincing is how you will strengthen culture of quality
ldquoLet one who wants to move and convince others first be convinced and moved themselvesrdquo Thomas Carlyle
Signals that question the competence motivation andor integrity of company personnel
Do not defend the plainly indefensible it adds further serious credibility costs
3142015 Ajazajazhussaincom 52
Quality is everyones responsibility
Lack of knowledge that is
the problem
If you do not know how to ask the
right question you discover nothing
If you cant describe what you
are doing as a process you dont know what youre
doing
Rational behavior requires theory
Reactive behavior requires only reflex
action
Whenever there is fear you will get wrong figures
3142015 Ajazajazhussaincom 53
Selected quotes W Edwards Deming
3142015 Ajazajazhussaincom 54
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
ldquoWE CANNOT CHANGE THE HUMAN CONDITION BUThellipWE CAN CHANGE THE CONDITIONS UNDER WHICH HUMANS WORKrdquo JAMES REASON
Disregard to Malice
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 55
ldquohelliprecords not completed
contemporaneouslyrdquo
ldquohellipobserved analyst back-date logbooksrdquo
ldquohelliptrial injectionshelliprdquo
ldquohellipresults failing specifications are
retested until acceptable results are obtainedhelliprdquo
ldquohellipover-writing electronic raw datahelliprdquo
ldquohellipOOS not investigates per XYZ SOPrdquo
ldquohellipappropriate controls not establishedhelliprdquo
Each additional observation adds
reasons to confirm that this is very likely a system
with intentional lsquoholesrsquo in its
defenses
Preconditions
Rationalization amp Attitude
Pressure amp Incentive
Opportunity ndashlsquoholes in the QMSrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 56
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 57
Attitude towards the behavior
Subjective norm
Perceived behavioral
control
IntentionFuture
Behavior
usually found to predict behavioral intentions with a high degree of accuracy
intentions in combination with perceived behavioral control can account for a considerable proportion of variance in behavior
PastBehavior
Ajen I The theory of planned behavior ORGANIZATIONAL BEHAVIOR AND HUMAN DECISION PROCESSES 50 179-211 (1991)
Heparin tragedy 2007 and 2008
FDA reports 149 deaths with allergic or hypersensitivity symptoms during that period
bull Contaminated heparin from China
QC Testing
bull Initial testing failed to detect the contaminant
Pharmacovigilence
bull Signals in the pharmacovigilence systems responded slowly and
Eventually the severity of reactions associated made it likely that the contamination would be detected
bull too late for those who died or were injured
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 58
Congressman Shimkus When the drug safety system fails people get sick Some die
bull Some of these people are already very vulnerable and proving the cause of harm from impurities adulteration and counterfeits can be elusive
It is hard to detect harm
bull Certainly the companies are obligated to ensure a culture of quality and maintain vigilance as well This reflects a systems approach to safety
FDA inspectors look for a culture of quality at
manufacturing facilities
bull FDA policies led to the failure to inspect the Chinese plantThis system approach wasnt at
play here
bull While it doesnt deny the counterfeit source tries to say that counterfeits didnt cause the reaction as if the adulteration itself was no big deal Is this an acceptable mindset helliphelliphellip
This brings me to China and its quality culture or lack thereof
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 59
ONE HUNDRED TENTH CONGRESS SECOND SESSION APRIL 29 2008 Serial No 110-109
21 CFR PART 211 SUBPARTS -Deviations signal gaps in CoQ
bullGENERAL PROVISIONSA
bullORGANIZATION AND PERSONNELB
bullBUILDINGS AND FACILITIESC
bullEQUIPMENTD
bullCONTROL OF COMPONENTS AND DRUG PRODUCT CONTAINERS AND CLOSURESE
bullPRODUCTION AND PROCESS CONTROLSF
bullPACKAGING AND LABELING CONTROLG
bullHOLDING AND DISTRIBUTIONH
bullLABORATORY CONTROLSI
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 60
For example the combinationhellip
The Power of Habit Why We Do What We Do in Life and Business Charles Duhigg (2012)
bull Scientific methodology
bull Engineering Design
bull Plan-Do-Check-ActConsciously
bull Habits (work to get rid of bad ones)
bull Habits (work to cultivate good one)
bull Keystone habits (Safety Alcoa ALCOA of data integrity)
Subconsciously
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 61
CoQ How
bull What are the predictors of CoQCoQ Manifests by Design -
lsquoquality by designrsquo the foundation
bull 1 2 3When do people change their behaviors
bull A B C D (any body can dance)What makes a QMS effective
bull X Y ZWhen proactive compliance occurs
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 62
Going beyond rules pays
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 63
Human behavior Connecting the Dots With the Right Connectors
GXPs ndash rational behaviors
How proactive compliance is achieved X Y Z
Quality Management System
What makes a QMS reliable A B C D
Culture of Quality
Why people change their behavior 1 2 3
Human Behaviors Beyond GXPs
Predictors of Culture of Quality
Why What and How of Culture of Quality
9192014 copy Ajaz S Hussain | INSIGHT ADVICE amp SOLUTIONS LLC 64
Predictors of CoQ Act consciously in the interest of patients ndash when no one is looking
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 65
Only four attributes
actually predict a culture of
quality
Leadership Emphasis
Message Credibility
Peer Involvement
Employee Empower-ment
People will change their
behavior if they see the new behavior as
Normal
(1)
Rewarding
(2)
Easy
(3)
Dr W Edwards Demingrsquos - ldquoOut of the crisisrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 66
The journey requires leadership
with Profound Knowledge as a
guide
bull As leaders responsible for system change top management is most in need of profound knowledge
bull Quality is often determined in the boardroom
bull Problems arise when management reacts to common cause or chance variation as if it were special cause variation
bull Prediction based in theory provides a foundation for planning a course of action Plan ndash Do ndash Check ndash Act
bull The leader serves the people with clear vision and guidance to empower them To be empowered is to share ownership in the identity
bull Giving people a certain degree of control over their work fulfills the need for freedom and provides opportunity for taking joy in work
Profound Knowledge as a guide
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 67
Appreciation for a System
Theory of Knowledge
Knowledge about
Variation
Human Behavior -Psychology of Change
A
B
C
D+
Systems Approach for ErrorDeviation Management
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 68
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
Human error models and management J Reason BMJ 320 768ndash770 (2000)
D+
Culture of Error Management परबधनbull Error strain
bull Covering upFear of Errors
bull Anticipation
bull Risk takingAwareness
bull Development QbDRFT
bull Error detection Communication
bull Analyzing errors Correction
Mastery orientation
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 69
Dots amp Connections
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 70
CoQ
1
2
3
QMS
A
B
C
D
GXP Behaviors
X
Y
Z
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 71
Culture of Quality
Normal
Rewarding
Easy
QMS
System
Knowledge
Variation
Behavior
Behavior -GXPs
Fear Removed
Mastery
Awareness
EnvironmentLeadership Emphasis
Message Credibility
Peer Involvement
Employee Empowerment
Connect to CoQ
Connect to GXPs
A Framework and a Tool (for gap analysis)
3122015 Ajaz S Hussain PhD 24
GMP Compliance amp Remediation
Jeff Medwid NIPTE-FDA Conference 13 June 2012
QbD amp QbR Clarity on Critical Functionality
FDArsquos New Pharma Quality
Office Will Take a Team
Approach Yu Explains
Carmelo Rosa MS PsyD November 2014
Urgent Need amp Opportunity
To align amp ensure sound scientific basis of these critical regulatory decisions
FDA CDER OPQ Plans for Surveillance of Pharmaceutical Quality
Teresa Mullin PhD December 2014
3122015 Ajaz S Hussain PhD 25
Need for a comprehensive (excipient) knowledge base
Teresa Mullin PhD December 2014
3122015 Ajaz S Hussain PhD 26
Why attention to (excipient) knowledge management is criticalSpecifically for physical attributes functionality performance
3122015 Ajaz S Hussain PhD 27
3122015 Ajaz S Hussain PhD 28
Today there are several product categories (eg controlled release inhalation products DPIrsquos topical transdermal liposomal products etc) which requires an exquisite control of complex physical material and product attributes (functionality)
Many of our current measurement systems need improvement
We depend on these to ensure control of lot-lot variability
Measurement system capability must be confirmed to be able to assess process capability (calibration amp Gauge RampR)
Life-cycle approach to quality continued process verification (FDArsquos Process Validation 2011) is a safety net
Supplier amp Excipient Qualification amp Process Validation
Measurement System Analysis
bull From lsquocalibrationrsquo to lsquoGauge RampRrsquoParticularly for physical
attributes destructive analysis
bull Many (including regulators) have not yet understood its importance
Gauge RampR well established but not commonly practiced
bull Measurement system in a state of control effective CAPA quality metrics Culture of Quality
With the move towards Statistical Process Control
bull Demonstrate equivalent in vitro performance more exacting criteria
Development of complex generic products (ER
Injectable Inhalation etc)
3122015 Ajaz S Hussain PhD 29
Process Validation (2011) Statistical Confidence Continued Process Verificationhellip
3122015 Ajaz S Hussain PhD 30
httpwwwslideshareneta2zpharmsciperformance-testing-pharmaceutical-quality-2004(accessed 6 December 2014)
3122015 Ajaz S Hussain PhD 31
Supplier amp Excipient Qualification amp CAPA
Out of Specification events are difficult to resolve
Excipient functionality can be a significant contributing factor
Sometimes reluctantly have to settle with - ldquoRoot cause unknown
600 days
I have inserted the ldquo600 daysrsquo on the figure ndash this is based on cases I have seen while at FDA)
3122015 Ajaz S Hussain PhD 32
Prevention of OOS and Effective CAPA needs a focus on critical functional attributes
Out of Specification events are difficult to resolve
Excipient functionality can be a significant contributing factor
Sometimes reluctantly have to settle with - ldquoRoot cause unknown
Compendial standards and manufacturing
3122015 Ajaz S Hussain PhD 33
Practice Control Process Maturity
Initial
bull Unpredictable
Managed
bull Characterized but reactive
Defined
bull Characterized proactive
Measured amp Controlled
bull In control
Optimizing
bull Focus on improvement
3122015 Ajaz S Hussain PhD 34
Capability Maturity Model Integration Carnegie Mellon University
A validated process
Maturity Level amp Assurance of Quality
Managed Characterized but reactive
High perceived risk of
lsquoCheating by Designrsquo
ldquoTrial Injectionsrdquo
ldquoTesting in to Compliancerdquo
Defined Characterized proactive
Lower level of assurance
Stopping amp Correcting
Batch Rejection
Measured amp
ControlledIn control
Quality by Design
Quality Assured
Improvement Opportunities
3122015 Ajaz S Hussain PhD 35
At the individual level in QC functionndash how often does this occur
attitude toward
performing the behavior
Process validation is
done so quality is good
test prone to error
ldquoBatch failure means I made
a mistakerdquo
subjective norm
documentation not critical
Compendial testing
sufficient
Indian regulators
collect amp test samples ndash no issue there
3122015 Ajaz S Hussain PhD 36
ldquoTesting into compliancerdquo
In general ndash low empowerment is a significant challenge (low perceived behavioral control) plus reasons to rationalizehellip
Excipient Functionality Can be critical for safety efficacy and quality
3122015 Ajaz S Hussain PhD 37
July 15 2005 FDA Public Health Advisory Safety Warnings Regarding Use of Fentanyl Transdermal (Skin) Patches
A pattern of failure Pharmaceutical Equivalence by Design (2004)
3122015 Ajaz S Hussain PhD 38
httpwwwnihsgojpdrugPhForumdocuments041122Hussain041122pdf
An attempt to correct
3122015 Ajaz S Hussain PhD 39
httpipecamericasorgsystemfilesKeyNoteEF13May11LawrenceYu(FDA)pdf
Recent challenges
3122015 Ajaz S Hussain PhD 40
Th
e V
oic
e o
f th
eA
mer
ican
P
sych
iatr
ic A
sso
ciat
ion
and
th
e P
sych
iatr
ic C
om
mu
nit
y
Physicians Question FDAs Confidence in Generic Drugs Safety Efficacy (OCTOBER 24 2014)
bull ldquomost patientsrdquo is not the same asldquo all patientsrdquo and whether the 24 to 36 normal subjects used in the agencys bioequivalency tests represents the full range of individual variation in the way drugs are absorbed across the pharmaceutical using population is uncertain
bull Individuals can sometimes be allergic and react differently to whatever substance goes into making up the capsule or the tablet
FDA Flags Generic Versions of ADHD Medication(NOVEMBER 14 2014)
bull FDA changed the therapeutic equivalence (TE) rating from AB to BXmdashmeaning that the products are still approved and can be prescribed but are no longer recommended as automatic substitutes
RLD Variability Can be a block-buster opportunityFocus on lsquocontrol strategyrsquo
bull Overcoming CP amp IP provide FDA a submission they need to address CP
bull Then begin with QTPP CQArsquos hellip skip lsquodesign spacersquo and focus on lsquocontrol strategy
bull The entire development team should read the complete package insert of RLD
bull Discuss to ensure a common understandingbull Failure modes amp intended use
bull Pharmaceutical Equivalence
bull Bioequivalence
bull Other studies
QbD Challenges
3122015 Ajaz S Hussain PhD 41
NewRegulators are not prepared to handle QbD applications
NewMisalignment of international regulatory authorities
New and Generics
RampD incentivized for lsquoshots on the goalrsquo not QbD
GenericsLack of belief in business case ndash lsquoGenerics are all about file first figure out laterrsquo
Biologics Lack of technology to execute
Ted Fuhr Mackinsey amp Company June 2010 FDA Advisory Committee
Summary
bull Excipient functionality can contribute in critical ways to product quality amp performance adequate control is necessary
bull Our databases tools and knowledge are lagging behind the rapidly increasing complexity and uncertainty
bull Risk to quality and to business is increasing and regulatory transitions pose additional difficulties
bull Effective knowledge management ndash IT and Human practices ndash is critical for organizational lsquobottom-linersquo
bull We all must come together collaboratively to address the urgent needs we owe it to the patients we serve
3122015 Ajaz S Hussain PhD 42
Knowledge Management amp Culture of Quality
Ajaz S Hussain PhD
Insight Advice amp Solutions LLCMaryland USA
Executive Director the National Institute for Pharmaceutical Technology amp Education
3122015 Ajaz S Hussain PhD 43
3122015 Ajaz S Hussain PhD 44
Life-cycle approach needed for knowledge management
Investigational ProductscGMPs
DevelopmentTechnology
TransferCommercial
ManufacturingDiscontinuation
Management Responsibility
Process Performance amp Product Quality Monitoring SystemCAPA Change Management Management Review
PQS Elements
Knowledge ManagementQuality Risk ManagementEnablers
ICH Q10 KM is a systematic approach to acquiring analyzing storing and disseminating information related to products manufacturing processes and components
Based on ICH Q10
ldquowe can be blind to the obvious and we are also blind to our blindnessrdquo
Daniel Kahneman Thinking Fast and Slow
3142015 Ajazajazhussaincom 45
httpwebmiteduperscipeopleadelsoncheckershadow_proofhtml
3122015 Ajaz S Hussain PhD 46
1938 The Federal Food Drug and Cosmetic (FDC)
bull 1937 Elixir of Sulfanilamide
1962 Kefauver-Harris Drug Amendments
bull 1962 Thalidomide
bull 1960 Color Additive Amendment
bull 1958 Food Additives Amendment GRAS
bull 1960 Color Additive Amendment
bull 1958 Food Additives Amendment GRAS
1992 Generic Drug Enforcement Act
bull1989 L-Tryptophan
bull 1989 Generic Drug Scandal
bull 1988 Food and Drug Administration Act
bull 1984 Fines Enhancement Laws Drug Price Competition and Patent Term Restoration Act
2012 Food and Drug Administration Safety and Innovation Act (FDASIA)
bull 2007 Heparin Disaster
2013 Pandemic and All-Hazards Preparedness Reauthorization Act (PAHPRA) Drug Quality and Security Act
bull 2012 The Deadly Meningitis Outbreak
Past 70 years 1937 ndash 2007 The diethylene glycol (DEG) narrative
3122015 Ajaz S Hussain PhD 47
0
5
10
15
20
25
30
35
Yea
rs
DEG Years since the previous incident
0
50
100
150
200
250
300
350
Number of Reported Deaths
1937
Eli
xir
of
Sulf
anil
amid
e
2007T
ootp
aste
conta
min
atio
n
0 70 years 0 70 years
Frequent reports
Mumbai Mumbai
Data from Excipient Fest Janeen Skutnik Chair ndashIPECAmericas 2009
Past 70+ years DEG contamination or economically motivated adulteration
3122015 Ajaz S Hussain PhD 48
Reported cases underestimate the real tragedy rapid intervention may not occur
Epidemic of Pediatric Deaths From Acute Renal Failure Caused by
Diethylene Glycol Poisoning JAMA 1998279(15)1175-1180
doi101001jama279151175
Month of hospital admission for children with
acute renal failure Haiti
October 1995-October 1996
Diethylene glycol poisoning in Gurgaon India 1998Bulletin of the World Health Organization 2001 79 88ndash95
We report a second episode of poisoning occurring in 1998 in
India as a result of children ingesting diethylene glycol at
least 33 children are known to have died
At the beginning of the investigation we never imagined that
contaminated medicine was causing acute renal failure in
children
A brand of cough expectorant manufactured by a local
pharmaceutical company was found by the Central Drugs
Laboratory Calcutta to contain 175 (vv) diethylene
glycol
The district and state drug controller had tested many
samples using thin layer chromatography before a sample of
medicine tested positive for diethylene glycol at the Central
Drugs Laboratory None of the earlier samples was found to
be contaminated
3122015 Ajaz S Hussain PhD 49
Guidance for Industry Testing of
Glycerin for Diethylene Glycol
CDER May 2007 Compliance
1 Manufacturers did not perform full
identity testing on the glycerin raw
material including tests to quantify
the amount of DEG
2 Relied on the certificate of analysis
(COA)
3 The origin of the glycerin was not
easily apparent from the COA
4 The COA was often a copy of a COA
on the letterhead of the distributor
5 The chain of custody or distribution
history of the glycerin was also not
readily known
USP Glycerin Monograph
Type of Posting Revision Bulletin
Posting Date 04ndashFebndash2009
Official Date 01ndashMayndash2009
Because of the serious hazards
associated withhellip and in response to
recommendations set forth in the
FDA Guidance for Industry Testing
of Glycerin for Diethylene Glycol
published in May 2007 USP has
revised the USP Glycerin monograph
Because diethylene glycol and
ethylene glycol are considered
unacceptable toxic substances the
testing of USP Glycerin should
demonstrate the absence of these
substances
April 2007 FDA request to
USP to revise the Glycerin
monographrsquos
IDENTIFICATION section
Revision includes adding ndash
Identification test B LIMIT OF
DIETHYLENE GLYCOL AND
ETHYLENE GLYCOL to detect
and quantify DEGEG in Glycerin
minus Is no longer part of the impurity
testing
ldquoLimit of DEG and Related
Compoundsrdquo minus Introduces a
capillary gas-chromatographic
(GC) method with flame ionization
detection (FID) minus Limit of NMT
010 each for diethylene glycol
and ethylene glycol is found
70+ years to get here how difficult will it be to change habits such as lsquoblind reliance of COArsquo
3122015 Ajaz S Hussain PhD 50
Personality and Habitual Frame Biases
Myers Brigs ENTJ (first tested at FDA)
S
TF
Expanded frame
future
possibilities
objective lsquocause
and effectrsquo
Expanded frame
future
possibilities
people and
relationships
Narrow frame
the present
individuals and
relationships
Narrow frame
the present
objective
cause and
effect
N
Based on Stanford Webinar - How to Overcome the Top 3 MegaBiases in Decision-Making
Stanford Universityrsquos Strategic Decision and Risk Management certificate program
From Mapping a Managers Brain on Incentives
Social
influences
Relative
thinking
UncertaintyComplexity
By Design Intention to act consciously
bull In the interest of patients and to continually improve this ability bull To provide a healing touch ndash one life at a time in what we do and how we
do it
1292014 Ajazajazhussaincom 51
Consciously
Scientific methodology
Engineering Design
Plan-Do-Check-Act
Subconsciously
Habits (work to get rid of bad ones)
Habits (work to cultivate good one)
Keystone habits (Safety Alcoa ALCOA of data integrity)
The Power of Habit Why We Do What We Do in Life and Business Charles Duhigg (2012)
httpwwwslideshareneta2zpharmscipharmaceutical-culture-of-quality
What does it take to come out of the cGMP crisis
Persuasive demonstration of
(1) Ability to face facts
(2) Legal amp regulatory requirements
3) Systems approach to quality
4) Changing behavior amp culture
What is often missed or is unconvincing is how you will strengthen culture of quality
ldquoLet one who wants to move and convince others first be convinced and moved themselvesrdquo Thomas Carlyle
Signals that question the competence motivation andor integrity of company personnel
Do not defend the plainly indefensible it adds further serious credibility costs
3142015 Ajazajazhussaincom 52
Quality is everyones responsibility
Lack of knowledge that is
the problem
If you do not know how to ask the
right question you discover nothing
If you cant describe what you
are doing as a process you dont know what youre
doing
Rational behavior requires theory
Reactive behavior requires only reflex
action
Whenever there is fear you will get wrong figures
3142015 Ajazajazhussaincom 53
Selected quotes W Edwards Deming
3142015 Ajazajazhussaincom 54
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
ldquoWE CANNOT CHANGE THE HUMAN CONDITION BUThellipWE CAN CHANGE THE CONDITIONS UNDER WHICH HUMANS WORKrdquo JAMES REASON
Disregard to Malice
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 55
ldquohelliprecords not completed
contemporaneouslyrdquo
ldquohellipobserved analyst back-date logbooksrdquo
ldquohelliptrial injectionshelliprdquo
ldquohellipresults failing specifications are
retested until acceptable results are obtainedhelliprdquo
ldquohellipover-writing electronic raw datahelliprdquo
ldquohellipOOS not investigates per XYZ SOPrdquo
ldquohellipappropriate controls not establishedhelliprdquo
Each additional observation adds
reasons to confirm that this is very likely a system
with intentional lsquoholesrsquo in its
defenses
Preconditions
Rationalization amp Attitude
Pressure amp Incentive
Opportunity ndashlsquoholes in the QMSrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 56
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 57
Attitude towards the behavior
Subjective norm
Perceived behavioral
control
IntentionFuture
Behavior
usually found to predict behavioral intentions with a high degree of accuracy
intentions in combination with perceived behavioral control can account for a considerable proportion of variance in behavior
PastBehavior
Ajen I The theory of planned behavior ORGANIZATIONAL BEHAVIOR AND HUMAN DECISION PROCESSES 50 179-211 (1991)
Heparin tragedy 2007 and 2008
FDA reports 149 deaths with allergic or hypersensitivity symptoms during that period
bull Contaminated heparin from China
QC Testing
bull Initial testing failed to detect the contaminant
Pharmacovigilence
bull Signals in the pharmacovigilence systems responded slowly and
Eventually the severity of reactions associated made it likely that the contamination would be detected
bull too late for those who died or were injured
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 58
Congressman Shimkus When the drug safety system fails people get sick Some die
bull Some of these people are already very vulnerable and proving the cause of harm from impurities adulteration and counterfeits can be elusive
It is hard to detect harm
bull Certainly the companies are obligated to ensure a culture of quality and maintain vigilance as well This reflects a systems approach to safety
FDA inspectors look for a culture of quality at
manufacturing facilities
bull FDA policies led to the failure to inspect the Chinese plantThis system approach wasnt at
play here
bull While it doesnt deny the counterfeit source tries to say that counterfeits didnt cause the reaction as if the adulteration itself was no big deal Is this an acceptable mindset helliphelliphellip
This brings me to China and its quality culture or lack thereof
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 59
ONE HUNDRED TENTH CONGRESS SECOND SESSION APRIL 29 2008 Serial No 110-109
21 CFR PART 211 SUBPARTS -Deviations signal gaps in CoQ
bullGENERAL PROVISIONSA
bullORGANIZATION AND PERSONNELB
bullBUILDINGS AND FACILITIESC
bullEQUIPMENTD
bullCONTROL OF COMPONENTS AND DRUG PRODUCT CONTAINERS AND CLOSURESE
bullPRODUCTION AND PROCESS CONTROLSF
bullPACKAGING AND LABELING CONTROLG
bullHOLDING AND DISTRIBUTIONH
bullLABORATORY CONTROLSI
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 60
For example the combinationhellip
The Power of Habit Why We Do What We Do in Life and Business Charles Duhigg (2012)
bull Scientific methodology
bull Engineering Design
bull Plan-Do-Check-ActConsciously
bull Habits (work to get rid of bad ones)
bull Habits (work to cultivate good one)
bull Keystone habits (Safety Alcoa ALCOA of data integrity)
Subconsciously
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 61
CoQ How
bull What are the predictors of CoQCoQ Manifests by Design -
lsquoquality by designrsquo the foundation
bull 1 2 3When do people change their behaviors
bull A B C D (any body can dance)What makes a QMS effective
bull X Y ZWhen proactive compliance occurs
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 62
Going beyond rules pays
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 63
Human behavior Connecting the Dots With the Right Connectors
GXPs ndash rational behaviors
How proactive compliance is achieved X Y Z
Quality Management System
What makes a QMS reliable A B C D
Culture of Quality
Why people change their behavior 1 2 3
Human Behaviors Beyond GXPs
Predictors of Culture of Quality
Why What and How of Culture of Quality
9192014 copy Ajaz S Hussain | INSIGHT ADVICE amp SOLUTIONS LLC 64
Predictors of CoQ Act consciously in the interest of patients ndash when no one is looking
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 65
Only four attributes
actually predict a culture of
quality
Leadership Emphasis
Message Credibility
Peer Involvement
Employee Empower-ment
People will change their
behavior if they see the new behavior as
Normal
(1)
Rewarding
(2)
Easy
(3)
Dr W Edwards Demingrsquos - ldquoOut of the crisisrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 66
The journey requires leadership
with Profound Knowledge as a
guide
bull As leaders responsible for system change top management is most in need of profound knowledge
bull Quality is often determined in the boardroom
bull Problems arise when management reacts to common cause or chance variation as if it were special cause variation
bull Prediction based in theory provides a foundation for planning a course of action Plan ndash Do ndash Check ndash Act
bull The leader serves the people with clear vision and guidance to empower them To be empowered is to share ownership in the identity
bull Giving people a certain degree of control over their work fulfills the need for freedom and provides opportunity for taking joy in work
Profound Knowledge as a guide
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 67
Appreciation for a System
Theory of Knowledge
Knowledge about
Variation
Human Behavior -Psychology of Change
A
B
C
D+
Systems Approach for ErrorDeviation Management
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 68
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
Human error models and management J Reason BMJ 320 768ndash770 (2000)
D+
Culture of Error Management परबधनbull Error strain
bull Covering upFear of Errors
bull Anticipation
bull Risk takingAwareness
bull Development QbDRFT
bull Error detection Communication
bull Analyzing errors Correction
Mastery orientation
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 69
Dots amp Connections
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 70
CoQ
1
2
3
QMS
A
B
C
D
GXP Behaviors
X
Y
Z
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 71
Culture of Quality
Normal
Rewarding
Easy
QMS
System
Knowledge
Variation
Behavior
Behavior -GXPs
Fear Removed
Mastery
Awareness
EnvironmentLeadership Emphasis
Message Credibility
Peer Involvement
Employee Empowerment
Connect to CoQ
Connect to GXPs
A Framework and a Tool (for gap analysis)
FDA CDER OPQ Plans for Surveillance of Pharmaceutical Quality
Teresa Mullin PhD December 2014
3122015 Ajaz S Hussain PhD 25
Need for a comprehensive (excipient) knowledge base
Teresa Mullin PhD December 2014
3122015 Ajaz S Hussain PhD 26
Why attention to (excipient) knowledge management is criticalSpecifically for physical attributes functionality performance
3122015 Ajaz S Hussain PhD 27
3122015 Ajaz S Hussain PhD 28
Today there are several product categories (eg controlled release inhalation products DPIrsquos topical transdermal liposomal products etc) which requires an exquisite control of complex physical material and product attributes (functionality)
Many of our current measurement systems need improvement
We depend on these to ensure control of lot-lot variability
Measurement system capability must be confirmed to be able to assess process capability (calibration amp Gauge RampR)
Life-cycle approach to quality continued process verification (FDArsquos Process Validation 2011) is a safety net
Supplier amp Excipient Qualification amp Process Validation
Measurement System Analysis
bull From lsquocalibrationrsquo to lsquoGauge RampRrsquoParticularly for physical
attributes destructive analysis
bull Many (including regulators) have not yet understood its importance
Gauge RampR well established but not commonly practiced
bull Measurement system in a state of control effective CAPA quality metrics Culture of Quality
With the move towards Statistical Process Control
bull Demonstrate equivalent in vitro performance more exacting criteria
Development of complex generic products (ER
Injectable Inhalation etc)
3122015 Ajaz S Hussain PhD 29
Process Validation (2011) Statistical Confidence Continued Process Verificationhellip
3122015 Ajaz S Hussain PhD 30
httpwwwslideshareneta2zpharmsciperformance-testing-pharmaceutical-quality-2004(accessed 6 December 2014)
3122015 Ajaz S Hussain PhD 31
Supplier amp Excipient Qualification amp CAPA
Out of Specification events are difficult to resolve
Excipient functionality can be a significant contributing factor
Sometimes reluctantly have to settle with - ldquoRoot cause unknown
600 days
I have inserted the ldquo600 daysrsquo on the figure ndash this is based on cases I have seen while at FDA)
3122015 Ajaz S Hussain PhD 32
Prevention of OOS and Effective CAPA needs a focus on critical functional attributes
Out of Specification events are difficult to resolve
Excipient functionality can be a significant contributing factor
Sometimes reluctantly have to settle with - ldquoRoot cause unknown
Compendial standards and manufacturing
3122015 Ajaz S Hussain PhD 33
Practice Control Process Maturity
Initial
bull Unpredictable
Managed
bull Characterized but reactive
Defined
bull Characterized proactive
Measured amp Controlled
bull In control
Optimizing
bull Focus on improvement
3122015 Ajaz S Hussain PhD 34
Capability Maturity Model Integration Carnegie Mellon University
A validated process
Maturity Level amp Assurance of Quality
Managed Characterized but reactive
High perceived risk of
lsquoCheating by Designrsquo
ldquoTrial Injectionsrdquo
ldquoTesting in to Compliancerdquo
Defined Characterized proactive
Lower level of assurance
Stopping amp Correcting
Batch Rejection
Measured amp
ControlledIn control
Quality by Design
Quality Assured
Improvement Opportunities
3122015 Ajaz S Hussain PhD 35
At the individual level in QC functionndash how often does this occur
attitude toward
performing the behavior
Process validation is
done so quality is good
test prone to error
ldquoBatch failure means I made
a mistakerdquo
subjective norm
documentation not critical
Compendial testing
sufficient
Indian regulators
collect amp test samples ndash no issue there
3122015 Ajaz S Hussain PhD 36
ldquoTesting into compliancerdquo
In general ndash low empowerment is a significant challenge (low perceived behavioral control) plus reasons to rationalizehellip
Excipient Functionality Can be critical for safety efficacy and quality
3122015 Ajaz S Hussain PhD 37
July 15 2005 FDA Public Health Advisory Safety Warnings Regarding Use of Fentanyl Transdermal (Skin) Patches
A pattern of failure Pharmaceutical Equivalence by Design (2004)
3122015 Ajaz S Hussain PhD 38
httpwwwnihsgojpdrugPhForumdocuments041122Hussain041122pdf
An attempt to correct
3122015 Ajaz S Hussain PhD 39
httpipecamericasorgsystemfilesKeyNoteEF13May11LawrenceYu(FDA)pdf
Recent challenges
3122015 Ajaz S Hussain PhD 40
Th
e V
oic
e o
f th
eA
mer
ican
P
sych
iatr
ic A
sso
ciat
ion
and
th
e P
sych
iatr
ic C
om
mu
nit
y
Physicians Question FDAs Confidence in Generic Drugs Safety Efficacy (OCTOBER 24 2014)
bull ldquomost patientsrdquo is not the same asldquo all patientsrdquo and whether the 24 to 36 normal subjects used in the agencys bioequivalency tests represents the full range of individual variation in the way drugs are absorbed across the pharmaceutical using population is uncertain
bull Individuals can sometimes be allergic and react differently to whatever substance goes into making up the capsule or the tablet
FDA Flags Generic Versions of ADHD Medication(NOVEMBER 14 2014)
bull FDA changed the therapeutic equivalence (TE) rating from AB to BXmdashmeaning that the products are still approved and can be prescribed but are no longer recommended as automatic substitutes
RLD Variability Can be a block-buster opportunityFocus on lsquocontrol strategyrsquo
bull Overcoming CP amp IP provide FDA a submission they need to address CP
bull Then begin with QTPP CQArsquos hellip skip lsquodesign spacersquo and focus on lsquocontrol strategy
bull The entire development team should read the complete package insert of RLD
bull Discuss to ensure a common understandingbull Failure modes amp intended use
bull Pharmaceutical Equivalence
bull Bioequivalence
bull Other studies
QbD Challenges
3122015 Ajaz S Hussain PhD 41
NewRegulators are not prepared to handle QbD applications
NewMisalignment of international regulatory authorities
New and Generics
RampD incentivized for lsquoshots on the goalrsquo not QbD
GenericsLack of belief in business case ndash lsquoGenerics are all about file first figure out laterrsquo
Biologics Lack of technology to execute
Ted Fuhr Mackinsey amp Company June 2010 FDA Advisory Committee
Summary
bull Excipient functionality can contribute in critical ways to product quality amp performance adequate control is necessary
bull Our databases tools and knowledge are lagging behind the rapidly increasing complexity and uncertainty
bull Risk to quality and to business is increasing and regulatory transitions pose additional difficulties
bull Effective knowledge management ndash IT and Human practices ndash is critical for organizational lsquobottom-linersquo
bull We all must come together collaboratively to address the urgent needs we owe it to the patients we serve
3122015 Ajaz S Hussain PhD 42
Knowledge Management amp Culture of Quality
Ajaz S Hussain PhD
Insight Advice amp Solutions LLCMaryland USA
Executive Director the National Institute for Pharmaceutical Technology amp Education
3122015 Ajaz S Hussain PhD 43
3122015 Ajaz S Hussain PhD 44
Life-cycle approach needed for knowledge management
Investigational ProductscGMPs
DevelopmentTechnology
TransferCommercial
ManufacturingDiscontinuation
Management Responsibility
Process Performance amp Product Quality Monitoring SystemCAPA Change Management Management Review
PQS Elements
Knowledge ManagementQuality Risk ManagementEnablers
ICH Q10 KM is a systematic approach to acquiring analyzing storing and disseminating information related to products manufacturing processes and components
Based on ICH Q10
ldquowe can be blind to the obvious and we are also blind to our blindnessrdquo
Daniel Kahneman Thinking Fast and Slow
3142015 Ajazajazhussaincom 45
httpwebmiteduperscipeopleadelsoncheckershadow_proofhtml
3122015 Ajaz S Hussain PhD 46
1938 The Federal Food Drug and Cosmetic (FDC)
bull 1937 Elixir of Sulfanilamide
1962 Kefauver-Harris Drug Amendments
bull 1962 Thalidomide
bull 1960 Color Additive Amendment
bull 1958 Food Additives Amendment GRAS
bull 1960 Color Additive Amendment
bull 1958 Food Additives Amendment GRAS
1992 Generic Drug Enforcement Act
bull1989 L-Tryptophan
bull 1989 Generic Drug Scandal
bull 1988 Food and Drug Administration Act
bull 1984 Fines Enhancement Laws Drug Price Competition and Patent Term Restoration Act
2012 Food and Drug Administration Safety and Innovation Act (FDASIA)
bull 2007 Heparin Disaster
2013 Pandemic and All-Hazards Preparedness Reauthorization Act (PAHPRA) Drug Quality and Security Act
bull 2012 The Deadly Meningitis Outbreak
Past 70 years 1937 ndash 2007 The diethylene glycol (DEG) narrative
3122015 Ajaz S Hussain PhD 47
0
5
10
15
20
25
30
35
Yea
rs
DEG Years since the previous incident
0
50
100
150
200
250
300
350
Number of Reported Deaths
1937
Eli
xir
of
Sulf
anil
amid
e
2007T
ootp
aste
conta
min
atio
n
0 70 years 0 70 years
Frequent reports
Mumbai Mumbai
Data from Excipient Fest Janeen Skutnik Chair ndashIPECAmericas 2009
Past 70+ years DEG contamination or economically motivated adulteration
3122015 Ajaz S Hussain PhD 48
Reported cases underestimate the real tragedy rapid intervention may not occur
Epidemic of Pediatric Deaths From Acute Renal Failure Caused by
Diethylene Glycol Poisoning JAMA 1998279(15)1175-1180
doi101001jama279151175
Month of hospital admission for children with
acute renal failure Haiti
October 1995-October 1996
Diethylene glycol poisoning in Gurgaon India 1998Bulletin of the World Health Organization 2001 79 88ndash95
We report a second episode of poisoning occurring in 1998 in
India as a result of children ingesting diethylene glycol at
least 33 children are known to have died
At the beginning of the investigation we never imagined that
contaminated medicine was causing acute renal failure in
children
A brand of cough expectorant manufactured by a local
pharmaceutical company was found by the Central Drugs
Laboratory Calcutta to contain 175 (vv) diethylene
glycol
The district and state drug controller had tested many
samples using thin layer chromatography before a sample of
medicine tested positive for diethylene glycol at the Central
Drugs Laboratory None of the earlier samples was found to
be contaminated
3122015 Ajaz S Hussain PhD 49
Guidance for Industry Testing of
Glycerin for Diethylene Glycol
CDER May 2007 Compliance
1 Manufacturers did not perform full
identity testing on the glycerin raw
material including tests to quantify
the amount of DEG
2 Relied on the certificate of analysis
(COA)
3 The origin of the glycerin was not
easily apparent from the COA
4 The COA was often a copy of a COA
on the letterhead of the distributor
5 The chain of custody or distribution
history of the glycerin was also not
readily known
USP Glycerin Monograph
Type of Posting Revision Bulletin
Posting Date 04ndashFebndash2009
Official Date 01ndashMayndash2009
Because of the serious hazards
associated withhellip and in response to
recommendations set forth in the
FDA Guidance for Industry Testing
of Glycerin for Diethylene Glycol
published in May 2007 USP has
revised the USP Glycerin monograph
Because diethylene glycol and
ethylene glycol are considered
unacceptable toxic substances the
testing of USP Glycerin should
demonstrate the absence of these
substances
April 2007 FDA request to
USP to revise the Glycerin
monographrsquos
IDENTIFICATION section
Revision includes adding ndash
Identification test B LIMIT OF
DIETHYLENE GLYCOL AND
ETHYLENE GLYCOL to detect
and quantify DEGEG in Glycerin
minus Is no longer part of the impurity
testing
ldquoLimit of DEG and Related
Compoundsrdquo minus Introduces a
capillary gas-chromatographic
(GC) method with flame ionization
detection (FID) minus Limit of NMT
010 each for diethylene glycol
and ethylene glycol is found
70+ years to get here how difficult will it be to change habits such as lsquoblind reliance of COArsquo
3122015 Ajaz S Hussain PhD 50
Personality and Habitual Frame Biases
Myers Brigs ENTJ (first tested at FDA)
S
TF
Expanded frame
future
possibilities
objective lsquocause
and effectrsquo
Expanded frame
future
possibilities
people and
relationships
Narrow frame
the present
individuals and
relationships
Narrow frame
the present
objective
cause and
effect
N
Based on Stanford Webinar - How to Overcome the Top 3 MegaBiases in Decision-Making
Stanford Universityrsquos Strategic Decision and Risk Management certificate program
From Mapping a Managers Brain on Incentives
Social
influences
Relative
thinking
UncertaintyComplexity
By Design Intention to act consciously
bull In the interest of patients and to continually improve this ability bull To provide a healing touch ndash one life at a time in what we do and how we
do it
1292014 Ajazajazhussaincom 51
Consciously
Scientific methodology
Engineering Design
Plan-Do-Check-Act
Subconsciously
Habits (work to get rid of bad ones)
Habits (work to cultivate good one)
Keystone habits (Safety Alcoa ALCOA of data integrity)
The Power of Habit Why We Do What We Do in Life and Business Charles Duhigg (2012)
httpwwwslideshareneta2zpharmscipharmaceutical-culture-of-quality
What does it take to come out of the cGMP crisis
Persuasive demonstration of
(1) Ability to face facts
(2) Legal amp regulatory requirements
3) Systems approach to quality
4) Changing behavior amp culture
What is often missed or is unconvincing is how you will strengthen culture of quality
ldquoLet one who wants to move and convince others first be convinced and moved themselvesrdquo Thomas Carlyle
Signals that question the competence motivation andor integrity of company personnel
Do not defend the plainly indefensible it adds further serious credibility costs
3142015 Ajazajazhussaincom 52
Quality is everyones responsibility
Lack of knowledge that is
the problem
If you do not know how to ask the
right question you discover nothing
If you cant describe what you
are doing as a process you dont know what youre
doing
Rational behavior requires theory
Reactive behavior requires only reflex
action
Whenever there is fear you will get wrong figures
3142015 Ajazajazhussaincom 53
Selected quotes W Edwards Deming
3142015 Ajazajazhussaincom 54
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
ldquoWE CANNOT CHANGE THE HUMAN CONDITION BUThellipWE CAN CHANGE THE CONDITIONS UNDER WHICH HUMANS WORKrdquo JAMES REASON
Disregard to Malice
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 55
ldquohelliprecords not completed
contemporaneouslyrdquo
ldquohellipobserved analyst back-date logbooksrdquo
ldquohelliptrial injectionshelliprdquo
ldquohellipresults failing specifications are
retested until acceptable results are obtainedhelliprdquo
ldquohellipover-writing electronic raw datahelliprdquo
ldquohellipOOS not investigates per XYZ SOPrdquo
ldquohellipappropriate controls not establishedhelliprdquo
Each additional observation adds
reasons to confirm that this is very likely a system
with intentional lsquoholesrsquo in its
defenses
Preconditions
Rationalization amp Attitude
Pressure amp Incentive
Opportunity ndashlsquoholes in the QMSrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 56
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 57
Attitude towards the behavior
Subjective norm
Perceived behavioral
control
IntentionFuture
Behavior
usually found to predict behavioral intentions with a high degree of accuracy
intentions in combination with perceived behavioral control can account for a considerable proportion of variance in behavior
PastBehavior
Ajen I The theory of planned behavior ORGANIZATIONAL BEHAVIOR AND HUMAN DECISION PROCESSES 50 179-211 (1991)
Heparin tragedy 2007 and 2008
FDA reports 149 deaths with allergic or hypersensitivity symptoms during that period
bull Contaminated heparin from China
QC Testing
bull Initial testing failed to detect the contaminant
Pharmacovigilence
bull Signals in the pharmacovigilence systems responded slowly and
Eventually the severity of reactions associated made it likely that the contamination would be detected
bull too late for those who died or were injured
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 58
Congressman Shimkus When the drug safety system fails people get sick Some die
bull Some of these people are already very vulnerable and proving the cause of harm from impurities adulteration and counterfeits can be elusive
It is hard to detect harm
bull Certainly the companies are obligated to ensure a culture of quality and maintain vigilance as well This reflects a systems approach to safety
FDA inspectors look for a culture of quality at
manufacturing facilities
bull FDA policies led to the failure to inspect the Chinese plantThis system approach wasnt at
play here
bull While it doesnt deny the counterfeit source tries to say that counterfeits didnt cause the reaction as if the adulteration itself was no big deal Is this an acceptable mindset helliphelliphellip
This brings me to China and its quality culture or lack thereof
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 59
ONE HUNDRED TENTH CONGRESS SECOND SESSION APRIL 29 2008 Serial No 110-109
21 CFR PART 211 SUBPARTS -Deviations signal gaps in CoQ
bullGENERAL PROVISIONSA
bullORGANIZATION AND PERSONNELB
bullBUILDINGS AND FACILITIESC
bullEQUIPMENTD
bullCONTROL OF COMPONENTS AND DRUG PRODUCT CONTAINERS AND CLOSURESE
bullPRODUCTION AND PROCESS CONTROLSF
bullPACKAGING AND LABELING CONTROLG
bullHOLDING AND DISTRIBUTIONH
bullLABORATORY CONTROLSI
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 60
For example the combinationhellip
The Power of Habit Why We Do What We Do in Life and Business Charles Duhigg (2012)
bull Scientific methodology
bull Engineering Design
bull Plan-Do-Check-ActConsciously
bull Habits (work to get rid of bad ones)
bull Habits (work to cultivate good one)
bull Keystone habits (Safety Alcoa ALCOA of data integrity)
Subconsciously
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 61
CoQ How
bull What are the predictors of CoQCoQ Manifests by Design -
lsquoquality by designrsquo the foundation
bull 1 2 3When do people change their behaviors
bull A B C D (any body can dance)What makes a QMS effective
bull X Y ZWhen proactive compliance occurs
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 62
Going beyond rules pays
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 63
Human behavior Connecting the Dots With the Right Connectors
GXPs ndash rational behaviors
How proactive compliance is achieved X Y Z
Quality Management System
What makes a QMS reliable A B C D
Culture of Quality
Why people change their behavior 1 2 3
Human Behaviors Beyond GXPs
Predictors of Culture of Quality
Why What and How of Culture of Quality
9192014 copy Ajaz S Hussain | INSIGHT ADVICE amp SOLUTIONS LLC 64
Predictors of CoQ Act consciously in the interest of patients ndash when no one is looking
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 65
Only four attributes
actually predict a culture of
quality
Leadership Emphasis
Message Credibility
Peer Involvement
Employee Empower-ment
People will change their
behavior if they see the new behavior as
Normal
(1)
Rewarding
(2)
Easy
(3)
Dr W Edwards Demingrsquos - ldquoOut of the crisisrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 66
The journey requires leadership
with Profound Knowledge as a
guide
bull As leaders responsible for system change top management is most in need of profound knowledge
bull Quality is often determined in the boardroom
bull Problems arise when management reacts to common cause or chance variation as if it were special cause variation
bull Prediction based in theory provides a foundation for planning a course of action Plan ndash Do ndash Check ndash Act
bull The leader serves the people with clear vision and guidance to empower them To be empowered is to share ownership in the identity
bull Giving people a certain degree of control over their work fulfills the need for freedom and provides opportunity for taking joy in work
Profound Knowledge as a guide
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 67
Appreciation for a System
Theory of Knowledge
Knowledge about
Variation
Human Behavior -Psychology of Change
A
B
C
D+
Systems Approach for ErrorDeviation Management
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 68
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
Human error models and management J Reason BMJ 320 768ndash770 (2000)
D+
Culture of Error Management परबधनbull Error strain
bull Covering upFear of Errors
bull Anticipation
bull Risk takingAwareness
bull Development QbDRFT
bull Error detection Communication
bull Analyzing errors Correction
Mastery orientation
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 69
Dots amp Connections
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 70
CoQ
1
2
3
QMS
A
B
C
D
GXP Behaviors
X
Y
Z
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 71
Culture of Quality
Normal
Rewarding
Easy
QMS
System
Knowledge
Variation
Behavior
Behavior -GXPs
Fear Removed
Mastery
Awareness
EnvironmentLeadership Emphasis
Message Credibility
Peer Involvement
Employee Empowerment
Connect to CoQ
Connect to GXPs
A Framework and a Tool (for gap analysis)
Need for a comprehensive (excipient) knowledge base
Teresa Mullin PhD December 2014
3122015 Ajaz S Hussain PhD 26
Why attention to (excipient) knowledge management is criticalSpecifically for physical attributes functionality performance
3122015 Ajaz S Hussain PhD 27
3122015 Ajaz S Hussain PhD 28
Today there are several product categories (eg controlled release inhalation products DPIrsquos topical transdermal liposomal products etc) which requires an exquisite control of complex physical material and product attributes (functionality)
Many of our current measurement systems need improvement
We depend on these to ensure control of lot-lot variability
Measurement system capability must be confirmed to be able to assess process capability (calibration amp Gauge RampR)
Life-cycle approach to quality continued process verification (FDArsquos Process Validation 2011) is a safety net
Supplier amp Excipient Qualification amp Process Validation
Measurement System Analysis
bull From lsquocalibrationrsquo to lsquoGauge RampRrsquoParticularly for physical
attributes destructive analysis
bull Many (including regulators) have not yet understood its importance
Gauge RampR well established but not commonly practiced
bull Measurement system in a state of control effective CAPA quality metrics Culture of Quality
With the move towards Statistical Process Control
bull Demonstrate equivalent in vitro performance more exacting criteria
Development of complex generic products (ER
Injectable Inhalation etc)
3122015 Ajaz S Hussain PhD 29
Process Validation (2011) Statistical Confidence Continued Process Verificationhellip
3122015 Ajaz S Hussain PhD 30
httpwwwslideshareneta2zpharmsciperformance-testing-pharmaceutical-quality-2004(accessed 6 December 2014)
3122015 Ajaz S Hussain PhD 31
Supplier amp Excipient Qualification amp CAPA
Out of Specification events are difficult to resolve
Excipient functionality can be a significant contributing factor
Sometimes reluctantly have to settle with - ldquoRoot cause unknown
600 days
I have inserted the ldquo600 daysrsquo on the figure ndash this is based on cases I have seen while at FDA)
3122015 Ajaz S Hussain PhD 32
Prevention of OOS and Effective CAPA needs a focus on critical functional attributes
Out of Specification events are difficult to resolve
Excipient functionality can be a significant contributing factor
Sometimes reluctantly have to settle with - ldquoRoot cause unknown
Compendial standards and manufacturing
3122015 Ajaz S Hussain PhD 33
Practice Control Process Maturity
Initial
bull Unpredictable
Managed
bull Characterized but reactive
Defined
bull Characterized proactive
Measured amp Controlled
bull In control
Optimizing
bull Focus on improvement
3122015 Ajaz S Hussain PhD 34
Capability Maturity Model Integration Carnegie Mellon University
A validated process
Maturity Level amp Assurance of Quality
Managed Characterized but reactive
High perceived risk of
lsquoCheating by Designrsquo
ldquoTrial Injectionsrdquo
ldquoTesting in to Compliancerdquo
Defined Characterized proactive
Lower level of assurance
Stopping amp Correcting
Batch Rejection
Measured amp
ControlledIn control
Quality by Design
Quality Assured
Improvement Opportunities
3122015 Ajaz S Hussain PhD 35
At the individual level in QC functionndash how often does this occur
attitude toward
performing the behavior
Process validation is
done so quality is good
test prone to error
ldquoBatch failure means I made
a mistakerdquo
subjective norm
documentation not critical
Compendial testing
sufficient
Indian regulators
collect amp test samples ndash no issue there
3122015 Ajaz S Hussain PhD 36
ldquoTesting into compliancerdquo
In general ndash low empowerment is a significant challenge (low perceived behavioral control) plus reasons to rationalizehellip
Excipient Functionality Can be critical for safety efficacy and quality
3122015 Ajaz S Hussain PhD 37
July 15 2005 FDA Public Health Advisory Safety Warnings Regarding Use of Fentanyl Transdermal (Skin) Patches
A pattern of failure Pharmaceutical Equivalence by Design (2004)
3122015 Ajaz S Hussain PhD 38
httpwwwnihsgojpdrugPhForumdocuments041122Hussain041122pdf
An attempt to correct
3122015 Ajaz S Hussain PhD 39
httpipecamericasorgsystemfilesKeyNoteEF13May11LawrenceYu(FDA)pdf
Recent challenges
3122015 Ajaz S Hussain PhD 40
Th
e V
oic
e o
f th
eA
mer
ican
P
sych
iatr
ic A
sso
ciat
ion
and
th
e P
sych
iatr
ic C
om
mu
nit
y
Physicians Question FDAs Confidence in Generic Drugs Safety Efficacy (OCTOBER 24 2014)
bull ldquomost patientsrdquo is not the same asldquo all patientsrdquo and whether the 24 to 36 normal subjects used in the agencys bioequivalency tests represents the full range of individual variation in the way drugs are absorbed across the pharmaceutical using population is uncertain
bull Individuals can sometimes be allergic and react differently to whatever substance goes into making up the capsule or the tablet
FDA Flags Generic Versions of ADHD Medication(NOVEMBER 14 2014)
bull FDA changed the therapeutic equivalence (TE) rating from AB to BXmdashmeaning that the products are still approved and can be prescribed but are no longer recommended as automatic substitutes
RLD Variability Can be a block-buster opportunityFocus on lsquocontrol strategyrsquo
bull Overcoming CP amp IP provide FDA a submission they need to address CP
bull Then begin with QTPP CQArsquos hellip skip lsquodesign spacersquo and focus on lsquocontrol strategy
bull The entire development team should read the complete package insert of RLD
bull Discuss to ensure a common understandingbull Failure modes amp intended use
bull Pharmaceutical Equivalence
bull Bioequivalence
bull Other studies
QbD Challenges
3122015 Ajaz S Hussain PhD 41
NewRegulators are not prepared to handle QbD applications
NewMisalignment of international regulatory authorities
New and Generics
RampD incentivized for lsquoshots on the goalrsquo not QbD
GenericsLack of belief in business case ndash lsquoGenerics are all about file first figure out laterrsquo
Biologics Lack of technology to execute
Ted Fuhr Mackinsey amp Company June 2010 FDA Advisory Committee
Summary
bull Excipient functionality can contribute in critical ways to product quality amp performance adequate control is necessary
bull Our databases tools and knowledge are lagging behind the rapidly increasing complexity and uncertainty
bull Risk to quality and to business is increasing and regulatory transitions pose additional difficulties
bull Effective knowledge management ndash IT and Human practices ndash is critical for organizational lsquobottom-linersquo
bull We all must come together collaboratively to address the urgent needs we owe it to the patients we serve
3122015 Ajaz S Hussain PhD 42
Knowledge Management amp Culture of Quality
Ajaz S Hussain PhD
Insight Advice amp Solutions LLCMaryland USA
Executive Director the National Institute for Pharmaceutical Technology amp Education
3122015 Ajaz S Hussain PhD 43
3122015 Ajaz S Hussain PhD 44
Life-cycle approach needed for knowledge management
Investigational ProductscGMPs
DevelopmentTechnology
TransferCommercial
ManufacturingDiscontinuation
Management Responsibility
Process Performance amp Product Quality Monitoring SystemCAPA Change Management Management Review
PQS Elements
Knowledge ManagementQuality Risk ManagementEnablers
ICH Q10 KM is a systematic approach to acquiring analyzing storing and disseminating information related to products manufacturing processes and components
Based on ICH Q10
ldquowe can be blind to the obvious and we are also blind to our blindnessrdquo
Daniel Kahneman Thinking Fast and Slow
3142015 Ajazajazhussaincom 45
httpwebmiteduperscipeopleadelsoncheckershadow_proofhtml
3122015 Ajaz S Hussain PhD 46
1938 The Federal Food Drug and Cosmetic (FDC)
bull 1937 Elixir of Sulfanilamide
1962 Kefauver-Harris Drug Amendments
bull 1962 Thalidomide
bull 1960 Color Additive Amendment
bull 1958 Food Additives Amendment GRAS
bull 1960 Color Additive Amendment
bull 1958 Food Additives Amendment GRAS
1992 Generic Drug Enforcement Act
bull1989 L-Tryptophan
bull 1989 Generic Drug Scandal
bull 1988 Food and Drug Administration Act
bull 1984 Fines Enhancement Laws Drug Price Competition and Patent Term Restoration Act
2012 Food and Drug Administration Safety and Innovation Act (FDASIA)
bull 2007 Heparin Disaster
2013 Pandemic and All-Hazards Preparedness Reauthorization Act (PAHPRA) Drug Quality and Security Act
bull 2012 The Deadly Meningitis Outbreak
Past 70 years 1937 ndash 2007 The diethylene glycol (DEG) narrative
3122015 Ajaz S Hussain PhD 47
0
5
10
15
20
25
30
35
Yea
rs
DEG Years since the previous incident
0
50
100
150
200
250
300
350
Number of Reported Deaths
1937
Eli
xir
of
Sulf
anil
amid
e
2007T
ootp
aste
conta
min
atio
n
0 70 years 0 70 years
Frequent reports
Mumbai Mumbai
Data from Excipient Fest Janeen Skutnik Chair ndashIPECAmericas 2009
Past 70+ years DEG contamination or economically motivated adulteration
3122015 Ajaz S Hussain PhD 48
Reported cases underestimate the real tragedy rapid intervention may not occur
Epidemic of Pediatric Deaths From Acute Renal Failure Caused by
Diethylene Glycol Poisoning JAMA 1998279(15)1175-1180
doi101001jama279151175
Month of hospital admission for children with
acute renal failure Haiti
October 1995-October 1996
Diethylene glycol poisoning in Gurgaon India 1998Bulletin of the World Health Organization 2001 79 88ndash95
We report a second episode of poisoning occurring in 1998 in
India as a result of children ingesting diethylene glycol at
least 33 children are known to have died
At the beginning of the investigation we never imagined that
contaminated medicine was causing acute renal failure in
children
A brand of cough expectorant manufactured by a local
pharmaceutical company was found by the Central Drugs
Laboratory Calcutta to contain 175 (vv) diethylene
glycol
The district and state drug controller had tested many
samples using thin layer chromatography before a sample of
medicine tested positive for diethylene glycol at the Central
Drugs Laboratory None of the earlier samples was found to
be contaminated
3122015 Ajaz S Hussain PhD 49
Guidance for Industry Testing of
Glycerin for Diethylene Glycol
CDER May 2007 Compliance
1 Manufacturers did not perform full
identity testing on the glycerin raw
material including tests to quantify
the amount of DEG
2 Relied on the certificate of analysis
(COA)
3 The origin of the glycerin was not
easily apparent from the COA
4 The COA was often a copy of a COA
on the letterhead of the distributor
5 The chain of custody or distribution
history of the glycerin was also not
readily known
USP Glycerin Monograph
Type of Posting Revision Bulletin
Posting Date 04ndashFebndash2009
Official Date 01ndashMayndash2009
Because of the serious hazards
associated withhellip and in response to
recommendations set forth in the
FDA Guidance for Industry Testing
of Glycerin for Diethylene Glycol
published in May 2007 USP has
revised the USP Glycerin monograph
Because diethylene glycol and
ethylene glycol are considered
unacceptable toxic substances the
testing of USP Glycerin should
demonstrate the absence of these
substances
April 2007 FDA request to
USP to revise the Glycerin
monographrsquos
IDENTIFICATION section
Revision includes adding ndash
Identification test B LIMIT OF
DIETHYLENE GLYCOL AND
ETHYLENE GLYCOL to detect
and quantify DEGEG in Glycerin
minus Is no longer part of the impurity
testing
ldquoLimit of DEG and Related
Compoundsrdquo minus Introduces a
capillary gas-chromatographic
(GC) method with flame ionization
detection (FID) minus Limit of NMT
010 each for diethylene glycol
and ethylene glycol is found
70+ years to get here how difficult will it be to change habits such as lsquoblind reliance of COArsquo
3122015 Ajaz S Hussain PhD 50
Personality and Habitual Frame Biases
Myers Brigs ENTJ (first tested at FDA)
S
TF
Expanded frame
future
possibilities
objective lsquocause
and effectrsquo
Expanded frame
future
possibilities
people and
relationships
Narrow frame
the present
individuals and
relationships
Narrow frame
the present
objective
cause and
effect
N
Based on Stanford Webinar - How to Overcome the Top 3 MegaBiases in Decision-Making
Stanford Universityrsquos Strategic Decision and Risk Management certificate program
From Mapping a Managers Brain on Incentives
Social
influences
Relative
thinking
UncertaintyComplexity
By Design Intention to act consciously
bull In the interest of patients and to continually improve this ability bull To provide a healing touch ndash one life at a time in what we do and how we
do it
1292014 Ajazajazhussaincom 51
Consciously
Scientific methodology
Engineering Design
Plan-Do-Check-Act
Subconsciously
Habits (work to get rid of bad ones)
Habits (work to cultivate good one)
Keystone habits (Safety Alcoa ALCOA of data integrity)
The Power of Habit Why We Do What We Do in Life and Business Charles Duhigg (2012)
httpwwwslideshareneta2zpharmscipharmaceutical-culture-of-quality
What does it take to come out of the cGMP crisis
Persuasive demonstration of
(1) Ability to face facts
(2) Legal amp regulatory requirements
3) Systems approach to quality
4) Changing behavior amp culture
What is often missed or is unconvincing is how you will strengthen culture of quality
ldquoLet one who wants to move and convince others first be convinced and moved themselvesrdquo Thomas Carlyle
Signals that question the competence motivation andor integrity of company personnel
Do not defend the plainly indefensible it adds further serious credibility costs
3142015 Ajazajazhussaincom 52
Quality is everyones responsibility
Lack of knowledge that is
the problem
If you do not know how to ask the
right question you discover nothing
If you cant describe what you
are doing as a process you dont know what youre
doing
Rational behavior requires theory
Reactive behavior requires only reflex
action
Whenever there is fear you will get wrong figures
3142015 Ajazajazhussaincom 53
Selected quotes W Edwards Deming
3142015 Ajazajazhussaincom 54
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
ldquoWE CANNOT CHANGE THE HUMAN CONDITION BUThellipWE CAN CHANGE THE CONDITIONS UNDER WHICH HUMANS WORKrdquo JAMES REASON
Disregard to Malice
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 55
ldquohelliprecords not completed
contemporaneouslyrdquo
ldquohellipobserved analyst back-date logbooksrdquo
ldquohelliptrial injectionshelliprdquo
ldquohellipresults failing specifications are
retested until acceptable results are obtainedhelliprdquo
ldquohellipover-writing electronic raw datahelliprdquo
ldquohellipOOS not investigates per XYZ SOPrdquo
ldquohellipappropriate controls not establishedhelliprdquo
Each additional observation adds
reasons to confirm that this is very likely a system
with intentional lsquoholesrsquo in its
defenses
Preconditions
Rationalization amp Attitude
Pressure amp Incentive
Opportunity ndashlsquoholes in the QMSrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 56
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 57
Attitude towards the behavior
Subjective norm
Perceived behavioral
control
IntentionFuture
Behavior
usually found to predict behavioral intentions with a high degree of accuracy
intentions in combination with perceived behavioral control can account for a considerable proportion of variance in behavior
PastBehavior
Ajen I The theory of planned behavior ORGANIZATIONAL BEHAVIOR AND HUMAN DECISION PROCESSES 50 179-211 (1991)
Heparin tragedy 2007 and 2008
FDA reports 149 deaths with allergic or hypersensitivity symptoms during that period
bull Contaminated heparin from China
QC Testing
bull Initial testing failed to detect the contaminant
Pharmacovigilence
bull Signals in the pharmacovigilence systems responded slowly and
Eventually the severity of reactions associated made it likely that the contamination would be detected
bull too late for those who died or were injured
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 58
Congressman Shimkus When the drug safety system fails people get sick Some die
bull Some of these people are already very vulnerable and proving the cause of harm from impurities adulteration and counterfeits can be elusive
It is hard to detect harm
bull Certainly the companies are obligated to ensure a culture of quality and maintain vigilance as well This reflects a systems approach to safety
FDA inspectors look for a culture of quality at
manufacturing facilities
bull FDA policies led to the failure to inspect the Chinese plantThis system approach wasnt at
play here
bull While it doesnt deny the counterfeit source tries to say that counterfeits didnt cause the reaction as if the adulteration itself was no big deal Is this an acceptable mindset helliphelliphellip
This brings me to China and its quality culture or lack thereof
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 59
ONE HUNDRED TENTH CONGRESS SECOND SESSION APRIL 29 2008 Serial No 110-109
21 CFR PART 211 SUBPARTS -Deviations signal gaps in CoQ
bullGENERAL PROVISIONSA
bullORGANIZATION AND PERSONNELB
bullBUILDINGS AND FACILITIESC
bullEQUIPMENTD
bullCONTROL OF COMPONENTS AND DRUG PRODUCT CONTAINERS AND CLOSURESE
bullPRODUCTION AND PROCESS CONTROLSF
bullPACKAGING AND LABELING CONTROLG
bullHOLDING AND DISTRIBUTIONH
bullLABORATORY CONTROLSI
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 60
For example the combinationhellip
The Power of Habit Why We Do What We Do in Life and Business Charles Duhigg (2012)
bull Scientific methodology
bull Engineering Design
bull Plan-Do-Check-ActConsciously
bull Habits (work to get rid of bad ones)
bull Habits (work to cultivate good one)
bull Keystone habits (Safety Alcoa ALCOA of data integrity)
Subconsciously
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 61
CoQ How
bull What are the predictors of CoQCoQ Manifests by Design -
lsquoquality by designrsquo the foundation
bull 1 2 3When do people change their behaviors
bull A B C D (any body can dance)What makes a QMS effective
bull X Y ZWhen proactive compliance occurs
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 62
Going beyond rules pays
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 63
Human behavior Connecting the Dots With the Right Connectors
GXPs ndash rational behaviors
How proactive compliance is achieved X Y Z
Quality Management System
What makes a QMS reliable A B C D
Culture of Quality
Why people change their behavior 1 2 3
Human Behaviors Beyond GXPs
Predictors of Culture of Quality
Why What and How of Culture of Quality
9192014 copy Ajaz S Hussain | INSIGHT ADVICE amp SOLUTIONS LLC 64
Predictors of CoQ Act consciously in the interest of patients ndash when no one is looking
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 65
Only four attributes
actually predict a culture of
quality
Leadership Emphasis
Message Credibility
Peer Involvement
Employee Empower-ment
People will change their
behavior if they see the new behavior as
Normal
(1)
Rewarding
(2)
Easy
(3)
Dr W Edwards Demingrsquos - ldquoOut of the crisisrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 66
The journey requires leadership
with Profound Knowledge as a
guide
bull As leaders responsible for system change top management is most in need of profound knowledge
bull Quality is often determined in the boardroom
bull Problems arise when management reacts to common cause or chance variation as if it were special cause variation
bull Prediction based in theory provides a foundation for planning a course of action Plan ndash Do ndash Check ndash Act
bull The leader serves the people with clear vision and guidance to empower them To be empowered is to share ownership in the identity
bull Giving people a certain degree of control over their work fulfills the need for freedom and provides opportunity for taking joy in work
Profound Knowledge as a guide
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 67
Appreciation for a System
Theory of Knowledge
Knowledge about
Variation
Human Behavior -Psychology of Change
A
B
C
D+
Systems Approach for ErrorDeviation Management
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 68
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
Human error models and management J Reason BMJ 320 768ndash770 (2000)
D+
Culture of Error Management परबधनbull Error strain
bull Covering upFear of Errors
bull Anticipation
bull Risk takingAwareness
bull Development QbDRFT
bull Error detection Communication
bull Analyzing errors Correction
Mastery orientation
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 69
Dots amp Connections
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 70
CoQ
1
2
3
QMS
A
B
C
D
GXP Behaviors
X
Y
Z
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 71
Culture of Quality
Normal
Rewarding
Easy
QMS
System
Knowledge
Variation
Behavior
Behavior -GXPs
Fear Removed
Mastery
Awareness
EnvironmentLeadership Emphasis
Message Credibility
Peer Involvement
Employee Empowerment
Connect to CoQ
Connect to GXPs
A Framework and a Tool (for gap analysis)
Why attention to (excipient) knowledge management is criticalSpecifically for physical attributes functionality performance
3122015 Ajaz S Hussain PhD 27
3122015 Ajaz S Hussain PhD 28
Today there are several product categories (eg controlled release inhalation products DPIrsquos topical transdermal liposomal products etc) which requires an exquisite control of complex physical material and product attributes (functionality)
Many of our current measurement systems need improvement
We depend on these to ensure control of lot-lot variability
Measurement system capability must be confirmed to be able to assess process capability (calibration amp Gauge RampR)
Life-cycle approach to quality continued process verification (FDArsquos Process Validation 2011) is a safety net
Supplier amp Excipient Qualification amp Process Validation
Measurement System Analysis
bull From lsquocalibrationrsquo to lsquoGauge RampRrsquoParticularly for physical
attributes destructive analysis
bull Many (including regulators) have not yet understood its importance
Gauge RampR well established but not commonly practiced
bull Measurement system in a state of control effective CAPA quality metrics Culture of Quality
With the move towards Statistical Process Control
bull Demonstrate equivalent in vitro performance more exacting criteria
Development of complex generic products (ER
Injectable Inhalation etc)
3122015 Ajaz S Hussain PhD 29
Process Validation (2011) Statistical Confidence Continued Process Verificationhellip
3122015 Ajaz S Hussain PhD 30
httpwwwslideshareneta2zpharmsciperformance-testing-pharmaceutical-quality-2004(accessed 6 December 2014)
3122015 Ajaz S Hussain PhD 31
Supplier amp Excipient Qualification amp CAPA
Out of Specification events are difficult to resolve
Excipient functionality can be a significant contributing factor
Sometimes reluctantly have to settle with - ldquoRoot cause unknown
600 days
I have inserted the ldquo600 daysrsquo on the figure ndash this is based on cases I have seen while at FDA)
3122015 Ajaz S Hussain PhD 32
Prevention of OOS and Effective CAPA needs a focus on critical functional attributes
Out of Specification events are difficult to resolve
Excipient functionality can be a significant contributing factor
Sometimes reluctantly have to settle with - ldquoRoot cause unknown
Compendial standards and manufacturing
3122015 Ajaz S Hussain PhD 33
Practice Control Process Maturity
Initial
bull Unpredictable
Managed
bull Characterized but reactive
Defined
bull Characterized proactive
Measured amp Controlled
bull In control
Optimizing
bull Focus on improvement
3122015 Ajaz S Hussain PhD 34
Capability Maturity Model Integration Carnegie Mellon University
A validated process
Maturity Level amp Assurance of Quality
Managed Characterized but reactive
High perceived risk of
lsquoCheating by Designrsquo
ldquoTrial Injectionsrdquo
ldquoTesting in to Compliancerdquo
Defined Characterized proactive
Lower level of assurance
Stopping amp Correcting
Batch Rejection
Measured amp
ControlledIn control
Quality by Design
Quality Assured
Improvement Opportunities
3122015 Ajaz S Hussain PhD 35
At the individual level in QC functionndash how often does this occur
attitude toward
performing the behavior
Process validation is
done so quality is good
test prone to error
ldquoBatch failure means I made
a mistakerdquo
subjective norm
documentation not critical
Compendial testing
sufficient
Indian regulators
collect amp test samples ndash no issue there
3122015 Ajaz S Hussain PhD 36
ldquoTesting into compliancerdquo
In general ndash low empowerment is a significant challenge (low perceived behavioral control) plus reasons to rationalizehellip
Excipient Functionality Can be critical for safety efficacy and quality
3122015 Ajaz S Hussain PhD 37
July 15 2005 FDA Public Health Advisory Safety Warnings Regarding Use of Fentanyl Transdermal (Skin) Patches
A pattern of failure Pharmaceutical Equivalence by Design (2004)
3122015 Ajaz S Hussain PhD 38
httpwwwnihsgojpdrugPhForumdocuments041122Hussain041122pdf
An attempt to correct
3122015 Ajaz S Hussain PhD 39
httpipecamericasorgsystemfilesKeyNoteEF13May11LawrenceYu(FDA)pdf
Recent challenges
3122015 Ajaz S Hussain PhD 40
Th
e V
oic
e o
f th
eA
mer
ican
P
sych
iatr
ic A
sso
ciat
ion
and
th
e P
sych
iatr
ic C
om
mu
nit
y
Physicians Question FDAs Confidence in Generic Drugs Safety Efficacy (OCTOBER 24 2014)
bull ldquomost patientsrdquo is not the same asldquo all patientsrdquo and whether the 24 to 36 normal subjects used in the agencys bioequivalency tests represents the full range of individual variation in the way drugs are absorbed across the pharmaceutical using population is uncertain
bull Individuals can sometimes be allergic and react differently to whatever substance goes into making up the capsule or the tablet
FDA Flags Generic Versions of ADHD Medication(NOVEMBER 14 2014)
bull FDA changed the therapeutic equivalence (TE) rating from AB to BXmdashmeaning that the products are still approved and can be prescribed but are no longer recommended as automatic substitutes
RLD Variability Can be a block-buster opportunityFocus on lsquocontrol strategyrsquo
bull Overcoming CP amp IP provide FDA a submission they need to address CP
bull Then begin with QTPP CQArsquos hellip skip lsquodesign spacersquo and focus on lsquocontrol strategy
bull The entire development team should read the complete package insert of RLD
bull Discuss to ensure a common understandingbull Failure modes amp intended use
bull Pharmaceutical Equivalence
bull Bioequivalence
bull Other studies
QbD Challenges
3122015 Ajaz S Hussain PhD 41
NewRegulators are not prepared to handle QbD applications
NewMisalignment of international regulatory authorities
New and Generics
RampD incentivized for lsquoshots on the goalrsquo not QbD
GenericsLack of belief in business case ndash lsquoGenerics are all about file first figure out laterrsquo
Biologics Lack of technology to execute
Ted Fuhr Mackinsey amp Company June 2010 FDA Advisory Committee
Summary
bull Excipient functionality can contribute in critical ways to product quality amp performance adequate control is necessary
bull Our databases tools and knowledge are lagging behind the rapidly increasing complexity and uncertainty
bull Risk to quality and to business is increasing and regulatory transitions pose additional difficulties
bull Effective knowledge management ndash IT and Human practices ndash is critical for organizational lsquobottom-linersquo
bull We all must come together collaboratively to address the urgent needs we owe it to the patients we serve
3122015 Ajaz S Hussain PhD 42
Knowledge Management amp Culture of Quality
Ajaz S Hussain PhD
Insight Advice amp Solutions LLCMaryland USA
Executive Director the National Institute for Pharmaceutical Technology amp Education
3122015 Ajaz S Hussain PhD 43
3122015 Ajaz S Hussain PhD 44
Life-cycle approach needed for knowledge management
Investigational ProductscGMPs
DevelopmentTechnology
TransferCommercial
ManufacturingDiscontinuation
Management Responsibility
Process Performance amp Product Quality Monitoring SystemCAPA Change Management Management Review
PQS Elements
Knowledge ManagementQuality Risk ManagementEnablers
ICH Q10 KM is a systematic approach to acquiring analyzing storing and disseminating information related to products manufacturing processes and components
Based on ICH Q10
ldquowe can be blind to the obvious and we are also blind to our blindnessrdquo
Daniel Kahneman Thinking Fast and Slow
3142015 Ajazajazhussaincom 45
httpwebmiteduperscipeopleadelsoncheckershadow_proofhtml
3122015 Ajaz S Hussain PhD 46
1938 The Federal Food Drug and Cosmetic (FDC)
bull 1937 Elixir of Sulfanilamide
1962 Kefauver-Harris Drug Amendments
bull 1962 Thalidomide
bull 1960 Color Additive Amendment
bull 1958 Food Additives Amendment GRAS
bull 1960 Color Additive Amendment
bull 1958 Food Additives Amendment GRAS
1992 Generic Drug Enforcement Act
bull1989 L-Tryptophan
bull 1989 Generic Drug Scandal
bull 1988 Food and Drug Administration Act
bull 1984 Fines Enhancement Laws Drug Price Competition and Patent Term Restoration Act
2012 Food and Drug Administration Safety and Innovation Act (FDASIA)
bull 2007 Heparin Disaster
2013 Pandemic and All-Hazards Preparedness Reauthorization Act (PAHPRA) Drug Quality and Security Act
bull 2012 The Deadly Meningitis Outbreak
Past 70 years 1937 ndash 2007 The diethylene glycol (DEG) narrative
3122015 Ajaz S Hussain PhD 47
0
5
10
15
20
25
30
35
Yea
rs
DEG Years since the previous incident
0
50
100
150
200
250
300
350
Number of Reported Deaths
1937
Eli
xir
of
Sulf
anil
amid
e
2007T
ootp
aste
conta
min
atio
n
0 70 years 0 70 years
Frequent reports
Mumbai Mumbai
Data from Excipient Fest Janeen Skutnik Chair ndashIPECAmericas 2009
Past 70+ years DEG contamination or economically motivated adulteration
3122015 Ajaz S Hussain PhD 48
Reported cases underestimate the real tragedy rapid intervention may not occur
Epidemic of Pediatric Deaths From Acute Renal Failure Caused by
Diethylene Glycol Poisoning JAMA 1998279(15)1175-1180
doi101001jama279151175
Month of hospital admission for children with
acute renal failure Haiti
October 1995-October 1996
Diethylene glycol poisoning in Gurgaon India 1998Bulletin of the World Health Organization 2001 79 88ndash95
We report a second episode of poisoning occurring in 1998 in
India as a result of children ingesting diethylene glycol at
least 33 children are known to have died
At the beginning of the investigation we never imagined that
contaminated medicine was causing acute renal failure in
children
A brand of cough expectorant manufactured by a local
pharmaceutical company was found by the Central Drugs
Laboratory Calcutta to contain 175 (vv) diethylene
glycol
The district and state drug controller had tested many
samples using thin layer chromatography before a sample of
medicine tested positive for diethylene glycol at the Central
Drugs Laboratory None of the earlier samples was found to
be contaminated
3122015 Ajaz S Hussain PhD 49
Guidance for Industry Testing of
Glycerin for Diethylene Glycol
CDER May 2007 Compliance
1 Manufacturers did not perform full
identity testing on the glycerin raw
material including tests to quantify
the amount of DEG
2 Relied on the certificate of analysis
(COA)
3 The origin of the glycerin was not
easily apparent from the COA
4 The COA was often a copy of a COA
on the letterhead of the distributor
5 The chain of custody or distribution
history of the glycerin was also not
readily known
USP Glycerin Monograph
Type of Posting Revision Bulletin
Posting Date 04ndashFebndash2009
Official Date 01ndashMayndash2009
Because of the serious hazards
associated withhellip and in response to
recommendations set forth in the
FDA Guidance for Industry Testing
of Glycerin for Diethylene Glycol
published in May 2007 USP has
revised the USP Glycerin monograph
Because diethylene glycol and
ethylene glycol are considered
unacceptable toxic substances the
testing of USP Glycerin should
demonstrate the absence of these
substances
April 2007 FDA request to
USP to revise the Glycerin
monographrsquos
IDENTIFICATION section
Revision includes adding ndash
Identification test B LIMIT OF
DIETHYLENE GLYCOL AND
ETHYLENE GLYCOL to detect
and quantify DEGEG in Glycerin
minus Is no longer part of the impurity
testing
ldquoLimit of DEG and Related
Compoundsrdquo minus Introduces a
capillary gas-chromatographic
(GC) method with flame ionization
detection (FID) minus Limit of NMT
010 each for diethylene glycol
and ethylene glycol is found
70+ years to get here how difficult will it be to change habits such as lsquoblind reliance of COArsquo
3122015 Ajaz S Hussain PhD 50
Personality and Habitual Frame Biases
Myers Brigs ENTJ (first tested at FDA)
S
TF
Expanded frame
future
possibilities
objective lsquocause
and effectrsquo
Expanded frame
future
possibilities
people and
relationships
Narrow frame
the present
individuals and
relationships
Narrow frame
the present
objective
cause and
effect
N
Based on Stanford Webinar - How to Overcome the Top 3 MegaBiases in Decision-Making
Stanford Universityrsquos Strategic Decision and Risk Management certificate program
From Mapping a Managers Brain on Incentives
Social
influences
Relative
thinking
UncertaintyComplexity
By Design Intention to act consciously
bull In the interest of patients and to continually improve this ability bull To provide a healing touch ndash one life at a time in what we do and how we
do it
1292014 Ajazajazhussaincom 51
Consciously
Scientific methodology
Engineering Design
Plan-Do-Check-Act
Subconsciously
Habits (work to get rid of bad ones)
Habits (work to cultivate good one)
Keystone habits (Safety Alcoa ALCOA of data integrity)
The Power of Habit Why We Do What We Do in Life and Business Charles Duhigg (2012)
httpwwwslideshareneta2zpharmscipharmaceutical-culture-of-quality
What does it take to come out of the cGMP crisis
Persuasive demonstration of
(1) Ability to face facts
(2) Legal amp regulatory requirements
3) Systems approach to quality
4) Changing behavior amp culture
What is often missed or is unconvincing is how you will strengthen culture of quality
ldquoLet one who wants to move and convince others first be convinced and moved themselvesrdquo Thomas Carlyle
Signals that question the competence motivation andor integrity of company personnel
Do not defend the plainly indefensible it adds further serious credibility costs
3142015 Ajazajazhussaincom 52
Quality is everyones responsibility
Lack of knowledge that is
the problem
If you do not know how to ask the
right question you discover nothing
If you cant describe what you
are doing as a process you dont know what youre
doing
Rational behavior requires theory
Reactive behavior requires only reflex
action
Whenever there is fear you will get wrong figures
3142015 Ajazajazhussaincom 53
Selected quotes W Edwards Deming
3142015 Ajazajazhussaincom 54
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
ldquoWE CANNOT CHANGE THE HUMAN CONDITION BUThellipWE CAN CHANGE THE CONDITIONS UNDER WHICH HUMANS WORKrdquo JAMES REASON
Disregard to Malice
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 55
ldquohelliprecords not completed
contemporaneouslyrdquo
ldquohellipobserved analyst back-date logbooksrdquo
ldquohelliptrial injectionshelliprdquo
ldquohellipresults failing specifications are
retested until acceptable results are obtainedhelliprdquo
ldquohellipover-writing electronic raw datahelliprdquo
ldquohellipOOS not investigates per XYZ SOPrdquo
ldquohellipappropriate controls not establishedhelliprdquo
Each additional observation adds
reasons to confirm that this is very likely a system
with intentional lsquoholesrsquo in its
defenses
Preconditions
Rationalization amp Attitude
Pressure amp Incentive
Opportunity ndashlsquoholes in the QMSrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 56
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 57
Attitude towards the behavior
Subjective norm
Perceived behavioral
control
IntentionFuture
Behavior
usually found to predict behavioral intentions with a high degree of accuracy
intentions in combination with perceived behavioral control can account for a considerable proportion of variance in behavior
PastBehavior
Ajen I The theory of planned behavior ORGANIZATIONAL BEHAVIOR AND HUMAN DECISION PROCESSES 50 179-211 (1991)
Heparin tragedy 2007 and 2008
FDA reports 149 deaths with allergic or hypersensitivity symptoms during that period
bull Contaminated heparin from China
QC Testing
bull Initial testing failed to detect the contaminant
Pharmacovigilence
bull Signals in the pharmacovigilence systems responded slowly and
Eventually the severity of reactions associated made it likely that the contamination would be detected
bull too late for those who died or were injured
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 58
Congressman Shimkus When the drug safety system fails people get sick Some die
bull Some of these people are already very vulnerable and proving the cause of harm from impurities adulteration and counterfeits can be elusive
It is hard to detect harm
bull Certainly the companies are obligated to ensure a culture of quality and maintain vigilance as well This reflects a systems approach to safety
FDA inspectors look for a culture of quality at
manufacturing facilities
bull FDA policies led to the failure to inspect the Chinese plantThis system approach wasnt at
play here
bull While it doesnt deny the counterfeit source tries to say that counterfeits didnt cause the reaction as if the adulteration itself was no big deal Is this an acceptable mindset helliphelliphellip
This brings me to China and its quality culture or lack thereof
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 59
ONE HUNDRED TENTH CONGRESS SECOND SESSION APRIL 29 2008 Serial No 110-109
21 CFR PART 211 SUBPARTS -Deviations signal gaps in CoQ
bullGENERAL PROVISIONSA
bullORGANIZATION AND PERSONNELB
bullBUILDINGS AND FACILITIESC
bullEQUIPMENTD
bullCONTROL OF COMPONENTS AND DRUG PRODUCT CONTAINERS AND CLOSURESE
bullPRODUCTION AND PROCESS CONTROLSF
bullPACKAGING AND LABELING CONTROLG
bullHOLDING AND DISTRIBUTIONH
bullLABORATORY CONTROLSI
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 60
For example the combinationhellip
The Power of Habit Why We Do What We Do in Life and Business Charles Duhigg (2012)
bull Scientific methodology
bull Engineering Design
bull Plan-Do-Check-ActConsciously
bull Habits (work to get rid of bad ones)
bull Habits (work to cultivate good one)
bull Keystone habits (Safety Alcoa ALCOA of data integrity)
Subconsciously
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 61
CoQ How
bull What are the predictors of CoQCoQ Manifests by Design -
lsquoquality by designrsquo the foundation
bull 1 2 3When do people change their behaviors
bull A B C D (any body can dance)What makes a QMS effective
bull X Y ZWhen proactive compliance occurs
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 62
Going beyond rules pays
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 63
Human behavior Connecting the Dots With the Right Connectors
GXPs ndash rational behaviors
How proactive compliance is achieved X Y Z
Quality Management System
What makes a QMS reliable A B C D
Culture of Quality
Why people change their behavior 1 2 3
Human Behaviors Beyond GXPs
Predictors of Culture of Quality
Why What and How of Culture of Quality
9192014 copy Ajaz S Hussain | INSIGHT ADVICE amp SOLUTIONS LLC 64
Predictors of CoQ Act consciously in the interest of patients ndash when no one is looking
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 65
Only four attributes
actually predict a culture of
quality
Leadership Emphasis
Message Credibility
Peer Involvement
Employee Empower-ment
People will change their
behavior if they see the new behavior as
Normal
(1)
Rewarding
(2)
Easy
(3)
Dr W Edwards Demingrsquos - ldquoOut of the crisisrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 66
The journey requires leadership
with Profound Knowledge as a
guide
bull As leaders responsible for system change top management is most in need of profound knowledge
bull Quality is often determined in the boardroom
bull Problems arise when management reacts to common cause or chance variation as if it were special cause variation
bull Prediction based in theory provides a foundation for planning a course of action Plan ndash Do ndash Check ndash Act
bull The leader serves the people with clear vision and guidance to empower them To be empowered is to share ownership in the identity
bull Giving people a certain degree of control over their work fulfills the need for freedom and provides opportunity for taking joy in work
Profound Knowledge as a guide
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 67
Appreciation for a System
Theory of Knowledge
Knowledge about
Variation
Human Behavior -Psychology of Change
A
B
C
D+
Systems Approach for ErrorDeviation Management
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 68
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
Human error models and management J Reason BMJ 320 768ndash770 (2000)
D+
Culture of Error Management परबधनbull Error strain
bull Covering upFear of Errors
bull Anticipation
bull Risk takingAwareness
bull Development QbDRFT
bull Error detection Communication
bull Analyzing errors Correction
Mastery orientation
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 69
Dots amp Connections
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 70
CoQ
1
2
3
QMS
A
B
C
D
GXP Behaviors
X
Y
Z
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 71
Culture of Quality
Normal
Rewarding
Easy
QMS
System
Knowledge
Variation
Behavior
Behavior -GXPs
Fear Removed
Mastery
Awareness
EnvironmentLeadership Emphasis
Message Credibility
Peer Involvement
Employee Empowerment
Connect to CoQ
Connect to GXPs
A Framework and a Tool (for gap analysis)
3122015 Ajaz S Hussain PhD 28
Today there are several product categories (eg controlled release inhalation products DPIrsquos topical transdermal liposomal products etc) which requires an exquisite control of complex physical material and product attributes (functionality)
Many of our current measurement systems need improvement
We depend on these to ensure control of lot-lot variability
Measurement system capability must be confirmed to be able to assess process capability (calibration amp Gauge RampR)
Life-cycle approach to quality continued process verification (FDArsquos Process Validation 2011) is a safety net
Supplier amp Excipient Qualification amp Process Validation
Measurement System Analysis
bull From lsquocalibrationrsquo to lsquoGauge RampRrsquoParticularly for physical
attributes destructive analysis
bull Many (including regulators) have not yet understood its importance
Gauge RampR well established but not commonly practiced
bull Measurement system in a state of control effective CAPA quality metrics Culture of Quality
With the move towards Statistical Process Control
bull Demonstrate equivalent in vitro performance more exacting criteria
Development of complex generic products (ER
Injectable Inhalation etc)
3122015 Ajaz S Hussain PhD 29
Process Validation (2011) Statistical Confidence Continued Process Verificationhellip
3122015 Ajaz S Hussain PhD 30
httpwwwslideshareneta2zpharmsciperformance-testing-pharmaceutical-quality-2004(accessed 6 December 2014)
3122015 Ajaz S Hussain PhD 31
Supplier amp Excipient Qualification amp CAPA
Out of Specification events are difficult to resolve
Excipient functionality can be a significant contributing factor
Sometimes reluctantly have to settle with - ldquoRoot cause unknown
600 days
I have inserted the ldquo600 daysrsquo on the figure ndash this is based on cases I have seen while at FDA)
3122015 Ajaz S Hussain PhD 32
Prevention of OOS and Effective CAPA needs a focus on critical functional attributes
Out of Specification events are difficult to resolve
Excipient functionality can be a significant contributing factor
Sometimes reluctantly have to settle with - ldquoRoot cause unknown
Compendial standards and manufacturing
3122015 Ajaz S Hussain PhD 33
Practice Control Process Maturity
Initial
bull Unpredictable
Managed
bull Characterized but reactive
Defined
bull Characterized proactive
Measured amp Controlled
bull In control
Optimizing
bull Focus on improvement
3122015 Ajaz S Hussain PhD 34
Capability Maturity Model Integration Carnegie Mellon University
A validated process
Maturity Level amp Assurance of Quality
Managed Characterized but reactive
High perceived risk of
lsquoCheating by Designrsquo
ldquoTrial Injectionsrdquo
ldquoTesting in to Compliancerdquo
Defined Characterized proactive
Lower level of assurance
Stopping amp Correcting
Batch Rejection
Measured amp
ControlledIn control
Quality by Design
Quality Assured
Improvement Opportunities
3122015 Ajaz S Hussain PhD 35
At the individual level in QC functionndash how often does this occur
attitude toward
performing the behavior
Process validation is
done so quality is good
test prone to error
ldquoBatch failure means I made
a mistakerdquo
subjective norm
documentation not critical
Compendial testing
sufficient
Indian regulators
collect amp test samples ndash no issue there
3122015 Ajaz S Hussain PhD 36
ldquoTesting into compliancerdquo
In general ndash low empowerment is a significant challenge (low perceived behavioral control) plus reasons to rationalizehellip
Excipient Functionality Can be critical for safety efficacy and quality
3122015 Ajaz S Hussain PhD 37
July 15 2005 FDA Public Health Advisory Safety Warnings Regarding Use of Fentanyl Transdermal (Skin) Patches
A pattern of failure Pharmaceutical Equivalence by Design (2004)
3122015 Ajaz S Hussain PhD 38
httpwwwnihsgojpdrugPhForumdocuments041122Hussain041122pdf
An attempt to correct
3122015 Ajaz S Hussain PhD 39
httpipecamericasorgsystemfilesKeyNoteEF13May11LawrenceYu(FDA)pdf
Recent challenges
3122015 Ajaz S Hussain PhD 40
Th
e V
oic
e o
f th
eA
mer
ican
P
sych
iatr
ic A
sso
ciat
ion
and
th
e P
sych
iatr
ic C
om
mu
nit
y
Physicians Question FDAs Confidence in Generic Drugs Safety Efficacy (OCTOBER 24 2014)
bull ldquomost patientsrdquo is not the same asldquo all patientsrdquo and whether the 24 to 36 normal subjects used in the agencys bioequivalency tests represents the full range of individual variation in the way drugs are absorbed across the pharmaceutical using population is uncertain
bull Individuals can sometimes be allergic and react differently to whatever substance goes into making up the capsule or the tablet
FDA Flags Generic Versions of ADHD Medication(NOVEMBER 14 2014)
bull FDA changed the therapeutic equivalence (TE) rating from AB to BXmdashmeaning that the products are still approved and can be prescribed but are no longer recommended as automatic substitutes
RLD Variability Can be a block-buster opportunityFocus on lsquocontrol strategyrsquo
bull Overcoming CP amp IP provide FDA a submission they need to address CP
bull Then begin with QTPP CQArsquos hellip skip lsquodesign spacersquo and focus on lsquocontrol strategy
bull The entire development team should read the complete package insert of RLD
bull Discuss to ensure a common understandingbull Failure modes amp intended use
bull Pharmaceutical Equivalence
bull Bioequivalence
bull Other studies
QbD Challenges
3122015 Ajaz S Hussain PhD 41
NewRegulators are not prepared to handle QbD applications
NewMisalignment of international regulatory authorities
New and Generics
RampD incentivized for lsquoshots on the goalrsquo not QbD
GenericsLack of belief in business case ndash lsquoGenerics are all about file first figure out laterrsquo
Biologics Lack of technology to execute
Ted Fuhr Mackinsey amp Company June 2010 FDA Advisory Committee
Summary
bull Excipient functionality can contribute in critical ways to product quality amp performance adequate control is necessary
bull Our databases tools and knowledge are lagging behind the rapidly increasing complexity and uncertainty
bull Risk to quality and to business is increasing and regulatory transitions pose additional difficulties
bull Effective knowledge management ndash IT and Human practices ndash is critical for organizational lsquobottom-linersquo
bull We all must come together collaboratively to address the urgent needs we owe it to the patients we serve
3122015 Ajaz S Hussain PhD 42
Knowledge Management amp Culture of Quality
Ajaz S Hussain PhD
Insight Advice amp Solutions LLCMaryland USA
Executive Director the National Institute for Pharmaceutical Technology amp Education
3122015 Ajaz S Hussain PhD 43
3122015 Ajaz S Hussain PhD 44
Life-cycle approach needed for knowledge management
Investigational ProductscGMPs
DevelopmentTechnology
TransferCommercial
ManufacturingDiscontinuation
Management Responsibility
Process Performance amp Product Quality Monitoring SystemCAPA Change Management Management Review
PQS Elements
Knowledge ManagementQuality Risk ManagementEnablers
ICH Q10 KM is a systematic approach to acquiring analyzing storing and disseminating information related to products manufacturing processes and components
Based on ICH Q10
ldquowe can be blind to the obvious and we are also blind to our blindnessrdquo
Daniel Kahneman Thinking Fast and Slow
3142015 Ajazajazhussaincom 45
httpwebmiteduperscipeopleadelsoncheckershadow_proofhtml
3122015 Ajaz S Hussain PhD 46
1938 The Federal Food Drug and Cosmetic (FDC)
bull 1937 Elixir of Sulfanilamide
1962 Kefauver-Harris Drug Amendments
bull 1962 Thalidomide
bull 1960 Color Additive Amendment
bull 1958 Food Additives Amendment GRAS
bull 1960 Color Additive Amendment
bull 1958 Food Additives Amendment GRAS
1992 Generic Drug Enforcement Act
bull1989 L-Tryptophan
bull 1989 Generic Drug Scandal
bull 1988 Food and Drug Administration Act
bull 1984 Fines Enhancement Laws Drug Price Competition and Patent Term Restoration Act
2012 Food and Drug Administration Safety and Innovation Act (FDASIA)
bull 2007 Heparin Disaster
2013 Pandemic and All-Hazards Preparedness Reauthorization Act (PAHPRA) Drug Quality and Security Act
bull 2012 The Deadly Meningitis Outbreak
Past 70 years 1937 ndash 2007 The diethylene glycol (DEG) narrative
3122015 Ajaz S Hussain PhD 47
0
5
10
15
20
25
30
35
Yea
rs
DEG Years since the previous incident
0
50
100
150
200
250
300
350
Number of Reported Deaths
1937
Eli
xir
of
Sulf
anil
amid
e
2007T
ootp
aste
conta
min
atio
n
0 70 years 0 70 years
Frequent reports
Mumbai Mumbai
Data from Excipient Fest Janeen Skutnik Chair ndashIPECAmericas 2009
Past 70+ years DEG contamination or economically motivated adulteration
3122015 Ajaz S Hussain PhD 48
Reported cases underestimate the real tragedy rapid intervention may not occur
Epidemic of Pediatric Deaths From Acute Renal Failure Caused by
Diethylene Glycol Poisoning JAMA 1998279(15)1175-1180
doi101001jama279151175
Month of hospital admission for children with
acute renal failure Haiti
October 1995-October 1996
Diethylene glycol poisoning in Gurgaon India 1998Bulletin of the World Health Organization 2001 79 88ndash95
We report a second episode of poisoning occurring in 1998 in
India as a result of children ingesting diethylene glycol at
least 33 children are known to have died
At the beginning of the investigation we never imagined that
contaminated medicine was causing acute renal failure in
children
A brand of cough expectorant manufactured by a local
pharmaceutical company was found by the Central Drugs
Laboratory Calcutta to contain 175 (vv) diethylene
glycol
The district and state drug controller had tested many
samples using thin layer chromatography before a sample of
medicine tested positive for diethylene glycol at the Central
Drugs Laboratory None of the earlier samples was found to
be contaminated
3122015 Ajaz S Hussain PhD 49
Guidance for Industry Testing of
Glycerin for Diethylene Glycol
CDER May 2007 Compliance
1 Manufacturers did not perform full
identity testing on the glycerin raw
material including tests to quantify
the amount of DEG
2 Relied on the certificate of analysis
(COA)
3 The origin of the glycerin was not
easily apparent from the COA
4 The COA was often a copy of a COA
on the letterhead of the distributor
5 The chain of custody or distribution
history of the glycerin was also not
readily known
USP Glycerin Monograph
Type of Posting Revision Bulletin
Posting Date 04ndashFebndash2009
Official Date 01ndashMayndash2009
Because of the serious hazards
associated withhellip and in response to
recommendations set forth in the
FDA Guidance for Industry Testing
of Glycerin for Diethylene Glycol
published in May 2007 USP has
revised the USP Glycerin monograph
Because diethylene glycol and
ethylene glycol are considered
unacceptable toxic substances the
testing of USP Glycerin should
demonstrate the absence of these
substances
April 2007 FDA request to
USP to revise the Glycerin
monographrsquos
IDENTIFICATION section
Revision includes adding ndash
Identification test B LIMIT OF
DIETHYLENE GLYCOL AND
ETHYLENE GLYCOL to detect
and quantify DEGEG in Glycerin
minus Is no longer part of the impurity
testing
ldquoLimit of DEG and Related
Compoundsrdquo minus Introduces a
capillary gas-chromatographic
(GC) method with flame ionization
detection (FID) minus Limit of NMT
010 each for diethylene glycol
and ethylene glycol is found
70+ years to get here how difficult will it be to change habits such as lsquoblind reliance of COArsquo
3122015 Ajaz S Hussain PhD 50
Personality and Habitual Frame Biases
Myers Brigs ENTJ (first tested at FDA)
S
TF
Expanded frame
future
possibilities
objective lsquocause
and effectrsquo
Expanded frame
future
possibilities
people and
relationships
Narrow frame
the present
individuals and
relationships
Narrow frame
the present
objective
cause and
effect
N
Based on Stanford Webinar - How to Overcome the Top 3 MegaBiases in Decision-Making
Stanford Universityrsquos Strategic Decision and Risk Management certificate program
From Mapping a Managers Brain on Incentives
Social
influences
Relative
thinking
UncertaintyComplexity
By Design Intention to act consciously
bull In the interest of patients and to continually improve this ability bull To provide a healing touch ndash one life at a time in what we do and how we
do it
1292014 Ajazajazhussaincom 51
Consciously
Scientific methodology
Engineering Design
Plan-Do-Check-Act
Subconsciously
Habits (work to get rid of bad ones)
Habits (work to cultivate good one)
Keystone habits (Safety Alcoa ALCOA of data integrity)
The Power of Habit Why We Do What We Do in Life and Business Charles Duhigg (2012)
httpwwwslideshareneta2zpharmscipharmaceutical-culture-of-quality
What does it take to come out of the cGMP crisis
Persuasive demonstration of
(1) Ability to face facts
(2) Legal amp regulatory requirements
3) Systems approach to quality
4) Changing behavior amp culture
What is often missed or is unconvincing is how you will strengthen culture of quality
ldquoLet one who wants to move and convince others first be convinced and moved themselvesrdquo Thomas Carlyle
Signals that question the competence motivation andor integrity of company personnel
Do not defend the plainly indefensible it adds further serious credibility costs
3142015 Ajazajazhussaincom 52
Quality is everyones responsibility
Lack of knowledge that is
the problem
If you do not know how to ask the
right question you discover nothing
If you cant describe what you
are doing as a process you dont know what youre
doing
Rational behavior requires theory
Reactive behavior requires only reflex
action
Whenever there is fear you will get wrong figures
3142015 Ajazajazhussaincom 53
Selected quotes W Edwards Deming
3142015 Ajazajazhussaincom 54
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
ldquoWE CANNOT CHANGE THE HUMAN CONDITION BUThellipWE CAN CHANGE THE CONDITIONS UNDER WHICH HUMANS WORKrdquo JAMES REASON
Disregard to Malice
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 55
ldquohelliprecords not completed
contemporaneouslyrdquo
ldquohellipobserved analyst back-date logbooksrdquo
ldquohelliptrial injectionshelliprdquo
ldquohellipresults failing specifications are
retested until acceptable results are obtainedhelliprdquo
ldquohellipover-writing electronic raw datahelliprdquo
ldquohellipOOS not investigates per XYZ SOPrdquo
ldquohellipappropriate controls not establishedhelliprdquo
Each additional observation adds
reasons to confirm that this is very likely a system
with intentional lsquoholesrsquo in its
defenses
Preconditions
Rationalization amp Attitude
Pressure amp Incentive
Opportunity ndashlsquoholes in the QMSrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 56
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 57
Attitude towards the behavior
Subjective norm
Perceived behavioral
control
IntentionFuture
Behavior
usually found to predict behavioral intentions with a high degree of accuracy
intentions in combination with perceived behavioral control can account for a considerable proportion of variance in behavior
PastBehavior
Ajen I The theory of planned behavior ORGANIZATIONAL BEHAVIOR AND HUMAN DECISION PROCESSES 50 179-211 (1991)
Heparin tragedy 2007 and 2008
FDA reports 149 deaths with allergic or hypersensitivity symptoms during that period
bull Contaminated heparin from China
QC Testing
bull Initial testing failed to detect the contaminant
Pharmacovigilence
bull Signals in the pharmacovigilence systems responded slowly and
Eventually the severity of reactions associated made it likely that the contamination would be detected
bull too late for those who died or were injured
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 58
Congressman Shimkus When the drug safety system fails people get sick Some die
bull Some of these people are already very vulnerable and proving the cause of harm from impurities adulteration and counterfeits can be elusive
It is hard to detect harm
bull Certainly the companies are obligated to ensure a culture of quality and maintain vigilance as well This reflects a systems approach to safety
FDA inspectors look for a culture of quality at
manufacturing facilities
bull FDA policies led to the failure to inspect the Chinese plantThis system approach wasnt at
play here
bull While it doesnt deny the counterfeit source tries to say that counterfeits didnt cause the reaction as if the adulteration itself was no big deal Is this an acceptable mindset helliphelliphellip
This brings me to China and its quality culture or lack thereof
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 59
ONE HUNDRED TENTH CONGRESS SECOND SESSION APRIL 29 2008 Serial No 110-109
21 CFR PART 211 SUBPARTS -Deviations signal gaps in CoQ
bullGENERAL PROVISIONSA
bullORGANIZATION AND PERSONNELB
bullBUILDINGS AND FACILITIESC
bullEQUIPMENTD
bullCONTROL OF COMPONENTS AND DRUG PRODUCT CONTAINERS AND CLOSURESE
bullPRODUCTION AND PROCESS CONTROLSF
bullPACKAGING AND LABELING CONTROLG
bullHOLDING AND DISTRIBUTIONH
bullLABORATORY CONTROLSI
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 60
For example the combinationhellip
The Power of Habit Why We Do What We Do in Life and Business Charles Duhigg (2012)
bull Scientific methodology
bull Engineering Design
bull Plan-Do-Check-ActConsciously
bull Habits (work to get rid of bad ones)
bull Habits (work to cultivate good one)
bull Keystone habits (Safety Alcoa ALCOA of data integrity)
Subconsciously
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 61
CoQ How
bull What are the predictors of CoQCoQ Manifests by Design -
lsquoquality by designrsquo the foundation
bull 1 2 3When do people change their behaviors
bull A B C D (any body can dance)What makes a QMS effective
bull X Y ZWhen proactive compliance occurs
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 62
Going beyond rules pays
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 63
Human behavior Connecting the Dots With the Right Connectors
GXPs ndash rational behaviors
How proactive compliance is achieved X Y Z
Quality Management System
What makes a QMS reliable A B C D
Culture of Quality
Why people change their behavior 1 2 3
Human Behaviors Beyond GXPs
Predictors of Culture of Quality
Why What and How of Culture of Quality
9192014 copy Ajaz S Hussain | INSIGHT ADVICE amp SOLUTIONS LLC 64
Predictors of CoQ Act consciously in the interest of patients ndash when no one is looking
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 65
Only four attributes
actually predict a culture of
quality
Leadership Emphasis
Message Credibility
Peer Involvement
Employee Empower-ment
People will change their
behavior if they see the new behavior as
Normal
(1)
Rewarding
(2)
Easy
(3)
Dr W Edwards Demingrsquos - ldquoOut of the crisisrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 66
The journey requires leadership
with Profound Knowledge as a
guide
bull As leaders responsible for system change top management is most in need of profound knowledge
bull Quality is often determined in the boardroom
bull Problems arise when management reacts to common cause or chance variation as if it were special cause variation
bull Prediction based in theory provides a foundation for planning a course of action Plan ndash Do ndash Check ndash Act
bull The leader serves the people with clear vision and guidance to empower them To be empowered is to share ownership in the identity
bull Giving people a certain degree of control over their work fulfills the need for freedom and provides opportunity for taking joy in work
Profound Knowledge as a guide
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 67
Appreciation for a System
Theory of Knowledge
Knowledge about
Variation
Human Behavior -Psychology of Change
A
B
C
D+
Systems Approach for ErrorDeviation Management
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 68
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
Human error models and management J Reason BMJ 320 768ndash770 (2000)
D+
Culture of Error Management परबधनbull Error strain
bull Covering upFear of Errors
bull Anticipation
bull Risk takingAwareness
bull Development QbDRFT
bull Error detection Communication
bull Analyzing errors Correction
Mastery orientation
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 69
Dots amp Connections
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 70
CoQ
1
2
3
QMS
A
B
C
D
GXP Behaviors
X
Y
Z
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 71
Culture of Quality
Normal
Rewarding
Easy
QMS
System
Knowledge
Variation
Behavior
Behavior -GXPs
Fear Removed
Mastery
Awareness
EnvironmentLeadership Emphasis
Message Credibility
Peer Involvement
Employee Empowerment
Connect to CoQ
Connect to GXPs
A Framework and a Tool (for gap analysis)
Measurement System Analysis
bull From lsquocalibrationrsquo to lsquoGauge RampRrsquoParticularly for physical
attributes destructive analysis
bull Many (including regulators) have not yet understood its importance
Gauge RampR well established but not commonly practiced
bull Measurement system in a state of control effective CAPA quality metrics Culture of Quality
With the move towards Statistical Process Control
bull Demonstrate equivalent in vitro performance more exacting criteria
Development of complex generic products (ER
Injectable Inhalation etc)
3122015 Ajaz S Hussain PhD 29
Process Validation (2011) Statistical Confidence Continued Process Verificationhellip
3122015 Ajaz S Hussain PhD 30
httpwwwslideshareneta2zpharmsciperformance-testing-pharmaceutical-quality-2004(accessed 6 December 2014)
3122015 Ajaz S Hussain PhD 31
Supplier amp Excipient Qualification amp CAPA
Out of Specification events are difficult to resolve
Excipient functionality can be a significant contributing factor
Sometimes reluctantly have to settle with - ldquoRoot cause unknown
600 days
I have inserted the ldquo600 daysrsquo on the figure ndash this is based on cases I have seen while at FDA)
3122015 Ajaz S Hussain PhD 32
Prevention of OOS and Effective CAPA needs a focus on critical functional attributes
Out of Specification events are difficult to resolve
Excipient functionality can be a significant contributing factor
Sometimes reluctantly have to settle with - ldquoRoot cause unknown
Compendial standards and manufacturing
3122015 Ajaz S Hussain PhD 33
Practice Control Process Maturity
Initial
bull Unpredictable
Managed
bull Characterized but reactive
Defined
bull Characterized proactive
Measured amp Controlled
bull In control
Optimizing
bull Focus on improvement
3122015 Ajaz S Hussain PhD 34
Capability Maturity Model Integration Carnegie Mellon University
A validated process
Maturity Level amp Assurance of Quality
Managed Characterized but reactive
High perceived risk of
lsquoCheating by Designrsquo
ldquoTrial Injectionsrdquo
ldquoTesting in to Compliancerdquo
Defined Characterized proactive
Lower level of assurance
Stopping amp Correcting
Batch Rejection
Measured amp
ControlledIn control
Quality by Design
Quality Assured
Improvement Opportunities
3122015 Ajaz S Hussain PhD 35
At the individual level in QC functionndash how often does this occur
attitude toward
performing the behavior
Process validation is
done so quality is good
test prone to error
ldquoBatch failure means I made
a mistakerdquo
subjective norm
documentation not critical
Compendial testing
sufficient
Indian regulators
collect amp test samples ndash no issue there
3122015 Ajaz S Hussain PhD 36
ldquoTesting into compliancerdquo
In general ndash low empowerment is a significant challenge (low perceived behavioral control) plus reasons to rationalizehellip
Excipient Functionality Can be critical for safety efficacy and quality
3122015 Ajaz S Hussain PhD 37
July 15 2005 FDA Public Health Advisory Safety Warnings Regarding Use of Fentanyl Transdermal (Skin) Patches
A pattern of failure Pharmaceutical Equivalence by Design (2004)
3122015 Ajaz S Hussain PhD 38
httpwwwnihsgojpdrugPhForumdocuments041122Hussain041122pdf
An attempt to correct
3122015 Ajaz S Hussain PhD 39
httpipecamericasorgsystemfilesKeyNoteEF13May11LawrenceYu(FDA)pdf
Recent challenges
3122015 Ajaz S Hussain PhD 40
Th
e V
oic
e o
f th
eA
mer
ican
P
sych
iatr
ic A
sso
ciat
ion
and
th
e P
sych
iatr
ic C
om
mu
nit
y
Physicians Question FDAs Confidence in Generic Drugs Safety Efficacy (OCTOBER 24 2014)
bull ldquomost patientsrdquo is not the same asldquo all patientsrdquo and whether the 24 to 36 normal subjects used in the agencys bioequivalency tests represents the full range of individual variation in the way drugs are absorbed across the pharmaceutical using population is uncertain
bull Individuals can sometimes be allergic and react differently to whatever substance goes into making up the capsule or the tablet
FDA Flags Generic Versions of ADHD Medication(NOVEMBER 14 2014)
bull FDA changed the therapeutic equivalence (TE) rating from AB to BXmdashmeaning that the products are still approved and can be prescribed but are no longer recommended as automatic substitutes
RLD Variability Can be a block-buster opportunityFocus on lsquocontrol strategyrsquo
bull Overcoming CP amp IP provide FDA a submission they need to address CP
bull Then begin with QTPP CQArsquos hellip skip lsquodesign spacersquo and focus on lsquocontrol strategy
bull The entire development team should read the complete package insert of RLD
bull Discuss to ensure a common understandingbull Failure modes amp intended use
bull Pharmaceutical Equivalence
bull Bioequivalence
bull Other studies
QbD Challenges
3122015 Ajaz S Hussain PhD 41
NewRegulators are not prepared to handle QbD applications
NewMisalignment of international regulatory authorities
New and Generics
RampD incentivized for lsquoshots on the goalrsquo not QbD
GenericsLack of belief in business case ndash lsquoGenerics are all about file first figure out laterrsquo
Biologics Lack of technology to execute
Ted Fuhr Mackinsey amp Company June 2010 FDA Advisory Committee
Summary
bull Excipient functionality can contribute in critical ways to product quality amp performance adequate control is necessary
bull Our databases tools and knowledge are lagging behind the rapidly increasing complexity and uncertainty
bull Risk to quality and to business is increasing and regulatory transitions pose additional difficulties
bull Effective knowledge management ndash IT and Human practices ndash is critical for organizational lsquobottom-linersquo
bull We all must come together collaboratively to address the urgent needs we owe it to the patients we serve
3122015 Ajaz S Hussain PhD 42
Knowledge Management amp Culture of Quality
Ajaz S Hussain PhD
Insight Advice amp Solutions LLCMaryland USA
Executive Director the National Institute for Pharmaceutical Technology amp Education
3122015 Ajaz S Hussain PhD 43
3122015 Ajaz S Hussain PhD 44
Life-cycle approach needed for knowledge management
Investigational ProductscGMPs
DevelopmentTechnology
TransferCommercial
ManufacturingDiscontinuation
Management Responsibility
Process Performance amp Product Quality Monitoring SystemCAPA Change Management Management Review
PQS Elements
Knowledge ManagementQuality Risk ManagementEnablers
ICH Q10 KM is a systematic approach to acquiring analyzing storing and disseminating information related to products manufacturing processes and components
Based on ICH Q10
ldquowe can be blind to the obvious and we are also blind to our blindnessrdquo
Daniel Kahneman Thinking Fast and Slow
3142015 Ajazajazhussaincom 45
httpwebmiteduperscipeopleadelsoncheckershadow_proofhtml
3122015 Ajaz S Hussain PhD 46
1938 The Federal Food Drug and Cosmetic (FDC)
bull 1937 Elixir of Sulfanilamide
1962 Kefauver-Harris Drug Amendments
bull 1962 Thalidomide
bull 1960 Color Additive Amendment
bull 1958 Food Additives Amendment GRAS
bull 1960 Color Additive Amendment
bull 1958 Food Additives Amendment GRAS
1992 Generic Drug Enforcement Act
bull1989 L-Tryptophan
bull 1989 Generic Drug Scandal
bull 1988 Food and Drug Administration Act
bull 1984 Fines Enhancement Laws Drug Price Competition and Patent Term Restoration Act
2012 Food and Drug Administration Safety and Innovation Act (FDASIA)
bull 2007 Heparin Disaster
2013 Pandemic and All-Hazards Preparedness Reauthorization Act (PAHPRA) Drug Quality and Security Act
bull 2012 The Deadly Meningitis Outbreak
Past 70 years 1937 ndash 2007 The diethylene glycol (DEG) narrative
3122015 Ajaz S Hussain PhD 47
0
5
10
15
20
25
30
35
Yea
rs
DEG Years since the previous incident
0
50
100
150
200
250
300
350
Number of Reported Deaths
1937
Eli
xir
of
Sulf
anil
amid
e
2007T
ootp
aste
conta
min
atio
n
0 70 years 0 70 years
Frequent reports
Mumbai Mumbai
Data from Excipient Fest Janeen Skutnik Chair ndashIPECAmericas 2009
Past 70+ years DEG contamination or economically motivated adulteration
3122015 Ajaz S Hussain PhD 48
Reported cases underestimate the real tragedy rapid intervention may not occur
Epidemic of Pediatric Deaths From Acute Renal Failure Caused by
Diethylene Glycol Poisoning JAMA 1998279(15)1175-1180
doi101001jama279151175
Month of hospital admission for children with
acute renal failure Haiti
October 1995-October 1996
Diethylene glycol poisoning in Gurgaon India 1998Bulletin of the World Health Organization 2001 79 88ndash95
We report a second episode of poisoning occurring in 1998 in
India as a result of children ingesting diethylene glycol at
least 33 children are known to have died
At the beginning of the investigation we never imagined that
contaminated medicine was causing acute renal failure in
children
A brand of cough expectorant manufactured by a local
pharmaceutical company was found by the Central Drugs
Laboratory Calcutta to contain 175 (vv) diethylene
glycol
The district and state drug controller had tested many
samples using thin layer chromatography before a sample of
medicine tested positive for diethylene glycol at the Central
Drugs Laboratory None of the earlier samples was found to
be contaminated
3122015 Ajaz S Hussain PhD 49
Guidance for Industry Testing of
Glycerin for Diethylene Glycol
CDER May 2007 Compliance
1 Manufacturers did not perform full
identity testing on the glycerin raw
material including tests to quantify
the amount of DEG
2 Relied on the certificate of analysis
(COA)
3 The origin of the glycerin was not
easily apparent from the COA
4 The COA was often a copy of a COA
on the letterhead of the distributor
5 The chain of custody or distribution
history of the glycerin was also not
readily known
USP Glycerin Monograph
Type of Posting Revision Bulletin
Posting Date 04ndashFebndash2009
Official Date 01ndashMayndash2009
Because of the serious hazards
associated withhellip and in response to
recommendations set forth in the
FDA Guidance for Industry Testing
of Glycerin for Diethylene Glycol
published in May 2007 USP has
revised the USP Glycerin monograph
Because diethylene glycol and
ethylene glycol are considered
unacceptable toxic substances the
testing of USP Glycerin should
demonstrate the absence of these
substances
April 2007 FDA request to
USP to revise the Glycerin
monographrsquos
IDENTIFICATION section
Revision includes adding ndash
Identification test B LIMIT OF
DIETHYLENE GLYCOL AND
ETHYLENE GLYCOL to detect
and quantify DEGEG in Glycerin
minus Is no longer part of the impurity
testing
ldquoLimit of DEG and Related
Compoundsrdquo minus Introduces a
capillary gas-chromatographic
(GC) method with flame ionization
detection (FID) minus Limit of NMT
010 each for diethylene glycol
and ethylene glycol is found
70+ years to get here how difficult will it be to change habits such as lsquoblind reliance of COArsquo
3122015 Ajaz S Hussain PhD 50
Personality and Habitual Frame Biases
Myers Brigs ENTJ (first tested at FDA)
S
TF
Expanded frame
future
possibilities
objective lsquocause
and effectrsquo
Expanded frame
future
possibilities
people and
relationships
Narrow frame
the present
individuals and
relationships
Narrow frame
the present
objective
cause and
effect
N
Based on Stanford Webinar - How to Overcome the Top 3 MegaBiases in Decision-Making
Stanford Universityrsquos Strategic Decision and Risk Management certificate program
From Mapping a Managers Brain on Incentives
Social
influences
Relative
thinking
UncertaintyComplexity
By Design Intention to act consciously
bull In the interest of patients and to continually improve this ability bull To provide a healing touch ndash one life at a time in what we do and how we
do it
1292014 Ajazajazhussaincom 51
Consciously
Scientific methodology
Engineering Design
Plan-Do-Check-Act
Subconsciously
Habits (work to get rid of bad ones)
Habits (work to cultivate good one)
Keystone habits (Safety Alcoa ALCOA of data integrity)
The Power of Habit Why We Do What We Do in Life and Business Charles Duhigg (2012)
httpwwwslideshareneta2zpharmscipharmaceutical-culture-of-quality
What does it take to come out of the cGMP crisis
Persuasive demonstration of
(1) Ability to face facts
(2) Legal amp regulatory requirements
3) Systems approach to quality
4) Changing behavior amp culture
What is often missed or is unconvincing is how you will strengthen culture of quality
ldquoLet one who wants to move and convince others first be convinced and moved themselvesrdquo Thomas Carlyle
Signals that question the competence motivation andor integrity of company personnel
Do not defend the plainly indefensible it adds further serious credibility costs
3142015 Ajazajazhussaincom 52
Quality is everyones responsibility
Lack of knowledge that is
the problem
If you do not know how to ask the
right question you discover nothing
If you cant describe what you
are doing as a process you dont know what youre
doing
Rational behavior requires theory
Reactive behavior requires only reflex
action
Whenever there is fear you will get wrong figures
3142015 Ajazajazhussaincom 53
Selected quotes W Edwards Deming
3142015 Ajazajazhussaincom 54
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
ldquoWE CANNOT CHANGE THE HUMAN CONDITION BUThellipWE CAN CHANGE THE CONDITIONS UNDER WHICH HUMANS WORKrdquo JAMES REASON
Disregard to Malice
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 55
ldquohelliprecords not completed
contemporaneouslyrdquo
ldquohellipobserved analyst back-date logbooksrdquo
ldquohelliptrial injectionshelliprdquo
ldquohellipresults failing specifications are
retested until acceptable results are obtainedhelliprdquo
ldquohellipover-writing electronic raw datahelliprdquo
ldquohellipOOS not investigates per XYZ SOPrdquo
ldquohellipappropriate controls not establishedhelliprdquo
Each additional observation adds
reasons to confirm that this is very likely a system
with intentional lsquoholesrsquo in its
defenses
Preconditions
Rationalization amp Attitude
Pressure amp Incentive
Opportunity ndashlsquoholes in the QMSrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 56
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 57
Attitude towards the behavior
Subjective norm
Perceived behavioral
control
IntentionFuture
Behavior
usually found to predict behavioral intentions with a high degree of accuracy
intentions in combination with perceived behavioral control can account for a considerable proportion of variance in behavior
PastBehavior
Ajen I The theory of planned behavior ORGANIZATIONAL BEHAVIOR AND HUMAN DECISION PROCESSES 50 179-211 (1991)
Heparin tragedy 2007 and 2008
FDA reports 149 deaths with allergic or hypersensitivity symptoms during that period
bull Contaminated heparin from China
QC Testing
bull Initial testing failed to detect the contaminant
Pharmacovigilence
bull Signals in the pharmacovigilence systems responded slowly and
Eventually the severity of reactions associated made it likely that the contamination would be detected
bull too late for those who died or were injured
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 58
Congressman Shimkus When the drug safety system fails people get sick Some die
bull Some of these people are already very vulnerable and proving the cause of harm from impurities adulteration and counterfeits can be elusive
It is hard to detect harm
bull Certainly the companies are obligated to ensure a culture of quality and maintain vigilance as well This reflects a systems approach to safety
FDA inspectors look for a culture of quality at
manufacturing facilities
bull FDA policies led to the failure to inspect the Chinese plantThis system approach wasnt at
play here
bull While it doesnt deny the counterfeit source tries to say that counterfeits didnt cause the reaction as if the adulteration itself was no big deal Is this an acceptable mindset helliphelliphellip
This brings me to China and its quality culture or lack thereof
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 59
ONE HUNDRED TENTH CONGRESS SECOND SESSION APRIL 29 2008 Serial No 110-109
21 CFR PART 211 SUBPARTS -Deviations signal gaps in CoQ
bullGENERAL PROVISIONSA
bullORGANIZATION AND PERSONNELB
bullBUILDINGS AND FACILITIESC
bullEQUIPMENTD
bullCONTROL OF COMPONENTS AND DRUG PRODUCT CONTAINERS AND CLOSURESE
bullPRODUCTION AND PROCESS CONTROLSF
bullPACKAGING AND LABELING CONTROLG
bullHOLDING AND DISTRIBUTIONH
bullLABORATORY CONTROLSI
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 60
For example the combinationhellip
The Power of Habit Why We Do What We Do in Life and Business Charles Duhigg (2012)
bull Scientific methodology
bull Engineering Design
bull Plan-Do-Check-ActConsciously
bull Habits (work to get rid of bad ones)
bull Habits (work to cultivate good one)
bull Keystone habits (Safety Alcoa ALCOA of data integrity)
Subconsciously
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 61
CoQ How
bull What are the predictors of CoQCoQ Manifests by Design -
lsquoquality by designrsquo the foundation
bull 1 2 3When do people change their behaviors
bull A B C D (any body can dance)What makes a QMS effective
bull X Y ZWhen proactive compliance occurs
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 62
Going beyond rules pays
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 63
Human behavior Connecting the Dots With the Right Connectors
GXPs ndash rational behaviors
How proactive compliance is achieved X Y Z
Quality Management System
What makes a QMS reliable A B C D
Culture of Quality
Why people change their behavior 1 2 3
Human Behaviors Beyond GXPs
Predictors of Culture of Quality
Why What and How of Culture of Quality
9192014 copy Ajaz S Hussain | INSIGHT ADVICE amp SOLUTIONS LLC 64
Predictors of CoQ Act consciously in the interest of patients ndash when no one is looking
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 65
Only four attributes
actually predict a culture of
quality
Leadership Emphasis
Message Credibility
Peer Involvement
Employee Empower-ment
People will change their
behavior if they see the new behavior as
Normal
(1)
Rewarding
(2)
Easy
(3)
Dr W Edwards Demingrsquos - ldquoOut of the crisisrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 66
The journey requires leadership
with Profound Knowledge as a
guide
bull As leaders responsible for system change top management is most in need of profound knowledge
bull Quality is often determined in the boardroom
bull Problems arise when management reacts to common cause or chance variation as if it were special cause variation
bull Prediction based in theory provides a foundation for planning a course of action Plan ndash Do ndash Check ndash Act
bull The leader serves the people with clear vision and guidance to empower them To be empowered is to share ownership in the identity
bull Giving people a certain degree of control over their work fulfills the need for freedom and provides opportunity for taking joy in work
Profound Knowledge as a guide
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 67
Appreciation for a System
Theory of Knowledge
Knowledge about
Variation
Human Behavior -Psychology of Change
A
B
C
D+
Systems Approach for ErrorDeviation Management
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 68
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
Human error models and management J Reason BMJ 320 768ndash770 (2000)
D+
Culture of Error Management परबधनbull Error strain
bull Covering upFear of Errors
bull Anticipation
bull Risk takingAwareness
bull Development QbDRFT
bull Error detection Communication
bull Analyzing errors Correction
Mastery orientation
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 69
Dots amp Connections
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 70
CoQ
1
2
3
QMS
A
B
C
D
GXP Behaviors
X
Y
Z
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 71
Culture of Quality
Normal
Rewarding
Easy
QMS
System
Knowledge
Variation
Behavior
Behavior -GXPs
Fear Removed
Mastery
Awareness
EnvironmentLeadership Emphasis
Message Credibility
Peer Involvement
Employee Empowerment
Connect to CoQ
Connect to GXPs
A Framework and a Tool (for gap analysis)
Process Validation (2011) Statistical Confidence Continued Process Verificationhellip
3122015 Ajaz S Hussain PhD 30
httpwwwslideshareneta2zpharmsciperformance-testing-pharmaceutical-quality-2004(accessed 6 December 2014)
3122015 Ajaz S Hussain PhD 31
Supplier amp Excipient Qualification amp CAPA
Out of Specification events are difficult to resolve
Excipient functionality can be a significant contributing factor
Sometimes reluctantly have to settle with - ldquoRoot cause unknown
600 days
I have inserted the ldquo600 daysrsquo on the figure ndash this is based on cases I have seen while at FDA)
3122015 Ajaz S Hussain PhD 32
Prevention of OOS and Effective CAPA needs a focus on critical functional attributes
Out of Specification events are difficult to resolve
Excipient functionality can be a significant contributing factor
Sometimes reluctantly have to settle with - ldquoRoot cause unknown
Compendial standards and manufacturing
3122015 Ajaz S Hussain PhD 33
Practice Control Process Maturity
Initial
bull Unpredictable
Managed
bull Characterized but reactive
Defined
bull Characterized proactive
Measured amp Controlled
bull In control
Optimizing
bull Focus on improvement
3122015 Ajaz S Hussain PhD 34
Capability Maturity Model Integration Carnegie Mellon University
A validated process
Maturity Level amp Assurance of Quality
Managed Characterized but reactive
High perceived risk of
lsquoCheating by Designrsquo
ldquoTrial Injectionsrdquo
ldquoTesting in to Compliancerdquo
Defined Characterized proactive
Lower level of assurance
Stopping amp Correcting
Batch Rejection
Measured amp
ControlledIn control
Quality by Design
Quality Assured
Improvement Opportunities
3122015 Ajaz S Hussain PhD 35
At the individual level in QC functionndash how often does this occur
attitude toward
performing the behavior
Process validation is
done so quality is good
test prone to error
ldquoBatch failure means I made
a mistakerdquo
subjective norm
documentation not critical
Compendial testing
sufficient
Indian regulators
collect amp test samples ndash no issue there
3122015 Ajaz S Hussain PhD 36
ldquoTesting into compliancerdquo
In general ndash low empowerment is a significant challenge (low perceived behavioral control) plus reasons to rationalizehellip
Excipient Functionality Can be critical for safety efficacy and quality
3122015 Ajaz S Hussain PhD 37
July 15 2005 FDA Public Health Advisory Safety Warnings Regarding Use of Fentanyl Transdermal (Skin) Patches
A pattern of failure Pharmaceutical Equivalence by Design (2004)
3122015 Ajaz S Hussain PhD 38
httpwwwnihsgojpdrugPhForumdocuments041122Hussain041122pdf
An attempt to correct
3122015 Ajaz S Hussain PhD 39
httpipecamericasorgsystemfilesKeyNoteEF13May11LawrenceYu(FDA)pdf
Recent challenges
3122015 Ajaz S Hussain PhD 40
Th
e V
oic
e o
f th
eA
mer
ican
P
sych
iatr
ic A
sso
ciat
ion
and
th
e P
sych
iatr
ic C
om
mu
nit
y
Physicians Question FDAs Confidence in Generic Drugs Safety Efficacy (OCTOBER 24 2014)
bull ldquomost patientsrdquo is not the same asldquo all patientsrdquo and whether the 24 to 36 normal subjects used in the agencys bioequivalency tests represents the full range of individual variation in the way drugs are absorbed across the pharmaceutical using population is uncertain
bull Individuals can sometimes be allergic and react differently to whatever substance goes into making up the capsule or the tablet
FDA Flags Generic Versions of ADHD Medication(NOVEMBER 14 2014)
bull FDA changed the therapeutic equivalence (TE) rating from AB to BXmdashmeaning that the products are still approved and can be prescribed but are no longer recommended as automatic substitutes
RLD Variability Can be a block-buster opportunityFocus on lsquocontrol strategyrsquo
bull Overcoming CP amp IP provide FDA a submission they need to address CP
bull Then begin with QTPP CQArsquos hellip skip lsquodesign spacersquo and focus on lsquocontrol strategy
bull The entire development team should read the complete package insert of RLD
bull Discuss to ensure a common understandingbull Failure modes amp intended use
bull Pharmaceutical Equivalence
bull Bioequivalence
bull Other studies
QbD Challenges
3122015 Ajaz S Hussain PhD 41
NewRegulators are not prepared to handle QbD applications
NewMisalignment of international regulatory authorities
New and Generics
RampD incentivized for lsquoshots on the goalrsquo not QbD
GenericsLack of belief in business case ndash lsquoGenerics are all about file first figure out laterrsquo
Biologics Lack of technology to execute
Ted Fuhr Mackinsey amp Company June 2010 FDA Advisory Committee
Summary
bull Excipient functionality can contribute in critical ways to product quality amp performance adequate control is necessary
bull Our databases tools and knowledge are lagging behind the rapidly increasing complexity and uncertainty
bull Risk to quality and to business is increasing and regulatory transitions pose additional difficulties
bull Effective knowledge management ndash IT and Human practices ndash is critical for organizational lsquobottom-linersquo
bull We all must come together collaboratively to address the urgent needs we owe it to the patients we serve
3122015 Ajaz S Hussain PhD 42
Knowledge Management amp Culture of Quality
Ajaz S Hussain PhD
Insight Advice amp Solutions LLCMaryland USA
Executive Director the National Institute for Pharmaceutical Technology amp Education
3122015 Ajaz S Hussain PhD 43
3122015 Ajaz S Hussain PhD 44
Life-cycle approach needed for knowledge management
Investigational ProductscGMPs
DevelopmentTechnology
TransferCommercial
ManufacturingDiscontinuation
Management Responsibility
Process Performance amp Product Quality Monitoring SystemCAPA Change Management Management Review
PQS Elements
Knowledge ManagementQuality Risk ManagementEnablers
ICH Q10 KM is a systematic approach to acquiring analyzing storing and disseminating information related to products manufacturing processes and components
Based on ICH Q10
ldquowe can be blind to the obvious and we are also blind to our blindnessrdquo
Daniel Kahneman Thinking Fast and Slow
3142015 Ajazajazhussaincom 45
httpwebmiteduperscipeopleadelsoncheckershadow_proofhtml
3122015 Ajaz S Hussain PhD 46
1938 The Federal Food Drug and Cosmetic (FDC)
bull 1937 Elixir of Sulfanilamide
1962 Kefauver-Harris Drug Amendments
bull 1962 Thalidomide
bull 1960 Color Additive Amendment
bull 1958 Food Additives Amendment GRAS
bull 1960 Color Additive Amendment
bull 1958 Food Additives Amendment GRAS
1992 Generic Drug Enforcement Act
bull1989 L-Tryptophan
bull 1989 Generic Drug Scandal
bull 1988 Food and Drug Administration Act
bull 1984 Fines Enhancement Laws Drug Price Competition and Patent Term Restoration Act
2012 Food and Drug Administration Safety and Innovation Act (FDASIA)
bull 2007 Heparin Disaster
2013 Pandemic and All-Hazards Preparedness Reauthorization Act (PAHPRA) Drug Quality and Security Act
bull 2012 The Deadly Meningitis Outbreak
Past 70 years 1937 ndash 2007 The diethylene glycol (DEG) narrative
3122015 Ajaz S Hussain PhD 47
0
5
10
15
20
25
30
35
Yea
rs
DEG Years since the previous incident
0
50
100
150
200
250
300
350
Number of Reported Deaths
1937
Eli
xir
of
Sulf
anil
amid
e
2007T
ootp
aste
conta
min
atio
n
0 70 years 0 70 years
Frequent reports
Mumbai Mumbai
Data from Excipient Fest Janeen Skutnik Chair ndashIPECAmericas 2009
Past 70+ years DEG contamination or economically motivated adulteration
3122015 Ajaz S Hussain PhD 48
Reported cases underestimate the real tragedy rapid intervention may not occur
Epidemic of Pediatric Deaths From Acute Renal Failure Caused by
Diethylene Glycol Poisoning JAMA 1998279(15)1175-1180
doi101001jama279151175
Month of hospital admission for children with
acute renal failure Haiti
October 1995-October 1996
Diethylene glycol poisoning in Gurgaon India 1998Bulletin of the World Health Organization 2001 79 88ndash95
We report a second episode of poisoning occurring in 1998 in
India as a result of children ingesting diethylene glycol at
least 33 children are known to have died
At the beginning of the investigation we never imagined that
contaminated medicine was causing acute renal failure in
children
A brand of cough expectorant manufactured by a local
pharmaceutical company was found by the Central Drugs
Laboratory Calcutta to contain 175 (vv) diethylene
glycol
The district and state drug controller had tested many
samples using thin layer chromatography before a sample of
medicine tested positive for diethylene glycol at the Central
Drugs Laboratory None of the earlier samples was found to
be contaminated
3122015 Ajaz S Hussain PhD 49
Guidance for Industry Testing of
Glycerin for Diethylene Glycol
CDER May 2007 Compliance
1 Manufacturers did not perform full
identity testing on the glycerin raw
material including tests to quantify
the amount of DEG
2 Relied on the certificate of analysis
(COA)
3 The origin of the glycerin was not
easily apparent from the COA
4 The COA was often a copy of a COA
on the letterhead of the distributor
5 The chain of custody or distribution
history of the glycerin was also not
readily known
USP Glycerin Monograph
Type of Posting Revision Bulletin
Posting Date 04ndashFebndash2009
Official Date 01ndashMayndash2009
Because of the serious hazards
associated withhellip and in response to
recommendations set forth in the
FDA Guidance for Industry Testing
of Glycerin for Diethylene Glycol
published in May 2007 USP has
revised the USP Glycerin monograph
Because diethylene glycol and
ethylene glycol are considered
unacceptable toxic substances the
testing of USP Glycerin should
demonstrate the absence of these
substances
April 2007 FDA request to
USP to revise the Glycerin
monographrsquos
IDENTIFICATION section
Revision includes adding ndash
Identification test B LIMIT OF
DIETHYLENE GLYCOL AND
ETHYLENE GLYCOL to detect
and quantify DEGEG in Glycerin
minus Is no longer part of the impurity
testing
ldquoLimit of DEG and Related
Compoundsrdquo minus Introduces a
capillary gas-chromatographic
(GC) method with flame ionization
detection (FID) minus Limit of NMT
010 each for diethylene glycol
and ethylene glycol is found
70+ years to get here how difficult will it be to change habits such as lsquoblind reliance of COArsquo
3122015 Ajaz S Hussain PhD 50
Personality and Habitual Frame Biases
Myers Brigs ENTJ (first tested at FDA)
S
TF
Expanded frame
future
possibilities
objective lsquocause
and effectrsquo
Expanded frame
future
possibilities
people and
relationships
Narrow frame
the present
individuals and
relationships
Narrow frame
the present
objective
cause and
effect
N
Based on Stanford Webinar - How to Overcome the Top 3 MegaBiases in Decision-Making
Stanford Universityrsquos Strategic Decision and Risk Management certificate program
From Mapping a Managers Brain on Incentives
Social
influences
Relative
thinking
UncertaintyComplexity
By Design Intention to act consciously
bull In the interest of patients and to continually improve this ability bull To provide a healing touch ndash one life at a time in what we do and how we
do it
1292014 Ajazajazhussaincom 51
Consciously
Scientific methodology
Engineering Design
Plan-Do-Check-Act
Subconsciously
Habits (work to get rid of bad ones)
Habits (work to cultivate good one)
Keystone habits (Safety Alcoa ALCOA of data integrity)
The Power of Habit Why We Do What We Do in Life and Business Charles Duhigg (2012)
httpwwwslideshareneta2zpharmscipharmaceutical-culture-of-quality
What does it take to come out of the cGMP crisis
Persuasive demonstration of
(1) Ability to face facts
(2) Legal amp regulatory requirements
3) Systems approach to quality
4) Changing behavior amp culture
What is often missed or is unconvincing is how you will strengthen culture of quality
ldquoLet one who wants to move and convince others first be convinced and moved themselvesrdquo Thomas Carlyle
Signals that question the competence motivation andor integrity of company personnel
Do not defend the plainly indefensible it adds further serious credibility costs
3142015 Ajazajazhussaincom 52
Quality is everyones responsibility
Lack of knowledge that is
the problem
If you do not know how to ask the
right question you discover nothing
If you cant describe what you
are doing as a process you dont know what youre
doing
Rational behavior requires theory
Reactive behavior requires only reflex
action
Whenever there is fear you will get wrong figures
3142015 Ajazajazhussaincom 53
Selected quotes W Edwards Deming
3142015 Ajazajazhussaincom 54
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
ldquoWE CANNOT CHANGE THE HUMAN CONDITION BUThellipWE CAN CHANGE THE CONDITIONS UNDER WHICH HUMANS WORKrdquo JAMES REASON
Disregard to Malice
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 55
ldquohelliprecords not completed
contemporaneouslyrdquo
ldquohellipobserved analyst back-date logbooksrdquo
ldquohelliptrial injectionshelliprdquo
ldquohellipresults failing specifications are
retested until acceptable results are obtainedhelliprdquo
ldquohellipover-writing electronic raw datahelliprdquo
ldquohellipOOS not investigates per XYZ SOPrdquo
ldquohellipappropriate controls not establishedhelliprdquo
Each additional observation adds
reasons to confirm that this is very likely a system
with intentional lsquoholesrsquo in its
defenses
Preconditions
Rationalization amp Attitude
Pressure amp Incentive
Opportunity ndashlsquoholes in the QMSrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 56
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 57
Attitude towards the behavior
Subjective norm
Perceived behavioral
control
IntentionFuture
Behavior
usually found to predict behavioral intentions with a high degree of accuracy
intentions in combination with perceived behavioral control can account for a considerable proportion of variance in behavior
PastBehavior
Ajen I The theory of planned behavior ORGANIZATIONAL BEHAVIOR AND HUMAN DECISION PROCESSES 50 179-211 (1991)
Heparin tragedy 2007 and 2008
FDA reports 149 deaths with allergic or hypersensitivity symptoms during that period
bull Contaminated heparin from China
QC Testing
bull Initial testing failed to detect the contaminant
Pharmacovigilence
bull Signals in the pharmacovigilence systems responded slowly and
Eventually the severity of reactions associated made it likely that the contamination would be detected
bull too late for those who died or were injured
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 58
Congressman Shimkus When the drug safety system fails people get sick Some die
bull Some of these people are already very vulnerable and proving the cause of harm from impurities adulteration and counterfeits can be elusive
It is hard to detect harm
bull Certainly the companies are obligated to ensure a culture of quality and maintain vigilance as well This reflects a systems approach to safety
FDA inspectors look for a culture of quality at
manufacturing facilities
bull FDA policies led to the failure to inspect the Chinese plantThis system approach wasnt at
play here
bull While it doesnt deny the counterfeit source tries to say that counterfeits didnt cause the reaction as if the adulteration itself was no big deal Is this an acceptable mindset helliphelliphellip
This brings me to China and its quality culture or lack thereof
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 59
ONE HUNDRED TENTH CONGRESS SECOND SESSION APRIL 29 2008 Serial No 110-109
21 CFR PART 211 SUBPARTS -Deviations signal gaps in CoQ
bullGENERAL PROVISIONSA
bullORGANIZATION AND PERSONNELB
bullBUILDINGS AND FACILITIESC
bullEQUIPMENTD
bullCONTROL OF COMPONENTS AND DRUG PRODUCT CONTAINERS AND CLOSURESE
bullPRODUCTION AND PROCESS CONTROLSF
bullPACKAGING AND LABELING CONTROLG
bullHOLDING AND DISTRIBUTIONH
bullLABORATORY CONTROLSI
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 60
For example the combinationhellip
The Power of Habit Why We Do What We Do in Life and Business Charles Duhigg (2012)
bull Scientific methodology
bull Engineering Design
bull Plan-Do-Check-ActConsciously
bull Habits (work to get rid of bad ones)
bull Habits (work to cultivate good one)
bull Keystone habits (Safety Alcoa ALCOA of data integrity)
Subconsciously
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 61
CoQ How
bull What are the predictors of CoQCoQ Manifests by Design -
lsquoquality by designrsquo the foundation
bull 1 2 3When do people change their behaviors
bull A B C D (any body can dance)What makes a QMS effective
bull X Y ZWhen proactive compliance occurs
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 62
Going beyond rules pays
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 63
Human behavior Connecting the Dots With the Right Connectors
GXPs ndash rational behaviors
How proactive compliance is achieved X Y Z
Quality Management System
What makes a QMS reliable A B C D
Culture of Quality
Why people change their behavior 1 2 3
Human Behaviors Beyond GXPs
Predictors of Culture of Quality
Why What and How of Culture of Quality
9192014 copy Ajaz S Hussain | INSIGHT ADVICE amp SOLUTIONS LLC 64
Predictors of CoQ Act consciously in the interest of patients ndash when no one is looking
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 65
Only four attributes
actually predict a culture of
quality
Leadership Emphasis
Message Credibility
Peer Involvement
Employee Empower-ment
People will change their
behavior if they see the new behavior as
Normal
(1)
Rewarding
(2)
Easy
(3)
Dr W Edwards Demingrsquos - ldquoOut of the crisisrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 66
The journey requires leadership
with Profound Knowledge as a
guide
bull As leaders responsible for system change top management is most in need of profound knowledge
bull Quality is often determined in the boardroom
bull Problems arise when management reacts to common cause or chance variation as if it were special cause variation
bull Prediction based in theory provides a foundation for planning a course of action Plan ndash Do ndash Check ndash Act
bull The leader serves the people with clear vision and guidance to empower them To be empowered is to share ownership in the identity
bull Giving people a certain degree of control over their work fulfills the need for freedom and provides opportunity for taking joy in work
Profound Knowledge as a guide
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 67
Appreciation for a System
Theory of Knowledge
Knowledge about
Variation
Human Behavior -Psychology of Change
A
B
C
D+
Systems Approach for ErrorDeviation Management
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 68
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
Human error models and management J Reason BMJ 320 768ndash770 (2000)
D+
Culture of Error Management परबधनbull Error strain
bull Covering upFear of Errors
bull Anticipation
bull Risk takingAwareness
bull Development QbDRFT
bull Error detection Communication
bull Analyzing errors Correction
Mastery orientation
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 69
Dots amp Connections
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 70
CoQ
1
2
3
QMS
A
B
C
D
GXP Behaviors
X
Y
Z
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 71
Culture of Quality
Normal
Rewarding
Easy
QMS
System
Knowledge
Variation
Behavior
Behavior -GXPs
Fear Removed
Mastery
Awareness
EnvironmentLeadership Emphasis
Message Credibility
Peer Involvement
Employee Empowerment
Connect to CoQ
Connect to GXPs
A Framework and a Tool (for gap analysis)
3122015 Ajaz S Hussain PhD 31
Supplier amp Excipient Qualification amp CAPA
Out of Specification events are difficult to resolve
Excipient functionality can be a significant contributing factor
Sometimes reluctantly have to settle with - ldquoRoot cause unknown
600 days
I have inserted the ldquo600 daysrsquo on the figure ndash this is based on cases I have seen while at FDA)
3122015 Ajaz S Hussain PhD 32
Prevention of OOS and Effective CAPA needs a focus on critical functional attributes
Out of Specification events are difficult to resolve
Excipient functionality can be a significant contributing factor
Sometimes reluctantly have to settle with - ldquoRoot cause unknown
Compendial standards and manufacturing
3122015 Ajaz S Hussain PhD 33
Practice Control Process Maturity
Initial
bull Unpredictable
Managed
bull Characterized but reactive
Defined
bull Characterized proactive
Measured amp Controlled
bull In control
Optimizing
bull Focus on improvement
3122015 Ajaz S Hussain PhD 34
Capability Maturity Model Integration Carnegie Mellon University
A validated process
Maturity Level amp Assurance of Quality
Managed Characterized but reactive
High perceived risk of
lsquoCheating by Designrsquo
ldquoTrial Injectionsrdquo
ldquoTesting in to Compliancerdquo
Defined Characterized proactive
Lower level of assurance
Stopping amp Correcting
Batch Rejection
Measured amp
ControlledIn control
Quality by Design
Quality Assured
Improvement Opportunities
3122015 Ajaz S Hussain PhD 35
At the individual level in QC functionndash how often does this occur
attitude toward
performing the behavior
Process validation is
done so quality is good
test prone to error
ldquoBatch failure means I made
a mistakerdquo
subjective norm
documentation not critical
Compendial testing
sufficient
Indian regulators
collect amp test samples ndash no issue there
3122015 Ajaz S Hussain PhD 36
ldquoTesting into compliancerdquo
In general ndash low empowerment is a significant challenge (low perceived behavioral control) plus reasons to rationalizehellip
Excipient Functionality Can be critical for safety efficacy and quality
3122015 Ajaz S Hussain PhD 37
July 15 2005 FDA Public Health Advisory Safety Warnings Regarding Use of Fentanyl Transdermal (Skin) Patches
A pattern of failure Pharmaceutical Equivalence by Design (2004)
3122015 Ajaz S Hussain PhD 38
httpwwwnihsgojpdrugPhForumdocuments041122Hussain041122pdf
An attempt to correct
3122015 Ajaz S Hussain PhD 39
httpipecamericasorgsystemfilesKeyNoteEF13May11LawrenceYu(FDA)pdf
Recent challenges
3122015 Ajaz S Hussain PhD 40
Th
e V
oic
e o
f th
eA
mer
ican
P
sych
iatr
ic A
sso
ciat
ion
and
th
e P
sych
iatr
ic C
om
mu
nit
y
Physicians Question FDAs Confidence in Generic Drugs Safety Efficacy (OCTOBER 24 2014)
bull ldquomost patientsrdquo is not the same asldquo all patientsrdquo and whether the 24 to 36 normal subjects used in the agencys bioequivalency tests represents the full range of individual variation in the way drugs are absorbed across the pharmaceutical using population is uncertain
bull Individuals can sometimes be allergic and react differently to whatever substance goes into making up the capsule or the tablet
FDA Flags Generic Versions of ADHD Medication(NOVEMBER 14 2014)
bull FDA changed the therapeutic equivalence (TE) rating from AB to BXmdashmeaning that the products are still approved and can be prescribed but are no longer recommended as automatic substitutes
RLD Variability Can be a block-buster opportunityFocus on lsquocontrol strategyrsquo
bull Overcoming CP amp IP provide FDA a submission they need to address CP
bull Then begin with QTPP CQArsquos hellip skip lsquodesign spacersquo and focus on lsquocontrol strategy
bull The entire development team should read the complete package insert of RLD
bull Discuss to ensure a common understandingbull Failure modes amp intended use
bull Pharmaceutical Equivalence
bull Bioequivalence
bull Other studies
QbD Challenges
3122015 Ajaz S Hussain PhD 41
NewRegulators are not prepared to handle QbD applications
NewMisalignment of international regulatory authorities
New and Generics
RampD incentivized for lsquoshots on the goalrsquo not QbD
GenericsLack of belief in business case ndash lsquoGenerics are all about file first figure out laterrsquo
Biologics Lack of technology to execute
Ted Fuhr Mackinsey amp Company June 2010 FDA Advisory Committee
Summary
bull Excipient functionality can contribute in critical ways to product quality amp performance adequate control is necessary
bull Our databases tools and knowledge are lagging behind the rapidly increasing complexity and uncertainty
bull Risk to quality and to business is increasing and regulatory transitions pose additional difficulties
bull Effective knowledge management ndash IT and Human practices ndash is critical for organizational lsquobottom-linersquo
bull We all must come together collaboratively to address the urgent needs we owe it to the patients we serve
3122015 Ajaz S Hussain PhD 42
Knowledge Management amp Culture of Quality
Ajaz S Hussain PhD
Insight Advice amp Solutions LLCMaryland USA
Executive Director the National Institute for Pharmaceutical Technology amp Education
3122015 Ajaz S Hussain PhD 43
3122015 Ajaz S Hussain PhD 44
Life-cycle approach needed for knowledge management
Investigational ProductscGMPs
DevelopmentTechnology
TransferCommercial
ManufacturingDiscontinuation
Management Responsibility
Process Performance amp Product Quality Monitoring SystemCAPA Change Management Management Review
PQS Elements
Knowledge ManagementQuality Risk ManagementEnablers
ICH Q10 KM is a systematic approach to acquiring analyzing storing and disseminating information related to products manufacturing processes and components
Based on ICH Q10
ldquowe can be blind to the obvious and we are also blind to our blindnessrdquo
Daniel Kahneman Thinking Fast and Slow
3142015 Ajazajazhussaincom 45
httpwebmiteduperscipeopleadelsoncheckershadow_proofhtml
3122015 Ajaz S Hussain PhD 46
1938 The Federal Food Drug and Cosmetic (FDC)
bull 1937 Elixir of Sulfanilamide
1962 Kefauver-Harris Drug Amendments
bull 1962 Thalidomide
bull 1960 Color Additive Amendment
bull 1958 Food Additives Amendment GRAS
bull 1960 Color Additive Amendment
bull 1958 Food Additives Amendment GRAS
1992 Generic Drug Enforcement Act
bull1989 L-Tryptophan
bull 1989 Generic Drug Scandal
bull 1988 Food and Drug Administration Act
bull 1984 Fines Enhancement Laws Drug Price Competition and Patent Term Restoration Act
2012 Food and Drug Administration Safety and Innovation Act (FDASIA)
bull 2007 Heparin Disaster
2013 Pandemic and All-Hazards Preparedness Reauthorization Act (PAHPRA) Drug Quality and Security Act
bull 2012 The Deadly Meningitis Outbreak
Past 70 years 1937 ndash 2007 The diethylene glycol (DEG) narrative
3122015 Ajaz S Hussain PhD 47
0
5
10
15
20
25
30
35
Yea
rs
DEG Years since the previous incident
0
50
100
150
200
250
300
350
Number of Reported Deaths
1937
Eli
xir
of
Sulf
anil
amid
e
2007T
ootp
aste
conta
min
atio
n
0 70 years 0 70 years
Frequent reports
Mumbai Mumbai
Data from Excipient Fest Janeen Skutnik Chair ndashIPECAmericas 2009
Past 70+ years DEG contamination or economically motivated adulteration
3122015 Ajaz S Hussain PhD 48
Reported cases underestimate the real tragedy rapid intervention may not occur
Epidemic of Pediatric Deaths From Acute Renal Failure Caused by
Diethylene Glycol Poisoning JAMA 1998279(15)1175-1180
doi101001jama279151175
Month of hospital admission for children with
acute renal failure Haiti
October 1995-October 1996
Diethylene glycol poisoning in Gurgaon India 1998Bulletin of the World Health Organization 2001 79 88ndash95
We report a second episode of poisoning occurring in 1998 in
India as a result of children ingesting diethylene glycol at
least 33 children are known to have died
At the beginning of the investigation we never imagined that
contaminated medicine was causing acute renal failure in
children
A brand of cough expectorant manufactured by a local
pharmaceutical company was found by the Central Drugs
Laboratory Calcutta to contain 175 (vv) diethylene
glycol
The district and state drug controller had tested many
samples using thin layer chromatography before a sample of
medicine tested positive for diethylene glycol at the Central
Drugs Laboratory None of the earlier samples was found to
be contaminated
3122015 Ajaz S Hussain PhD 49
Guidance for Industry Testing of
Glycerin for Diethylene Glycol
CDER May 2007 Compliance
1 Manufacturers did not perform full
identity testing on the glycerin raw
material including tests to quantify
the amount of DEG
2 Relied on the certificate of analysis
(COA)
3 The origin of the glycerin was not
easily apparent from the COA
4 The COA was often a copy of a COA
on the letterhead of the distributor
5 The chain of custody or distribution
history of the glycerin was also not
readily known
USP Glycerin Monograph
Type of Posting Revision Bulletin
Posting Date 04ndashFebndash2009
Official Date 01ndashMayndash2009
Because of the serious hazards
associated withhellip and in response to
recommendations set forth in the
FDA Guidance for Industry Testing
of Glycerin for Diethylene Glycol
published in May 2007 USP has
revised the USP Glycerin monograph
Because diethylene glycol and
ethylene glycol are considered
unacceptable toxic substances the
testing of USP Glycerin should
demonstrate the absence of these
substances
April 2007 FDA request to
USP to revise the Glycerin
monographrsquos
IDENTIFICATION section
Revision includes adding ndash
Identification test B LIMIT OF
DIETHYLENE GLYCOL AND
ETHYLENE GLYCOL to detect
and quantify DEGEG in Glycerin
minus Is no longer part of the impurity
testing
ldquoLimit of DEG and Related
Compoundsrdquo minus Introduces a
capillary gas-chromatographic
(GC) method with flame ionization
detection (FID) minus Limit of NMT
010 each for diethylene glycol
and ethylene glycol is found
70+ years to get here how difficult will it be to change habits such as lsquoblind reliance of COArsquo
3122015 Ajaz S Hussain PhD 50
Personality and Habitual Frame Biases
Myers Brigs ENTJ (first tested at FDA)
S
TF
Expanded frame
future
possibilities
objective lsquocause
and effectrsquo
Expanded frame
future
possibilities
people and
relationships
Narrow frame
the present
individuals and
relationships
Narrow frame
the present
objective
cause and
effect
N
Based on Stanford Webinar - How to Overcome the Top 3 MegaBiases in Decision-Making
Stanford Universityrsquos Strategic Decision and Risk Management certificate program
From Mapping a Managers Brain on Incentives
Social
influences
Relative
thinking
UncertaintyComplexity
By Design Intention to act consciously
bull In the interest of patients and to continually improve this ability bull To provide a healing touch ndash one life at a time in what we do and how we
do it
1292014 Ajazajazhussaincom 51
Consciously
Scientific methodology
Engineering Design
Plan-Do-Check-Act
Subconsciously
Habits (work to get rid of bad ones)
Habits (work to cultivate good one)
Keystone habits (Safety Alcoa ALCOA of data integrity)
The Power of Habit Why We Do What We Do in Life and Business Charles Duhigg (2012)
httpwwwslideshareneta2zpharmscipharmaceutical-culture-of-quality
What does it take to come out of the cGMP crisis
Persuasive demonstration of
(1) Ability to face facts
(2) Legal amp regulatory requirements
3) Systems approach to quality
4) Changing behavior amp culture
What is often missed or is unconvincing is how you will strengthen culture of quality
ldquoLet one who wants to move and convince others first be convinced and moved themselvesrdquo Thomas Carlyle
Signals that question the competence motivation andor integrity of company personnel
Do not defend the plainly indefensible it adds further serious credibility costs
3142015 Ajazajazhussaincom 52
Quality is everyones responsibility
Lack of knowledge that is
the problem
If you do not know how to ask the
right question you discover nothing
If you cant describe what you
are doing as a process you dont know what youre
doing
Rational behavior requires theory
Reactive behavior requires only reflex
action
Whenever there is fear you will get wrong figures
3142015 Ajazajazhussaincom 53
Selected quotes W Edwards Deming
3142015 Ajazajazhussaincom 54
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
ldquoWE CANNOT CHANGE THE HUMAN CONDITION BUThellipWE CAN CHANGE THE CONDITIONS UNDER WHICH HUMANS WORKrdquo JAMES REASON
Disregard to Malice
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 55
ldquohelliprecords not completed
contemporaneouslyrdquo
ldquohellipobserved analyst back-date logbooksrdquo
ldquohelliptrial injectionshelliprdquo
ldquohellipresults failing specifications are
retested until acceptable results are obtainedhelliprdquo
ldquohellipover-writing electronic raw datahelliprdquo
ldquohellipOOS not investigates per XYZ SOPrdquo
ldquohellipappropriate controls not establishedhelliprdquo
Each additional observation adds
reasons to confirm that this is very likely a system
with intentional lsquoholesrsquo in its
defenses
Preconditions
Rationalization amp Attitude
Pressure amp Incentive
Opportunity ndashlsquoholes in the QMSrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 56
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 57
Attitude towards the behavior
Subjective norm
Perceived behavioral
control
IntentionFuture
Behavior
usually found to predict behavioral intentions with a high degree of accuracy
intentions in combination with perceived behavioral control can account for a considerable proportion of variance in behavior
PastBehavior
Ajen I The theory of planned behavior ORGANIZATIONAL BEHAVIOR AND HUMAN DECISION PROCESSES 50 179-211 (1991)
Heparin tragedy 2007 and 2008
FDA reports 149 deaths with allergic or hypersensitivity symptoms during that period
bull Contaminated heparin from China
QC Testing
bull Initial testing failed to detect the contaminant
Pharmacovigilence
bull Signals in the pharmacovigilence systems responded slowly and
Eventually the severity of reactions associated made it likely that the contamination would be detected
bull too late for those who died or were injured
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 58
Congressman Shimkus When the drug safety system fails people get sick Some die
bull Some of these people are already very vulnerable and proving the cause of harm from impurities adulteration and counterfeits can be elusive
It is hard to detect harm
bull Certainly the companies are obligated to ensure a culture of quality and maintain vigilance as well This reflects a systems approach to safety
FDA inspectors look for a culture of quality at
manufacturing facilities
bull FDA policies led to the failure to inspect the Chinese plantThis system approach wasnt at
play here
bull While it doesnt deny the counterfeit source tries to say that counterfeits didnt cause the reaction as if the adulteration itself was no big deal Is this an acceptable mindset helliphelliphellip
This brings me to China and its quality culture or lack thereof
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 59
ONE HUNDRED TENTH CONGRESS SECOND SESSION APRIL 29 2008 Serial No 110-109
21 CFR PART 211 SUBPARTS -Deviations signal gaps in CoQ
bullGENERAL PROVISIONSA
bullORGANIZATION AND PERSONNELB
bullBUILDINGS AND FACILITIESC
bullEQUIPMENTD
bullCONTROL OF COMPONENTS AND DRUG PRODUCT CONTAINERS AND CLOSURESE
bullPRODUCTION AND PROCESS CONTROLSF
bullPACKAGING AND LABELING CONTROLG
bullHOLDING AND DISTRIBUTIONH
bullLABORATORY CONTROLSI
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 60
For example the combinationhellip
The Power of Habit Why We Do What We Do in Life and Business Charles Duhigg (2012)
bull Scientific methodology
bull Engineering Design
bull Plan-Do-Check-ActConsciously
bull Habits (work to get rid of bad ones)
bull Habits (work to cultivate good one)
bull Keystone habits (Safety Alcoa ALCOA of data integrity)
Subconsciously
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 61
CoQ How
bull What are the predictors of CoQCoQ Manifests by Design -
lsquoquality by designrsquo the foundation
bull 1 2 3When do people change their behaviors
bull A B C D (any body can dance)What makes a QMS effective
bull X Y ZWhen proactive compliance occurs
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 62
Going beyond rules pays
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 63
Human behavior Connecting the Dots With the Right Connectors
GXPs ndash rational behaviors
How proactive compliance is achieved X Y Z
Quality Management System
What makes a QMS reliable A B C D
Culture of Quality
Why people change their behavior 1 2 3
Human Behaviors Beyond GXPs
Predictors of Culture of Quality
Why What and How of Culture of Quality
9192014 copy Ajaz S Hussain | INSIGHT ADVICE amp SOLUTIONS LLC 64
Predictors of CoQ Act consciously in the interest of patients ndash when no one is looking
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 65
Only four attributes
actually predict a culture of
quality
Leadership Emphasis
Message Credibility
Peer Involvement
Employee Empower-ment
People will change their
behavior if they see the new behavior as
Normal
(1)
Rewarding
(2)
Easy
(3)
Dr W Edwards Demingrsquos - ldquoOut of the crisisrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 66
The journey requires leadership
with Profound Knowledge as a
guide
bull As leaders responsible for system change top management is most in need of profound knowledge
bull Quality is often determined in the boardroom
bull Problems arise when management reacts to common cause or chance variation as if it were special cause variation
bull Prediction based in theory provides a foundation for planning a course of action Plan ndash Do ndash Check ndash Act
bull The leader serves the people with clear vision and guidance to empower them To be empowered is to share ownership in the identity
bull Giving people a certain degree of control over their work fulfills the need for freedom and provides opportunity for taking joy in work
Profound Knowledge as a guide
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 67
Appreciation for a System
Theory of Knowledge
Knowledge about
Variation
Human Behavior -Psychology of Change
A
B
C
D+
Systems Approach for ErrorDeviation Management
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 68
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
Human error models and management J Reason BMJ 320 768ndash770 (2000)
D+
Culture of Error Management परबधनbull Error strain
bull Covering upFear of Errors
bull Anticipation
bull Risk takingAwareness
bull Development QbDRFT
bull Error detection Communication
bull Analyzing errors Correction
Mastery orientation
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 69
Dots amp Connections
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 70
CoQ
1
2
3
QMS
A
B
C
D
GXP Behaviors
X
Y
Z
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 71
Culture of Quality
Normal
Rewarding
Easy
QMS
System
Knowledge
Variation
Behavior
Behavior -GXPs
Fear Removed
Mastery
Awareness
EnvironmentLeadership Emphasis
Message Credibility
Peer Involvement
Employee Empowerment
Connect to CoQ
Connect to GXPs
A Framework and a Tool (for gap analysis)
3122015 Ajaz S Hussain PhD 32
Prevention of OOS and Effective CAPA needs a focus on critical functional attributes
Out of Specification events are difficult to resolve
Excipient functionality can be a significant contributing factor
Sometimes reluctantly have to settle with - ldquoRoot cause unknown
Compendial standards and manufacturing
3122015 Ajaz S Hussain PhD 33
Practice Control Process Maturity
Initial
bull Unpredictable
Managed
bull Characterized but reactive
Defined
bull Characterized proactive
Measured amp Controlled
bull In control
Optimizing
bull Focus on improvement
3122015 Ajaz S Hussain PhD 34
Capability Maturity Model Integration Carnegie Mellon University
A validated process
Maturity Level amp Assurance of Quality
Managed Characterized but reactive
High perceived risk of
lsquoCheating by Designrsquo
ldquoTrial Injectionsrdquo
ldquoTesting in to Compliancerdquo
Defined Characterized proactive
Lower level of assurance
Stopping amp Correcting
Batch Rejection
Measured amp
ControlledIn control
Quality by Design
Quality Assured
Improvement Opportunities
3122015 Ajaz S Hussain PhD 35
At the individual level in QC functionndash how often does this occur
attitude toward
performing the behavior
Process validation is
done so quality is good
test prone to error
ldquoBatch failure means I made
a mistakerdquo
subjective norm
documentation not critical
Compendial testing
sufficient
Indian regulators
collect amp test samples ndash no issue there
3122015 Ajaz S Hussain PhD 36
ldquoTesting into compliancerdquo
In general ndash low empowerment is a significant challenge (low perceived behavioral control) plus reasons to rationalizehellip
Excipient Functionality Can be critical for safety efficacy and quality
3122015 Ajaz S Hussain PhD 37
July 15 2005 FDA Public Health Advisory Safety Warnings Regarding Use of Fentanyl Transdermal (Skin) Patches
A pattern of failure Pharmaceutical Equivalence by Design (2004)
3122015 Ajaz S Hussain PhD 38
httpwwwnihsgojpdrugPhForumdocuments041122Hussain041122pdf
An attempt to correct
3122015 Ajaz S Hussain PhD 39
httpipecamericasorgsystemfilesKeyNoteEF13May11LawrenceYu(FDA)pdf
Recent challenges
3122015 Ajaz S Hussain PhD 40
Th
e V
oic
e o
f th
eA
mer
ican
P
sych
iatr
ic A
sso
ciat
ion
and
th
e P
sych
iatr
ic C
om
mu
nit
y
Physicians Question FDAs Confidence in Generic Drugs Safety Efficacy (OCTOBER 24 2014)
bull ldquomost patientsrdquo is not the same asldquo all patientsrdquo and whether the 24 to 36 normal subjects used in the agencys bioequivalency tests represents the full range of individual variation in the way drugs are absorbed across the pharmaceutical using population is uncertain
bull Individuals can sometimes be allergic and react differently to whatever substance goes into making up the capsule or the tablet
FDA Flags Generic Versions of ADHD Medication(NOVEMBER 14 2014)
bull FDA changed the therapeutic equivalence (TE) rating from AB to BXmdashmeaning that the products are still approved and can be prescribed but are no longer recommended as automatic substitutes
RLD Variability Can be a block-buster opportunityFocus on lsquocontrol strategyrsquo
bull Overcoming CP amp IP provide FDA a submission they need to address CP
bull Then begin with QTPP CQArsquos hellip skip lsquodesign spacersquo and focus on lsquocontrol strategy
bull The entire development team should read the complete package insert of RLD
bull Discuss to ensure a common understandingbull Failure modes amp intended use
bull Pharmaceutical Equivalence
bull Bioequivalence
bull Other studies
QbD Challenges
3122015 Ajaz S Hussain PhD 41
NewRegulators are not prepared to handle QbD applications
NewMisalignment of international regulatory authorities
New and Generics
RampD incentivized for lsquoshots on the goalrsquo not QbD
GenericsLack of belief in business case ndash lsquoGenerics are all about file first figure out laterrsquo
Biologics Lack of technology to execute
Ted Fuhr Mackinsey amp Company June 2010 FDA Advisory Committee
Summary
bull Excipient functionality can contribute in critical ways to product quality amp performance adequate control is necessary
bull Our databases tools and knowledge are lagging behind the rapidly increasing complexity and uncertainty
bull Risk to quality and to business is increasing and regulatory transitions pose additional difficulties
bull Effective knowledge management ndash IT and Human practices ndash is critical for organizational lsquobottom-linersquo
bull We all must come together collaboratively to address the urgent needs we owe it to the patients we serve
3122015 Ajaz S Hussain PhD 42
Knowledge Management amp Culture of Quality
Ajaz S Hussain PhD
Insight Advice amp Solutions LLCMaryland USA
Executive Director the National Institute for Pharmaceutical Technology amp Education
3122015 Ajaz S Hussain PhD 43
3122015 Ajaz S Hussain PhD 44
Life-cycle approach needed for knowledge management
Investigational ProductscGMPs
DevelopmentTechnology
TransferCommercial
ManufacturingDiscontinuation
Management Responsibility
Process Performance amp Product Quality Monitoring SystemCAPA Change Management Management Review
PQS Elements
Knowledge ManagementQuality Risk ManagementEnablers
ICH Q10 KM is a systematic approach to acquiring analyzing storing and disseminating information related to products manufacturing processes and components
Based on ICH Q10
ldquowe can be blind to the obvious and we are also blind to our blindnessrdquo
Daniel Kahneman Thinking Fast and Slow
3142015 Ajazajazhussaincom 45
httpwebmiteduperscipeopleadelsoncheckershadow_proofhtml
3122015 Ajaz S Hussain PhD 46
1938 The Federal Food Drug and Cosmetic (FDC)
bull 1937 Elixir of Sulfanilamide
1962 Kefauver-Harris Drug Amendments
bull 1962 Thalidomide
bull 1960 Color Additive Amendment
bull 1958 Food Additives Amendment GRAS
bull 1960 Color Additive Amendment
bull 1958 Food Additives Amendment GRAS
1992 Generic Drug Enforcement Act
bull1989 L-Tryptophan
bull 1989 Generic Drug Scandal
bull 1988 Food and Drug Administration Act
bull 1984 Fines Enhancement Laws Drug Price Competition and Patent Term Restoration Act
2012 Food and Drug Administration Safety and Innovation Act (FDASIA)
bull 2007 Heparin Disaster
2013 Pandemic and All-Hazards Preparedness Reauthorization Act (PAHPRA) Drug Quality and Security Act
bull 2012 The Deadly Meningitis Outbreak
Past 70 years 1937 ndash 2007 The diethylene glycol (DEG) narrative
3122015 Ajaz S Hussain PhD 47
0
5
10
15
20
25
30
35
Yea
rs
DEG Years since the previous incident
0
50
100
150
200
250
300
350
Number of Reported Deaths
1937
Eli
xir
of
Sulf
anil
amid
e
2007T
ootp
aste
conta
min
atio
n
0 70 years 0 70 years
Frequent reports
Mumbai Mumbai
Data from Excipient Fest Janeen Skutnik Chair ndashIPECAmericas 2009
Past 70+ years DEG contamination or economically motivated adulteration
3122015 Ajaz S Hussain PhD 48
Reported cases underestimate the real tragedy rapid intervention may not occur
Epidemic of Pediatric Deaths From Acute Renal Failure Caused by
Diethylene Glycol Poisoning JAMA 1998279(15)1175-1180
doi101001jama279151175
Month of hospital admission for children with
acute renal failure Haiti
October 1995-October 1996
Diethylene glycol poisoning in Gurgaon India 1998Bulletin of the World Health Organization 2001 79 88ndash95
We report a second episode of poisoning occurring in 1998 in
India as a result of children ingesting diethylene glycol at
least 33 children are known to have died
At the beginning of the investigation we never imagined that
contaminated medicine was causing acute renal failure in
children
A brand of cough expectorant manufactured by a local
pharmaceutical company was found by the Central Drugs
Laboratory Calcutta to contain 175 (vv) diethylene
glycol
The district and state drug controller had tested many
samples using thin layer chromatography before a sample of
medicine tested positive for diethylene glycol at the Central
Drugs Laboratory None of the earlier samples was found to
be contaminated
3122015 Ajaz S Hussain PhD 49
Guidance for Industry Testing of
Glycerin for Diethylene Glycol
CDER May 2007 Compliance
1 Manufacturers did not perform full
identity testing on the glycerin raw
material including tests to quantify
the amount of DEG
2 Relied on the certificate of analysis
(COA)
3 The origin of the glycerin was not
easily apparent from the COA
4 The COA was often a copy of a COA
on the letterhead of the distributor
5 The chain of custody or distribution
history of the glycerin was also not
readily known
USP Glycerin Monograph
Type of Posting Revision Bulletin
Posting Date 04ndashFebndash2009
Official Date 01ndashMayndash2009
Because of the serious hazards
associated withhellip and in response to
recommendations set forth in the
FDA Guidance for Industry Testing
of Glycerin for Diethylene Glycol
published in May 2007 USP has
revised the USP Glycerin monograph
Because diethylene glycol and
ethylene glycol are considered
unacceptable toxic substances the
testing of USP Glycerin should
demonstrate the absence of these
substances
April 2007 FDA request to
USP to revise the Glycerin
monographrsquos
IDENTIFICATION section
Revision includes adding ndash
Identification test B LIMIT OF
DIETHYLENE GLYCOL AND
ETHYLENE GLYCOL to detect
and quantify DEGEG in Glycerin
minus Is no longer part of the impurity
testing
ldquoLimit of DEG and Related
Compoundsrdquo minus Introduces a
capillary gas-chromatographic
(GC) method with flame ionization
detection (FID) minus Limit of NMT
010 each for diethylene glycol
and ethylene glycol is found
70+ years to get here how difficult will it be to change habits such as lsquoblind reliance of COArsquo
3122015 Ajaz S Hussain PhD 50
Personality and Habitual Frame Biases
Myers Brigs ENTJ (first tested at FDA)
S
TF
Expanded frame
future
possibilities
objective lsquocause
and effectrsquo
Expanded frame
future
possibilities
people and
relationships
Narrow frame
the present
individuals and
relationships
Narrow frame
the present
objective
cause and
effect
N
Based on Stanford Webinar - How to Overcome the Top 3 MegaBiases in Decision-Making
Stanford Universityrsquos Strategic Decision and Risk Management certificate program
From Mapping a Managers Brain on Incentives
Social
influences
Relative
thinking
UncertaintyComplexity
By Design Intention to act consciously
bull In the interest of patients and to continually improve this ability bull To provide a healing touch ndash one life at a time in what we do and how we
do it
1292014 Ajazajazhussaincom 51
Consciously
Scientific methodology
Engineering Design
Plan-Do-Check-Act
Subconsciously
Habits (work to get rid of bad ones)
Habits (work to cultivate good one)
Keystone habits (Safety Alcoa ALCOA of data integrity)
The Power of Habit Why We Do What We Do in Life and Business Charles Duhigg (2012)
httpwwwslideshareneta2zpharmscipharmaceutical-culture-of-quality
What does it take to come out of the cGMP crisis
Persuasive demonstration of
(1) Ability to face facts
(2) Legal amp regulatory requirements
3) Systems approach to quality
4) Changing behavior amp culture
What is often missed or is unconvincing is how you will strengthen culture of quality
ldquoLet one who wants to move and convince others first be convinced and moved themselvesrdquo Thomas Carlyle
Signals that question the competence motivation andor integrity of company personnel
Do not defend the plainly indefensible it adds further serious credibility costs
3142015 Ajazajazhussaincom 52
Quality is everyones responsibility
Lack of knowledge that is
the problem
If you do not know how to ask the
right question you discover nothing
If you cant describe what you
are doing as a process you dont know what youre
doing
Rational behavior requires theory
Reactive behavior requires only reflex
action
Whenever there is fear you will get wrong figures
3142015 Ajazajazhussaincom 53
Selected quotes W Edwards Deming
3142015 Ajazajazhussaincom 54
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
ldquoWE CANNOT CHANGE THE HUMAN CONDITION BUThellipWE CAN CHANGE THE CONDITIONS UNDER WHICH HUMANS WORKrdquo JAMES REASON
Disregard to Malice
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 55
ldquohelliprecords not completed
contemporaneouslyrdquo
ldquohellipobserved analyst back-date logbooksrdquo
ldquohelliptrial injectionshelliprdquo
ldquohellipresults failing specifications are
retested until acceptable results are obtainedhelliprdquo
ldquohellipover-writing electronic raw datahelliprdquo
ldquohellipOOS not investigates per XYZ SOPrdquo
ldquohellipappropriate controls not establishedhelliprdquo
Each additional observation adds
reasons to confirm that this is very likely a system
with intentional lsquoholesrsquo in its
defenses
Preconditions
Rationalization amp Attitude
Pressure amp Incentive
Opportunity ndashlsquoholes in the QMSrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 56
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 57
Attitude towards the behavior
Subjective norm
Perceived behavioral
control
IntentionFuture
Behavior
usually found to predict behavioral intentions with a high degree of accuracy
intentions in combination with perceived behavioral control can account for a considerable proportion of variance in behavior
PastBehavior
Ajen I The theory of planned behavior ORGANIZATIONAL BEHAVIOR AND HUMAN DECISION PROCESSES 50 179-211 (1991)
Heparin tragedy 2007 and 2008
FDA reports 149 deaths with allergic or hypersensitivity symptoms during that period
bull Contaminated heparin from China
QC Testing
bull Initial testing failed to detect the contaminant
Pharmacovigilence
bull Signals in the pharmacovigilence systems responded slowly and
Eventually the severity of reactions associated made it likely that the contamination would be detected
bull too late for those who died or were injured
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 58
Congressman Shimkus When the drug safety system fails people get sick Some die
bull Some of these people are already very vulnerable and proving the cause of harm from impurities adulteration and counterfeits can be elusive
It is hard to detect harm
bull Certainly the companies are obligated to ensure a culture of quality and maintain vigilance as well This reflects a systems approach to safety
FDA inspectors look for a culture of quality at
manufacturing facilities
bull FDA policies led to the failure to inspect the Chinese plantThis system approach wasnt at
play here
bull While it doesnt deny the counterfeit source tries to say that counterfeits didnt cause the reaction as if the adulteration itself was no big deal Is this an acceptable mindset helliphelliphellip
This brings me to China and its quality culture or lack thereof
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 59
ONE HUNDRED TENTH CONGRESS SECOND SESSION APRIL 29 2008 Serial No 110-109
21 CFR PART 211 SUBPARTS -Deviations signal gaps in CoQ
bullGENERAL PROVISIONSA
bullORGANIZATION AND PERSONNELB
bullBUILDINGS AND FACILITIESC
bullEQUIPMENTD
bullCONTROL OF COMPONENTS AND DRUG PRODUCT CONTAINERS AND CLOSURESE
bullPRODUCTION AND PROCESS CONTROLSF
bullPACKAGING AND LABELING CONTROLG
bullHOLDING AND DISTRIBUTIONH
bullLABORATORY CONTROLSI
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 60
For example the combinationhellip
The Power of Habit Why We Do What We Do in Life and Business Charles Duhigg (2012)
bull Scientific methodology
bull Engineering Design
bull Plan-Do-Check-ActConsciously
bull Habits (work to get rid of bad ones)
bull Habits (work to cultivate good one)
bull Keystone habits (Safety Alcoa ALCOA of data integrity)
Subconsciously
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 61
CoQ How
bull What are the predictors of CoQCoQ Manifests by Design -
lsquoquality by designrsquo the foundation
bull 1 2 3When do people change their behaviors
bull A B C D (any body can dance)What makes a QMS effective
bull X Y ZWhen proactive compliance occurs
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 62
Going beyond rules pays
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 63
Human behavior Connecting the Dots With the Right Connectors
GXPs ndash rational behaviors
How proactive compliance is achieved X Y Z
Quality Management System
What makes a QMS reliable A B C D
Culture of Quality
Why people change their behavior 1 2 3
Human Behaviors Beyond GXPs
Predictors of Culture of Quality
Why What and How of Culture of Quality
9192014 copy Ajaz S Hussain | INSIGHT ADVICE amp SOLUTIONS LLC 64
Predictors of CoQ Act consciously in the interest of patients ndash when no one is looking
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 65
Only four attributes
actually predict a culture of
quality
Leadership Emphasis
Message Credibility
Peer Involvement
Employee Empower-ment
People will change their
behavior if they see the new behavior as
Normal
(1)
Rewarding
(2)
Easy
(3)
Dr W Edwards Demingrsquos - ldquoOut of the crisisrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 66
The journey requires leadership
with Profound Knowledge as a
guide
bull As leaders responsible for system change top management is most in need of profound knowledge
bull Quality is often determined in the boardroom
bull Problems arise when management reacts to common cause or chance variation as if it were special cause variation
bull Prediction based in theory provides a foundation for planning a course of action Plan ndash Do ndash Check ndash Act
bull The leader serves the people with clear vision and guidance to empower them To be empowered is to share ownership in the identity
bull Giving people a certain degree of control over their work fulfills the need for freedom and provides opportunity for taking joy in work
Profound Knowledge as a guide
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 67
Appreciation for a System
Theory of Knowledge
Knowledge about
Variation
Human Behavior -Psychology of Change
A
B
C
D+
Systems Approach for ErrorDeviation Management
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 68
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
Human error models and management J Reason BMJ 320 768ndash770 (2000)
D+
Culture of Error Management परबधनbull Error strain
bull Covering upFear of Errors
bull Anticipation
bull Risk takingAwareness
bull Development QbDRFT
bull Error detection Communication
bull Analyzing errors Correction
Mastery orientation
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 69
Dots amp Connections
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 70
CoQ
1
2
3
QMS
A
B
C
D
GXP Behaviors
X
Y
Z
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 71
Culture of Quality
Normal
Rewarding
Easy
QMS
System
Knowledge
Variation
Behavior
Behavior -GXPs
Fear Removed
Mastery
Awareness
EnvironmentLeadership Emphasis
Message Credibility
Peer Involvement
Employee Empowerment
Connect to CoQ
Connect to GXPs
A Framework and a Tool (for gap analysis)
Compendial standards and manufacturing
3122015 Ajaz S Hussain PhD 33
Practice Control Process Maturity
Initial
bull Unpredictable
Managed
bull Characterized but reactive
Defined
bull Characterized proactive
Measured amp Controlled
bull In control
Optimizing
bull Focus on improvement
3122015 Ajaz S Hussain PhD 34
Capability Maturity Model Integration Carnegie Mellon University
A validated process
Maturity Level amp Assurance of Quality
Managed Characterized but reactive
High perceived risk of
lsquoCheating by Designrsquo
ldquoTrial Injectionsrdquo
ldquoTesting in to Compliancerdquo
Defined Characterized proactive
Lower level of assurance
Stopping amp Correcting
Batch Rejection
Measured amp
ControlledIn control
Quality by Design
Quality Assured
Improvement Opportunities
3122015 Ajaz S Hussain PhD 35
At the individual level in QC functionndash how often does this occur
attitude toward
performing the behavior
Process validation is
done so quality is good
test prone to error
ldquoBatch failure means I made
a mistakerdquo
subjective norm
documentation not critical
Compendial testing
sufficient
Indian regulators
collect amp test samples ndash no issue there
3122015 Ajaz S Hussain PhD 36
ldquoTesting into compliancerdquo
In general ndash low empowerment is a significant challenge (low perceived behavioral control) plus reasons to rationalizehellip
Excipient Functionality Can be critical for safety efficacy and quality
3122015 Ajaz S Hussain PhD 37
July 15 2005 FDA Public Health Advisory Safety Warnings Regarding Use of Fentanyl Transdermal (Skin) Patches
A pattern of failure Pharmaceutical Equivalence by Design (2004)
3122015 Ajaz S Hussain PhD 38
httpwwwnihsgojpdrugPhForumdocuments041122Hussain041122pdf
An attempt to correct
3122015 Ajaz S Hussain PhD 39
httpipecamericasorgsystemfilesKeyNoteEF13May11LawrenceYu(FDA)pdf
Recent challenges
3122015 Ajaz S Hussain PhD 40
Th
e V
oic
e o
f th
eA
mer
ican
P
sych
iatr
ic A
sso
ciat
ion
and
th
e P
sych
iatr
ic C
om
mu
nit
y
Physicians Question FDAs Confidence in Generic Drugs Safety Efficacy (OCTOBER 24 2014)
bull ldquomost patientsrdquo is not the same asldquo all patientsrdquo and whether the 24 to 36 normal subjects used in the agencys bioequivalency tests represents the full range of individual variation in the way drugs are absorbed across the pharmaceutical using population is uncertain
bull Individuals can sometimes be allergic and react differently to whatever substance goes into making up the capsule or the tablet
FDA Flags Generic Versions of ADHD Medication(NOVEMBER 14 2014)
bull FDA changed the therapeutic equivalence (TE) rating from AB to BXmdashmeaning that the products are still approved and can be prescribed but are no longer recommended as automatic substitutes
RLD Variability Can be a block-buster opportunityFocus on lsquocontrol strategyrsquo
bull Overcoming CP amp IP provide FDA a submission they need to address CP
bull Then begin with QTPP CQArsquos hellip skip lsquodesign spacersquo and focus on lsquocontrol strategy
bull The entire development team should read the complete package insert of RLD
bull Discuss to ensure a common understandingbull Failure modes amp intended use
bull Pharmaceutical Equivalence
bull Bioequivalence
bull Other studies
QbD Challenges
3122015 Ajaz S Hussain PhD 41
NewRegulators are not prepared to handle QbD applications
NewMisalignment of international regulatory authorities
New and Generics
RampD incentivized for lsquoshots on the goalrsquo not QbD
GenericsLack of belief in business case ndash lsquoGenerics are all about file first figure out laterrsquo
Biologics Lack of technology to execute
Ted Fuhr Mackinsey amp Company June 2010 FDA Advisory Committee
Summary
bull Excipient functionality can contribute in critical ways to product quality amp performance adequate control is necessary
bull Our databases tools and knowledge are lagging behind the rapidly increasing complexity and uncertainty
bull Risk to quality and to business is increasing and regulatory transitions pose additional difficulties
bull Effective knowledge management ndash IT and Human practices ndash is critical for organizational lsquobottom-linersquo
bull We all must come together collaboratively to address the urgent needs we owe it to the patients we serve
3122015 Ajaz S Hussain PhD 42
Knowledge Management amp Culture of Quality
Ajaz S Hussain PhD
Insight Advice amp Solutions LLCMaryland USA
Executive Director the National Institute for Pharmaceutical Technology amp Education
3122015 Ajaz S Hussain PhD 43
3122015 Ajaz S Hussain PhD 44
Life-cycle approach needed for knowledge management
Investigational ProductscGMPs
DevelopmentTechnology
TransferCommercial
ManufacturingDiscontinuation
Management Responsibility
Process Performance amp Product Quality Monitoring SystemCAPA Change Management Management Review
PQS Elements
Knowledge ManagementQuality Risk ManagementEnablers
ICH Q10 KM is a systematic approach to acquiring analyzing storing and disseminating information related to products manufacturing processes and components
Based on ICH Q10
ldquowe can be blind to the obvious and we are also blind to our blindnessrdquo
Daniel Kahneman Thinking Fast and Slow
3142015 Ajazajazhussaincom 45
httpwebmiteduperscipeopleadelsoncheckershadow_proofhtml
3122015 Ajaz S Hussain PhD 46
1938 The Federal Food Drug and Cosmetic (FDC)
bull 1937 Elixir of Sulfanilamide
1962 Kefauver-Harris Drug Amendments
bull 1962 Thalidomide
bull 1960 Color Additive Amendment
bull 1958 Food Additives Amendment GRAS
bull 1960 Color Additive Amendment
bull 1958 Food Additives Amendment GRAS
1992 Generic Drug Enforcement Act
bull1989 L-Tryptophan
bull 1989 Generic Drug Scandal
bull 1988 Food and Drug Administration Act
bull 1984 Fines Enhancement Laws Drug Price Competition and Patent Term Restoration Act
2012 Food and Drug Administration Safety and Innovation Act (FDASIA)
bull 2007 Heparin Disaster
2013 Pandemic and All-Hazards Preparedness Reauthorization Act (PAHPRA) Drug Quality and Security Act
bull 2012 The Deadly Meningitis Outbreak
Past 70 years 1937 ndash 2007 The diethylene glycol (DEG) narrative
3122015 Ajaz S Hussain PhD 47
0
5
10
15
20
25
30
35
Yea
rs
DEG Years since the previous incident
0
50
100
150
200
250
300
350
Number of Reported Deaths
1937
Eli
xir
of
Sulf
anil
amid
e
2007T
ootp
aste
conta
min
atio
n
0 70 years 0 70 years
Frequent reports
Mumbai Mumbai
Data from Excipient Fest Janeen Skutnik Chair ndashIPECAmericas 2009
Past 70+ years DEG contamination or economically motivated adulteration
3122015 Ajaz S Hussain PhD 48
Reported cases underestimate the real tragedy rapid intervention may not occur
Epidemic of Pediatric Deaths From Acute Renal Failure Caused by
Diethylene Glycol Poisoning JAMA 1998279(15)1175-1180
doi101001jama279151175
Month of hospital admission for children with
acute renal failure Haiti
October 1995-October 1996
Diethylene glycol poisoning in Gurgaon India 1998Bulletin of the World Health Organization 2001 79 88ndash95
We report a second episode of poisoning occurring in 1998 in
India as a result of children ingesting diethylene glycol at
least 33 children are known to have died
At the beginning of the investigation we never imagined that
contaminated medicine was causing acute renal failure in
children
A brand of cough expectorant manufactured by a local
pharmaceutical company was found by the Central Drugs
Laboratory Calcutta to contain 175 (vv) diethylene
glycol
The district and state drug controller had tested many
samples using thin layer chromatography before a sample of
medicine tested positive for diethylene glycol at the Central
Drugs Laboratory None of the earlier samples was found to
be contaminated
3122015 Ajaz S Hussain PhD 49
Guidance for Industry Testing of
Glycerin for Diethylene Glycol
CDER May 2007 Compliance
1 Manufacturers did not perform full
identity testing on the glycerin raw
material including tests to quantify
the amount of DEG
2 Relied on the certificate of analysis
(COA)
3 The origin of the glycerin was not
easily apparent from the COA
4 The COA was often a copy of a COA
on the letterhead of the distributor
5 The chain of custody or distribution
history of the glycerin was also not
readily known
USP Glycerin Monograph
Type of Posting Revision Bulletin
Posting Date 04ndashFebndash2009
Official Date 01ndashMayndash2009
Because of the serious hazards
associated withhellip and in response to
recommendations set forth in the
FDA Guidance for Industry Testing
of Glycerin for Diethylene Glycol
published in May 2007 USP has
revised the USP Glycerin monograph
Because diethylene glycol and
ethylene glycol are considered
unacceptable toxic substances the
testing of USP Glycerin should
demonstrate the absence of these
substances
April 2007 FDA request to
USP to revise the Glycerin
monographrsquos
IDENTIFICATION section
Revision includes adding ndash
Identification test B LIMIT OF
DIETHYLENE GLYCOL AND
ETHYLENE GLYCOL to detect
and quantify DEGEG in Glycerin
minus Is no longer part of the impurity
testing
ldquoLimit of DEG and Related
Compoundsrdquo minus Introduces a
capillary gas-chromatographic
(GC) method with flame ionization
detection (FID) minus Limit of NMT
010 each for diethylene glycol
and ethylene glycol is found
70+ years to get here how difficult will it be to change habits such as lsquoblind reliance of COArsquo
3122015 Ajaz S Hussain PhD 50
Personality and Habitual Frame Biases
Myers Brigs ENTJ (first tested at FDA)
S
TF
Expanded frame
future
possibilities
objective lsquocause
and effectrsquo
Expanded frame
future
possibilities
people and
relationships
Narrow frame
the present
individuals and
relationships
Narrow frame
the present
objective
cause and
effect
N
Based on Stanford Webinar - How to Overcome the Top 3 MegaBiases in Decision-Making
Stanford Universityrsquos Strategic Decision and Risk Management certificate program
From Mapping a Managers Brain on Incentives
Social
influences
Relative
thinking
UncertaintyComplexity
By Design Intention to act consciously
bull In the interest of patients and to continually improve this ability bull To provide a healing touch ndash one life at a time in what we do and how we
do it
1292014 Ajazajazhussaincom 51
Consciously
Scientific methodology
Engineering Design
Plan-Do-Check-Act
Subconsciously
Habits (work to get rid of bad ones)
Habits (work to cultivate good one)
Keystone habits (Safety Alcoa ALCOA of data integrity)
The Power of Habit Why We Do What We Do in Life and Business Charles Duhigg (2012)
httpwwwslideshareneta2zpharmscipharmaceutical-culture-of-quality
What does it take to come out of the cGMP crisis
Persuasive demonstration of
(1) Ability to face facts
(2) Legal amp regulatory requirements
3) Systems approach to quality
4) Changing behavior amp culture
What is often missed or is unconvincing is how you will strengthen culture of quality
ldquoLet one who wants to move and convince others first be convinced and moved themselvesrdquo Thomas Carlyle
Signals that question the competence motivation andor integrity of company personnel
Do not defend the plainly indefensible it adds further serious credibility costs
3142015 Ajazajazhussaincom 52
Quality is everyones responsibility
Lack of knowledge that is
the problem
If you do not know how to ask the
right question you discover nothing
If you cant describe what you
are doing as a process you dont know what youre
doing
Rational behavior requires theory
Reactive behavior requires only reflex
action
Whenever there is fear you will get wrong figures
3142015 Ajazajazhussaincom 53
Selected quotes W Edwards Deming
3142015 Ajazajazhussaincom 54
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
ldquoWE CANNOT CHANGE THE HUMAN CONDITION BUThellipWE CAN CHANGE THE CONDITIONS UNDER WHICH HUMANS WORKrdquo JAMES REASON
Disregard to Malice
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 55
ldquohelliprecords not completed
contemporaneouslyrdquo
ldquohellipobserved analyst back-date logbooksrdquo
ldquohelliptrial injectionshelliprdquo
ldquohellipresults failing specifications are
retested until acceptable results are obtainedhelliprdquo
ldquohellipover-writing electronic raw datahelliprdquo
ldquohellipOOS not investigates per XYZ SOPrdquo
ldquohellipappropriate controls not establishedhelliprdquo
Each additional observation adds
reasons to confirm that this is very likely a system
with intentional lsquoholesrsquo in its
defenses
Preconditions
Rationalization amp Attitude
Pressure amp Incentive
Opportunity ndashlsquoholes in the QMSrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 56
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 57
Attitude towards the behavior
Subjective norm
Perceived behavioral
control
IntentionFuture
Behavior
usually found to predict behavioral intentions with a high degree of accuracy
intentions in combination with perceived behavioral control can account for a considerable proportion of variance in behavior
PastBehavior
Ajen I The theory of planned behavior ORGANIZATIONAL BEHAVIOR AND HUMAN DECISION PROCESSES 50 179-211 (1991)
Heparin tragedy 2007 and 2008
FDA reports 149 deaths with allergic or hypersensitivity symptoms during that period
bull Contaminated heparin from China
QC Testing
bull Initial testing failed to detect the contaminant
Pharmacovigilence
bull Signals in the pharmacovigilence systems responded slowly and
Eventually the severity of reactions associated made it likely that the contamination would be detected
bull too late for those who died or were injured
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 58
Congressman Shimkus When the drug safety system fails people get sick Some die
bull Some of these people are already very vulnerable and proving the cause of harm from impurities adulteration and counterfeits can be elusive
It is hard to detect harm
bull Certainly the companies are obligated to ensure a culture of quality and maintain vigilance as well This reflects a systems approach to safety
FDA inspectors look for a culture of quality at
manufacturing facilities
bull FDA policies led to the failure to inspect the Chinese plantThis system approach wasnt at
play here
bull While it doesnt deny the counterfeit source tries to say that counterfeits didnt cause the reaction as if the adulteration itself was no big deal Is this an acceptable mindset helliphelliphellip
This brings me to China and its quality culture or lack thereof
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 59
ONE HUNDRED TENTH CONGRESS SECOND SESSION APRIL 29 2008 Serial No 110-109
21 CFR PART 211 SUBPARTS -Deviations signal gaps in CoQ
bullGENERAL PROVISIONSA
bullORGANIZATION AND PERSONNELB
bullBUILDINGS AND FACILITIESC
bullEQUIPMENTD
bullCONTROL OF COMPONENTS AND DRUG PRODUCT CONTAINERS AND CLOSURESE
bullPRODUCTION AND PROCESS CONTROLSF
bullPACKAGING AND LABELING CONTROLG
bullHOLDING AND DISTRIBUTIONH
bullLABORATORY CONTROLSI
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 60
For example the combinationhellip
The Power of Habit Why We Do What We Do in Life and Business Charles Duhigg (2012)
bull Scientific methodology
bull Engineering Design
bull Plan-Do-Check-ActConsciously
bull Habits (work to get rid of bad ones)
bull Habits (work to cultivate good one)
bull Keystone habits (Safety Alcoa ALCOA of data integrity)
Subconsciously
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 61
CoQ How
bull What are the predictors of CoQCoQ Manifests by Design -
lsquoquality by designrsquo the foundation
bull 1 2 3When do people change their behaviors
bull A B C D (any body can dance)What makes a QMS effective
bull X Y ZWhen proactive compliance occurs
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 62
Going beyond rules pays
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 63
Human behavior Connecting the Dots With the Right Connectors
GXPs ndash rational behaviors
How proactive compliance is achieved X Y Z
Quality Management System
What makes a QMS reliable A B C D
Culture of Quality
Why people change their behavior 1 2 3
Human Behaviors Beyond GXPs
Predictors of Culture of Quality
Why What and How of Culture of Quality
9192014 copy Ajaz S Hussain | INSIGHT ADVICE amp SOLUTIONS LLC 64
Predictors of CoQ Act consciously in the interest of patients ndash when no one is looking
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 65
Only four attributes
actually predict a culture of
quality
Leadership Emphasis
Message Credibility
Peer Involvement
Employee Empower-ment
People will change their
behavior if they see the new behavior as
Normal
(1)
Rewarding
(2)
Easy
(3)
Dr W Edwards Demingrsquos - ldquoOut of the crisisrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 66
The journey requires leadership
with Profound Knowledge as a
guide
bull As leaders responsible for system change top management is most in need of profound knowledge
bull Quality is often determined in the boardroom
bull Problems arise when management reacts to common cause or chance variation as if it were special cause variation
bull Prediction based in theory provides a foundation for planning a course of action Plan ndash Do ndash Check ndash Act
bull The leader serves the people with clear vision and guidance to empower them To be empowered is to share ownership in the identity
bull Giving people a certain degree of control over their work fulfills the need for freedom and provides opportunity for taking joy in work
Profound Knowledge as a guide
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 67
Appreciation for a System
Theory of Knowledge
Knowledge about
Variation
Human Behavior -Psychology of Change
A
B
C
D+
Systems Approach for ErrorDeviation Management
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 68
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
Human error models and management J Reason BMJ 320 768ndash770 (2000)
D+
Culture of Error Management परबधनbull Error strain
bull Covering upFear of Errors
bull Anticipation
bull Risk takingAwareness
bull Development QbDRFT
bull Error detection Communication
bull Analyzing errors Correction
Mastery orientation
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 69
Dots amp Connections
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 70
CoQ
1
2
3
QMS
A
B
C
D
GXP Behaviors
X
Y
Z
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 71
Culture of Quality
Normal
Rewarding
Easy
QMS
System
Knowledge
Variation
Behavior
Behavior -GXPs
Fear Removed
Mastery
Awareness
EnvironmentLeadership Emphasis
Message Credibility
Peer Involvement
Employee Empowerment
Connect to CoQ
Connect to GXPs
A Framework and a Tool (for gap analysis)
Practice Control Process Maturity
Initial
bull Unpredictable
Managed
bull Characterized but reactive
Defined
bull Characterized proactive
Measured amp Controlled
bull In control
Optimizing
bull Focus on improvement
3122015 Ajaz S Hussain PhD 34
Capability Maturity Model Integration Carnegie Mellon University
A validated process
Maturity Level amp Assurance of Quality
Managed Characterized but reactive
High perceived risk of
lsquoCheating by Designrsquo
ldquoTrial Injectionsrdquo
ldquoTesting in to Compliancerdquo
Defined Characterized proactive
Lower level of assurance
Stopping amp Correcting
Batch Rejection
Measured amp
ControlledIn control
Quality by Design
Quality Assured
Improvement Opportunities
3122015 Ajaz S Hussain PhD 35
At the individual level in QC functionndash how often does this occur
attitude toward
performing the behavior
Process validation is
done so quality is good
test prone to error
ldquoBatch failure means I made
a mistakerdquo
subjective norm
documentation not critical
Compendial testing
sufficient
Indian regulators
collect amp test samples ndash no issue there
3122015 Ajaz S Hussain PhD 36
ldquoTesting into compliancerdquo
In general ndash low empowerment is a significant challenge (low perceived behavioral control) plus reasons to rationalizehellip
Excipient Functionality Can be critical for safety efficacy and quality
3122015 Ajaz S Hussain PhD 37
July 15 2005 FDA Public Health Advisory Safety Warnings Regarding Use of Fentanyl Transdermal (Skin) Patches
A pattern of failure Pharmaceutical Equivalence by Design (2004)
3122015 Ajaz S Hussain PhD 38
httpwwwnihsgojpdrugPhForumdocuments041122Hussain041122pdf
An attempt to correct
3122015 Ajaz S Hussain PhD 39
httpipecamericasorgsystemfilesKeyNoteEF13May11LawrenceYu(FDA)pdf
Recent challenges
3122015 Ajaz S Hussain PhD 40
Th
e V
oic
e o
f th
eA
mer
ican
P
sych
iatr
ic A
sso
ciat
ion
and
th
e P
sych
iatr
ic C
om
mu
nit
y
Physicians Question FDAs Confidence in Generic Drugs Safety Efficacy (OCTOBER 24 2014)
bull ldquomost patientsrdquo is not the same asldquo all patientsrdquo and whether the 24 to 36 normal subjects used in the agencys bioequivalency tests represents the full range of individual variation in the way drugs are absorbed across the pharmaceutical using population is uncertain
bull Individuals can sometimes be allergic and react differently to whatever substance goes into making up the capsule or the tablet
FDA Flags Generic Versions of ADHD Medication(NOVEMBER 14 2014)
bull FDA changed the therapeutic equivalence (TE) rating from AB to BXmdashmeaning that the products are still approved and can be prescribed but are no longer recommended as automatic substitutes
RLD Variability Can be a block-buster opportunityFocus on lsquocontrol strategyrsquo
bull Overcoming CP amp IP provide FDA a submission they need to address CP
bull Then begin with QTPP CQArsquos hellip skip lsquodesign spacersquo and focus on lsquocontrol strategy
bull The entire development team should read the complete package insert of RLD
bull Discuss to ensure a common understandingbull Failure modes amp intended use
bull Pharmaceutical Equivalence
bull Bioequivalence
bull Other studies
QbD Challenges
3122015 Ajaz S Hussain PhD 41
NewRegulators are not prepared to handle QbD applications
NewMisalignment of international regulatory authorities
New and Generics
RampD incentivized for lsquoshots on the goalrsquo not QbD
GenericsLack of belief in business case ndash lsquoGenerics are all about file first figure out laterrsquo
Biologics Lack of technology to execute
Ted Fuhr Mackinsey amp Company June 2010 FDA Advisory Committee
Summary
bull Excipient functionality can contribute in critical ways to product quality amp performance adequate control is necessary
bull Our databases tools and knowledge are lagging behind the rapidly increasing complexity and uncertainty
bull Risk to quality and to business is increasing and regulatory transitions pose additional difficulties
bull Effective knowledge management ndash IT and Human practices ndash is critical for organizational lsquobottom-linersquo
bull We all must come together collaboratively to address the urgent needs we owe it to the patients we serve
3122015 Ajaz S Hussain PhD 42
Knowledge Management amp Culture of Quality
Ajaz S Hussain PhD
Insight Advice amp Solutions LLCMaryland USA
Executive Director the National Institute for Pharmaceutical Technology amp Education
3122015 Ajaz S Hussain PhD 43
3122015 Ajaz S Hussain PhD 44
Life-cycle approach needed for knowledge management
Investigational ProductscGMPs
DevelopmentTechnology
TransferCommercial
ManufacturingDiscontinuation
Management Responsibility
Process Performance amp Product Quality Monitoring SystemCAPA Change Management Management Review
PQS Elements
Knowledge ManagementQuality Risk ManagementEnablers
ICH Q10 KM is a systematic approach to acquiring analyzing storing and disseminating information related to products manufacturing processes and components
Based on ICH Q10
ldquowe can be blind to the obvious and we are also blind to our blindnessrdquo
Daniel Kahneman Thinking Fast and Slow
3142015 Ajazajazhussaincom 45
httpwebmiteduperscipeopleadelsoncheckershadow_proofhtml
3122015 Ajaz S Hussain PhD 46
1938 The Federal Food Drug and Cosmetic (FDC)
bull 1937 Elixir of Sulfanilamide
1962 Kefauver-Harris Drug Amendments
bull 1962 Thalidomide
bull 1960 Color Additive Amendment
bull 1958 Food Additives Amendment GRAS
bull 1960 Color Additive Amendment
bull 1958 Food Additives Amendment GRAS
1992 Generic Drug Enforcement Act
bull1989 L-Tryptophan
bull 1989 Generic Drug Scandal
bull 1988 Food and Drug Administration Act
bull 1984 Fines Enhancement Laws Drug Price Competition and Patent Term Restoration Act
2012 Food and Drug Administration Safety and Innovation Act (FDASIA)
bull 2007 Heparin Disaster
2013 Pandemic and All-Hazards Preparedness Reauthorization Act (PAHPRA) Drug Quality and Security Act
bull 2012 The Deadly Meningitis Outbreak
Past 70 years 1937 ndash 2007 The diethylene glycol (DEG) narrative
3122015 Ajaz S Hussain PhD 47
0
5
10
15
20
25
30
35
Yea
rs
DEG Years since the previous incident
0
50
100
150
200
250
300
350
Number of Reported Deaths
1937
Eli
xir
of
Sulf
anil
amid
e
2007T
ootp
aste
conta
min
atio
n
0 70 years 0 70 years
Frequent reports
Mumbai Mumbai
Data from Excipient Fest Janeen Skutnik Chair ndashIPECAmericas 2009
Past 70+ years DEG contamination or economically motivated adulteration
3122015 Ajaz S Hussain PhD 48
Reported cases underestimate the real tragedy rapid intervention may not occur
Epidemic of Pediatric Deaths From Acute Renal Failure Caused by
Diethylene Glycol Poisoning JAMA 1998279(15)1175-1180
doi101001jama279151175
Month of hospital admission for children with
acute renal failure Haiti
October 1995-October 1996
Diethylene glycol poisoning in Gurgaon India 1998Bulletin of the World Health Organization 2001 79 88ndash95
We report a second episode of poisoning occurring in 1998 in
India as a result of children ingesting diethylene glycol at
least 33 children are known to have died
At the beginning of the investigation we never imagined that
contaminated medicine was causing acute renal failure in
children
A brand of cough expectorant manufactured by a local
pharmaceutical company was found by the Central Drugs
Laboratory Calcutta to contain 175 (vv) diethylene
glycol
The district and state drug controller had tested many
samples using thin layer chromatography before a sample of
medicine tested positive for diethylene glycol at the Central
Drugs Laboratory None of the earlier samples was found to
be contaminated
3122015 Ajaz S Hussain PhD 49
Guidance for Industry Testing of
Glycerin for Diethylene Glycol
CDER May 2007 Compliance
1 Manufacturers did not perform full
identity testing on the glycerin raw
material including tests to quantify
the amount of DEG
2 Relied on the certificate of analysis
(COA)
3 The origin of the glycerin was not
easily apparent from the COA
4 The COA was often a copy of a COA
on the letterhead of the distributor
5 The chain of custody or distribution
history of the glycerin was also not
readily known
USP Glycerin Monograph
Type of Posting Revision Bulletin
Posting Date 04ndashFebndash2009
Official Date 01ndashMayndash2009
Because of the serious hazards
associated withhellip and in response to
recommendations set forth in the
FDA Guidance for Industry Testing
of Glycerin for Diethylene Glycol
published in May 2007 USP has
revised the USP Glycerin monograph
Because diethylene glycol and
ethylene glycol are considered
unacceptable toxic substances the
testing of USP Glycerin should
demonstrate the absence of these
substances
April 2007 FDA request to
USP to revise the Glycerin
monographrsquos
IDENTIFICATION section
Revision includes adding ndash
Identification test B LIMIT OF
DIETHYLENE GLYCOL AND
ETHYLENE GLYCOL to detect
and quantify DEGEG in Glycerin
minus Is no longer part of the impurity
testing
ldquoLimit of DEG and Related
Compoundsrdquo minus Introduces a
capillary gas-chromatographic
(GC) method with flame ionization
detection (FID) minus Limit of NMT
010 each for diethylene glycol
and ethylene glycol is found
70+ years to get here how difficult will it be to change habits such as lsquoblind reliance of COArsquo
3122015 Ajaz S Hussain PhD 50
Personality and Habitual Frame Biases
Myers Brigs ENTJ (first tested at FDA)
S
TF
Expanded frame
future
possibilities
objective lsquocause
and effectrsquo
Expanded frame
future
possibilities
people and
relationships
Narrow frame
the present
individuals and
relationships
Narrow frame
the present
objective
cause and
effect
N
Based on Stanford Webinar - How to Overcome the Top 3 MegaBiases in Decision-Making
Stanford Universityrsquos Strategic Decision and Risk Management certificate program
From Mapping a Managers Brain on Incentives
Social
influences
Relative
thinking
UncertaintyComplexity
By Design Intention to act consciously
bull In the interest of patients and to continually improve this ability bull To provide a healing touch ndash one life at a time in what we do and how we
do it
1292014 Ajazajazhussaincom 51
Consciously
Scientific methodology
Engineering Design
Plan-Do-Check-Act
Subconsciously
Habits (work to get rid of bad ones)
Habits (work to cultivate good one)
Keystone habits (Safety Alcoa ALCOA of data integrity)
The Power of Habit Why We Do What We Do in Life and Business Charles Duhigg (2012)
httpwwwslideshareneta2zpharmscipharmaceutical-culture-of-quality
What does it take to come out of the cGMP crisis
Persuasive demonstration of
(1) Ability to face facts
(2) Legal amp regulatory requirements
3) Systems approach to quality
4) Changing behavior amp culture
What is often missed or is unconvincing is how you will strengthen culture of quality
ldquoLet one who wants to move and convince others first be convinced and moved themselvesrdquo Thomas Carlyle
Signals that question the competence motivation andor integrity of company personnel
Do not defend the plainly indefensible it adds further serious credibility costs
3142015 Ajazajazhussaincom 52
Quality is everyones responsibility
Lack of knowledge that is
the problem
If you do not know how to ask the
right question you discover nothing
If you cant describe what you
are doing as a process you dont know what youre
doing
Rational behavior requires theory
Reactive behavior requires only reflex
action
Whenever there is fear you will get wrong figures
3142015 Ajazajazhussaincom 53
Selected quotes W Edwards Deming
3142015 Ajazajazhussaincom 54
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
ldquoWE CANNOT CHANGE THE HUMAN CONDITION BUThellipWE CAN CHANGE THE CONDITIONS UNDER WHICH HUMANS WORKrdquo JAMES REASON
Disregard to Malice
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 55
ldquohelliprecords not completed
contemporaneouslyrdquo
ldquohellipobserved analyst back-date logbooksrdquo
ldquohelliptrial injectionshelliprdquo
ldquohellipresults failing specifications are
retested until acceptable results are obtainedhelliprdquo
ldquohellipover-writing electronic raw datahelliprdquo
ldquohellipOOS not investigates per XYZ SOPrdquo
ldquohellipappropriate controls not establishedhelliprdquo
Each additional observation adds
reasons to confirm that this is very likely a system
with intentional lsquoholesrsquo in its
defenses
Preconditions
Rationalization amp Attitude
Pressure amp Incentive
Opportunity ndashlsquoholes in the QMSrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 56
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 57
Attitude towards the behavior
Subjective norm
Perceived behavioral
control
IntentionFuture
Behavior
usually found to predict behavioral intentions with a high degree of accuracy
intentions in combination with perceived behavioral control can account for a considerable proportion of variance in behavior
PastBehavior
Ajen I The theory of planned behavior ORGANIZATIONAL BEHAVIOR AND HUMAN DECISION PROCESSES 50 179-211 (1991)
Heparin tragedy 2007 and 2008
FDA reports 149 deaths with allergic or hypersensitivity symptoms during that period
bull Contaminated heparin from China
QC Testing
bull Initial testing failed to detect the contaminant
Pharmacovigilence
bull Signals in the pharmacovigilence systems responded slowly and
Eventually the severity of reactions associated made it likely that the contamination would be detected
bull too late for those who died or were injured
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 58
Congressman Shimkus When the drug safety system fails people get sick Some die
bull Some of these people are already very vulnerable and proving the cause of harm from impurities adulteration and counterfeits can be elusive
It is hard to detect harm
bull Certainly the companies are obligated to ensure a culture of quality and maintain vigilance as well This reflects a systems approach to safety
FDA inspectors look for a culture of quality at
manufacturing facilities
bull FDA policies led to the failure to inspect the Chinese plantThis system approach wasnt at
play here
bull While it doesnt deny the counterfeit source tries to say that counterfeits didnt cause the reaction as if the adulteration itself was no big deal Is this an acceptable mindset helliphelliphellip
This brings me to China and its quality culture or lack thereof
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 59
ONE HUNDRED TENTH CONGRESS SECOND SESSION APRIL 29 2008 Serial No 110-109
21 CFR PART 211 SUBPARTS -Deviations signal gaps in CoQ
bullGENERAL PROVISIONSA
bullORGANIZATION AND PERSONNELB
bullBUILDINGS AND FACILITIESC
bullEQUIPMENTD
bullCONTROL OF COMPONENTS AND DRUG PRODUCT CONTAINERS AND CLOSURESE
bullPRODUCTION AND PROCESS CONTROLSF
bullPACKAGING AND LABELING CONTROLG
bullHOLDING AND DISTRIBUTIONH
bullLABORATORY CONTROLSI
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 60
For example the combinationhellip
The Power of Habit Why We Do What We Do in Life and Business Charles Duhigg (2012)
bull Scientific methodology
bull Engineering Design
bull Plan-Do-Check-ActConsciously
bull Habits (work to get rid of bad ones)
bull Habits (work to cultivate good one)
bull Keystone habits (Safety Alcoa ALCOA of data integrity)
Subconsciously
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 61
CoQ How
bull What are the predictors of CoQCoQ Manifests by Design -
lsquoquality by designrsquo the foundation
bull 1 2 3When do people change their behaviors
bull A B C D (any body can dance)What makes a QMS effective
bull X Y ZWhen proactive compliance occurs
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 62
Going beyond rules pays
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 63
Human behavior Connecting the Dots With the Right Connectors
GXPs ndash rational behaviors
How proactive compliance is achieved X Y Z
Quality Management System
What makes a QMS reliable A B C D
Culture of Quality
Why people change their behavior 1 2 3
Human Behaviors Beyond GXPs
Predictors of Culture of Quality
Why What and How of Culture of Quality
9192014 copy Ajaz S Hussain | INSIGHT ADVICE amp SOLUTIONS LLC 64
Predictors of CoQ Act consciously in the interest of patients ndash when no one is looking
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 65
Only four attributes
actually predict a culture of
quality
Leadership Emphasis
Message Credibility
Peer Involvement
Employee Empower-ment
People will change their
behavior if they see the new behavior as
Normal
(1)
Rewarding
(2)
Easy
(3)
Dr W Edwards Demingrsquos - ldquoOut of the crisisrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 66
The journey requires leadership
with Profound Knowledge as a
guide
bull As leaders responsible for system change top management is most in need of profound knowledge
bull Quality is often determined in the boardroom
bull Problems arise when management reacts to common cause or chance variation as if it were special cause variation
bull Prediction based in theory provides a foundation for planning a course of action Plan ndash Do ndash Check ndash Act
bull The leader serves the people with clear vision and guidance to empower them To be empowered is to share ownership in the identity
bull Giving people a certain degree of control over their work fulfills the need for freedom and provides opportunity for taking joy in work
Profound Knowledge as a guide
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 67
Appreciation for a System
Theory of Knowledge
Knowledge about
Variation
Human Behavior -Psychology of Change
A
B
C
D+
Systems Approach for ErrorDeviation Management
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 68
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
Human error models and management J Reason BMJ 320 768ndash770 (2000)
D+
Culture of Error Management परबधनbull Error strain
bull Covering upFear of Errors
bull Anticipation
bull Risk takingAwareness
bull Development QbDRFT
bull Error detection Communication
bull Analyzing errors Correction
Mastery orientation
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 69
Dots amp Connections
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 70
CoQ
1
2
3
QMS
A
B
C
D
GXP Behaviors
X
Y
Z
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 71
Culture of Quality
Normal
Rewarding
Easy
QMS
System
Knowledge
Variation
Behavior
Behavior -GXPs
Fear Removed
Mastery
Awareness
EnvironmentLeadership Emphasis
Message Credibility
Peer Involvement
Employee Empowerment
Connect to CoQ
Connect to GXPs
A Framework and a Tool (for gap analysis)
Maturity Level amp Assurance of Quality
Managed Characterized but reactive
High perceived risk of
lsquoCheating by Designrsquo
ldquoTrial Injectionsrdquo
ldquoTesting in to Compliancerdquo
Defined Characterized proactive
Lower level of assurance
Stopping amp Correcting
Batch Rejection
Measured amp
ControlledIn control
Quality by Design
Quality Assured
Improvement Opportunities
3122015 Ajaz S Hussain PhD 35
At the individual level in QC functionndash how often does this occur
attitude toward
performing the behavior
Process validation is
done so quality is good
test prone to error
ldquoBatch failure means I made
a mistakerdquo
subjective norm
documentation not critical
Compendial testing
sufficient
Indian regulators
collect amp test samples ndash no issue there
3122015 Ajaz S Hussain PhD 36
ldquoTesting into compliancerdquo
In general ndash low empowerment is a significant challenge (low perceived behavioral control) plus reasons to rationalizehellip
Excipient Functionality Can be critical for safety efficacy and quality
3122015 Ajaz S Hussain PhD 37
July 15 2005 FDA Public Health Advisory Safety Warnings Regarding Use of Fentanyl Transdermal (Skin) Patches
A pattern of failure Pharmaceutical Equivalence by Design (2004)
3122015 Ajaz S Hussain PhD 38
httpwwwnihsgojpdrugPhForumdocuments041122Hussain041122pdf
An attempt to correct
3122015 Ajaz S Hussain PhD 39
httpipecamericasorgsystemfilesKeyNoteEF13May11LawrenceYu(FDA)pdf
Recent challenges
3122015 Ajaz S Hussain PhD 40
Th
e V
oic
e o
f th
eA
mer
ican
P
sych
iatr
ic A
sso
ciat
ion
and
th
e P
sych
iatr
ic C
om
mu
nit
y
Physicians Question FDAs Confidence in Generic Drugs Safety Efficacy (OCTOBER 24 2014)
bull ldquomost patientsrdquo is not the same asldquo all patientsrdquo and whether the 24 to 36 normal subjects used in the agencys bioequivalency tests represents the full range of individual variation in the way drugs are absorbed across the pharmaceutical using population is uncertain
bull Individuals can sometimes be allergic and react differently to whatever substance goes into making up the capsule or the tablet
FDA Flags Generic Versions of ADHD Medication(NOVEMBER 14 2014)
bull FDA changed the therapeutic equivalence (TE) rating from AB to BXmdashmeaning that the products are still approved and can be prescribed but are no longer recommended as automatic substitutes
RLD Variability Can be a block-buster opportunityFocus on lsquocontrol strategyrsquo
bull Overcoming CP amp IP provide FDA a submission they need to address CP
bull Then begin with QTPP CQArsquos hellip skip lsquodesign spacersquo and focus on lsquocontrol strategy
bull The entire development team should read the complete package insert of RLD
bull Discuss to ensure a common understandingbull Failure modes amp intended use
bull Pharmaceutical Equivalence
bull Bioequivalence
bull Other studies
QbD Challenges
3122015 Ajaz S Hussain PhD 41
NewRegulators are not prepared to handle QbD applications
NewMisalignment of international regulatory authorities
New and Generics
RampD incentivized for lsquoshots on the goalrsquo not QbD
GenericsLack of belief in business case ndash lsquoGenerics are all about file first figure out laterrsquo
Biologics Lack of technology to execute
Ted Fuhr Mackinsey amp Company June 2010 FDA Advisory Committee
Summary
bull Excipient functionality can contribute in critical ways to product quality amp performance adequate control is necessary
bull Our databases tools and knowledge are lagging behind the rapidly increasing complexity and uncertainty
bull Risk to quality and to business is increasing and regulatory transitions pose additional difficulties
bull Effective knowledge management ndash IT and Human practices ndash is critical for organizational lsquobottom-linersquo
bull We all must come together collaboratively to address the urgent needs we owe it to the patients we serve
3122015 Ajaz S Hussain PhD 42
Knowledge Management amp Culture of Quality
Ajaz S Hussain PhD
Insight Advice amp Solutions LLCMaryland USA
Executive Director the National Institute for Pharmaceutical Technology amp Education
3122015 Ajaz S Hussain PhD 43
3122015 Ajaz S Hussain PhD 44
Life-cycle approach needed for knowledge management
Investigational ProductscGMPs
DevelopmentTechnology
TransferCommercial
ManufacturingDiscontinuation
Management Responsibility
Process Performance amp Product Quality Monitoring SystemCAPA Change Management Management Review
PQS Elements
Knowledge ManagementQuality Risk ManagementEnablers
ICH Q10 KM is a systematic approach to acquiring analyzing storing and disseminating information related to products manufacturing processes and components
Based on ICH Q10
ldquowe can be blind to the obvious and we are also blind to our blindnessrdquo
Daniel Kahneman Thinking Fast and Slow
3142015 Ajazajazhussaincom 45
httpwebmiteduperscipeopleadelsoncheckershadow_proofhtml
3122015 Ajaz S Hussain PhD 46
1938 The Federal Food Drug and Cosmetic (FDC)
bull 1937 Elixir of Sulfanilamide
1962 Kefauver-Harris Drug Amendments
bull 1962 Thalidomide
bull 1960 Color Additive Amendment
bull 1958 Food Additives Amendment GRAS
bull 1960 Color Additive Amendment
bull 1958 Food Additives Amendment GRAS
1992 Generic Drug Enforcement Act
bull1989 L-Tryptophan
bull 1989 Generic Drug Scandal
bull 1988 Food and Drug Administration Act
bull 1984 Fines Enhancement Laws Drug Price Competition and Patent Term Restoration Act
2012 Food and Drug Administration Safety and Innovation Act (FDASIA)
bull 2007 Heparin Disaster
2013 Pandemic and All-Hazards Preparedness Reauthorization Act (PAHPRA) Drug Quality and Security Act
bull 2012 The Deadly Meningitis Outbreak
Past 70 years 1937 ndash 2007 The diethylene glycol (DEG) narrative
3122015 Ajaz S Hussain PhD 47
0
5
10
15
20
25
30
35
Yea
rs
DEG Years since the previous incident
0
50
100
150
200
250
300
350
Number of Reported Deaths
1937
Eli
xir
of
Sulf
anil
amid
e
2007T
ootp
aste
conta
min
atio
n
0 70 years 0 70 years
Frequent reports
Mumbai Mumbai
Data from Excipient Fest Janeen Skutnik Chair ndashIPECAmericas 2009
Past 70+ years DEG contamination or economically motivated adulteration
3122015 Ajaz S Hussain PhD 48
Reported cases underestimate the real tragedy rapid intervention may not occur
Epidemic of Pediatric Deaths From Acute Renal Failure Caused by
Diethylene Glycol Poisoning JAMA 1998279(15)1175-1180
doi101001jama279151175
Month of hospital admission for children with
acute renal failure Haiti
October 1995-October 1996
Diethylene glycol poisoning in Gurgaon India 1998Bulletin of the World Health Organization 2001 79 88ndash95
We report a second episode of poisoning occurring in 1998 in
India as a result of children ingesting diethylene glycol at
least 33 children are known to have died
At the beginning of the investigation we never imagined that
contaminated medicine was causing acute renal failure in
children
A brand of cough expectorant manufactured by a local
pharmaceutical company was found by the Central Drugs
Laboratory Calcutta to contain 175 (vv) diethylene
glycol
The district and state drug controller had tested many
samples using thin layer chromatography before a sample of
medicine tested positive for diethylene glycol at the Central
Drugs Laboratory None of the earlier samples was found to
be contaminated
3122015 Ajaz S Hussain PhD 49
Guidance for Industry Testing of
Glycerin for Diethylene Glycol
CDER May 2007 Compliance
1 Manufacturers did not perform full
identity testing on the glycerin raw
material including tests to quantify
the amount of DEG
2 Relied on the certificate of analysis
(COA)
3 The origin of the glycerin was not
easily apparent from the COA
4 The COA was often a copy of a COA
on the letterhead of the distributor
5 The chain of custody or distribution
history of the glycerin was also not
readily known
USP Glycerin Monograph
Type of Posting Revision Bulletin
Posting Date 04ndashFebndash2009
Official Date 01ndashMayndash2009
Because of the serious hazards
associated withhellip and in response to
recommendations set forth in the
FDA Guidance for Industry Testing
of Glycerin for Diethylene Glycol
published in May 2007 USP has
revised the USP Glycerin monograph
Because diethylene glycol and
ethylene glycol are considered
unacceptable toxic substances the
testing of USP Glycerin should
demonstrate the absence of these
substances
April 2007 FDA request to
USP to revise the Glycerin
monographrsquos
IDENTIFICATION section
Revision includes adding ndash
Identification test B LIMIT OF
DIETHYLENE GLYCOL AND
ETHYLENE GLYCOL to detect
and quantify DEGEG in Glycerin
minus Is no longer part of the impurity
testing
ldquoLimit of DEG and Related
Compoundsrdquo minus Introduces a
capillary gas-chromatographic
(GC) method with flame ionization
detection (FID) minus Limit of NMT
010 each for diethylene glycol
and ethylene glycol is found
70+ years to get here how difficult will it be to change habits such as lsquoblind reliance of COArsquo
3122015 Ajaz S Hussain PhD 50
Personality and Habitual Frame Biases
Myers Brigs ENTJ (first tested at FDA)
S
TF
Expanded frame
future
possibilities
objective lsquocause
and effectrsquo
Expanded frame
future
possibilities
people and
relationships
Narrow frame
the present
individuals and
relationships
Narrow frame
the present
objective
cause and
effect
N
Based on Stanford Webinar - How to Overcome the Top 3 MegaBiases in Decision-Making
Stanford Universityrsquos Strategic Decision and Risk Management certificate program
From Mapping a Managers Brain on Incentives
Social
influences
Relative
thinking
UncertaintyComplexity
By Design Intention to act consciously
bull In the interest of patients and to continually improve this ability bull To provide a healing touch ndash one life at a time in what we do and how we
do it
1292014 Ajazajazhussaincom 51
Consciously
Scientific methodology
Engineering Design
Plan-Do-Check-Act
Subconsciously
Habits (work to get rid of bad ones)
Habits (work to cultivate good one)
Keystone habits (Safety Alcoa ALCOA of data integrity)
The Power of Habit Why We Do What We Do in Life and Business Charles Duhigg (2012)
httpwwwslideshareneta2zpharmscipharmaceutical-culture-of-quality
What does it take to come out of the cGMP crisis
Persuasive demonstration of
(1) Ability to face facts
(2) Legal amp regulatory requirements
3) Systems approach to quality
4) Changing behavior amp culture
What is often missed or is unconvincing is how you will strengthen culture of quality
ldquoLet one who wants to move and convince others first be convinced and moved themselvesrdquo Thomas Carlyle
Signals that question the competence motivation andor integrity of company personnel
Do not defend the plainly indefensible it adds further serious credibility costs
3142015 Ajazajazhussaincom 52
Quality is everyones responsibility
Lack of knowledge that is
the problem
If you do not know how to ask the
right question you discover nothing
If you cant describe what you
are doing as a process you dont know what youre
doing
Rational behavior requires theory
Reactive behavior requires only reflex
action
Whenever there is fear you will get wrong figures
3142015 Ajazajazhussaincom 53
Selected quotes W Edwards Deming
3142015 Ajazajazhussaincom 54
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
ldquoWE CANNOT CHANGE THE HUMAN CONDITION BUThellipWE CAN CHANGE THE CONDITIONS UNDER WHICH HUMANS WORKrdquo JAMES REASON
Disregard to Malice
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 55
ldquohelliprecords not completed
contemporaneouslyrdquo
ldquohellipobserved analyst back-date logbooksrdquo
ldquohelliptrial injectionshelliprdquo
ldquohellipresults failing specifications are
retested until acceptable results are obtainedhelliprdquo
ldquohellipover-writing electronic raw datahelliprdquo
ldquohellipOOS not investigates per XYZ SOPrdquo
ldquohellipappropriate controls not establishedhelliprdquo
Each additional observation adds
reasons to confirm that this is very likely a system
with intentional lsquoholesrsquo in its
defenses
Preconditions
Rationalization amp Attitude
Pressure amp Incentive
Opportunity ndashlsquoholes in the QMSrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 56
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 57
Attitude towards the behavior
Subjective norm
Perceived behavioral
control
IntentionFuture
Behavior
usually found to predict behavioral intentions with a high degree of accuracy
intentions in combination with perceived behavioral control can account for a considerable proportion of variance in behavior
PastBehavior
Ajen I The theory of planned behavior ORGANIZATIONAL BEHAVIOR AND HUMAN DECISION PROCESSES 50 179-211 (1991)
Heparin tragedy 2007 and 2008
FDA reports 149 deaths with allergic or hypersensitivity symptoms during that period
bull Contaminated heparin from China
QC Testing
bull Initial testing failed to detect the contaminant
Pharmacovigilence
bull Signals in the pharmacovigilence systems responded slowly and
Eventually the severity of reactions associated made it likely that the contamination would be detected
bull too late for those who died or were injured
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 58
Congressman Shimkus When the drug safety system fails people get sick Some die
bull Some of these people are already very vulnerable and proving the cause of harm from impurities adulteration and counterfeits can be elusive
It is hard to detect harm
bull Certainly the companies are obligated to ensure a culture of quality and maintain vigilance as well This reflects a systems approach to safety
FDA inspectors look for a culture of quality at
manufacturing facilities
bull FDA policies led to the failure to inspect the Chinese plantThis system approach wasnt at
play here
bull While it doesnt deny the counterfeit source tries to say that counterfeits didnt cause the reaction as if the adulteration itself was no big deal Is this an acceptable mindset helliphelliphellip
This brings me to China and its quality culture or lack thereof
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 59
ONE HUNDRED TENTH CONGRESS SECOND SESSION APRIL 29 2008 Serial No 110-109
21 CFR PART 211 SUBPARTS -Deviations signal gaps in CoQ
bullGENERAL PROVISIONSA
bullORGANIZATION AND PERSONNELB
bullBUILDINGS AND FACILITIESC
bullEQUIPMENTD
bullCONTROL OF COMPONENTS AND DRUG PRODUCT CONTAINERS AND CLOSURESE
bullPRODUCTION AND PROCESS CONTROLSF
bullPACKAGING AND LABELING CONTROLG
bullHOLDING AND DISTRIBUTIONH
bullLABORATORY CONTROLSI
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 60
For example the combinationhellip
The Power of Habit Why We Do What We Do in Life and Business Charles Duhigg (2012)
bull Scientific methodology
bull Engineering Design
bull Plan-Do-Check-ActConsciously
bull Habits (work to get rid of bad ones)
bull Habits (work to cultivate good one)
bull Keystone habits (Safety Alcoa ALCOA of data integrity)
Subconsciously
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 61
CoQ How
bull What are the predictors of CoQCoQ Manifests by Design -
lsquoquality by designrsquo the foundation
bull 1 2 3When do people change their behaviors
bull A B C D (any body can dance)What makes a QMS effective
bull X Y ZWhen proactive compliance occurs
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 62
Going beyond rules pays
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 63
Human behavior Connecting the Dots With the Right Connectors
GXPs ndash rational behaviors
How proactive compliance is achieved X Y Z
Quality Management System
What makes a QMS reliable A B C D
Culture of Quality
Why people change their behavior 1 2 3
Human Behaviors Beyond GXPs
Predictors of Culture of Quality
Why What and How of Culture of Quality
9192014 copy Ajaz S Hussain | INSIGHT ADVICE amp SOLUTIONS LLC 64
Predictors of CoQ Act consciously in the interest of patients ndash when no one is looking
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 65
Only four attributes
actually predict a culture of
quality
Leadership Emphasis
Message Credibility
Peer Involvement
Employee Empower-ment
People will change their
behavior if they see the new behavior as
Normal
(1)
Rewarding
(2)
Easy
(3)
Dr W Edwards Demingrsquos - ldquoOut of the crisisrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 66
The journey requires leadership
with Profound Knowledge as a
guide
bull As leaders responsible for system change top management is most in need of profound knowledge
bull Quality is often determined in the boardroom
bull Problems arise when management reacts to common cause or chance variation as if it were special cause variation
bull Prediction based in theory provides a foundation for planning a course of action Plan ndash Do ndash Check ndash Act
bull The leader serves the people with clear vision and guidance to empower them To be empowered is to share ownership in the identity
bull Giving people a certain degree of control over their work fulfills the need for freedom and provides opportunity for taking joy in work
Profound Knowledge as a guide
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 67
Appreciation for a System
Theory of Knowledge
Knowledge about
Variation
Human Behavior -Psychology of Change
A
B
C
D+
Systems Approach for ErrorDeviation Management
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 68
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
Human error models and management J Reason BMJ 320 768ndash770 (2000)
D+
Culture of Error Management परबधनbull Error strain
bull Covering upFear of Errors
bull Anticipation
bull Risk takingAwareness
bull Development QbDRFT
bull Error detection Communication
bull Analyzing errors Correction
Mastery orientation
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 69
Dots amp Connections
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 70
CoQ
1
2
3
QMS
A
B
C
D
GXP Behaviors
X
Y
Z
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 71
Culture of Quality
Normal
Rewarding
Easy
QMS
System
Knowledge
Variation
Behavior
Behavior -GXPs
Fear Removed
Mastery
Awareness
EnvironmentLeadership Emphasis
Message Credibility
Peer Involvement
Employee Empowerment
Connect to CoQ
Connect to GXPs
A Framework and a Tool (for gap analysis)
At the individual level in QC functionndash how often does this occur
attitude toward
performing the behavior
Process validation is
done so quality is good
test prone to error
ldquoBatch failure means I made
a mistakerdquo
subjective norm
documentation not critical
Compendial testing
sufficient
Indian regulators
collect amp test samples ndash no issue there
3122015 Ajaz S Hussain PhD 36
ldquoTesting into compliancerdquo
In general ndash low empowerment is a significant challenge (low perceived behavioral control) plus reasons to rationalizehellip
Excipient Functionality Can be critical for safety efficacy and quality
3122015 Ajaz S Hussain PhD 37
July 15 2005 FDA Public Health Advisory Safety Warnings Regarding Use of Fentanyl Transdermal (Skin) Patches
A pattern of failure Pharmaceutical Equivalence by Design (2004)
3122015 Ajaz S Hussain PhD 38
httpwwwnihsgojpdrugPhForumdocuments041122Hussain041122pdf
An attempt to correct
3122015 Ajaz S Hussain PhD 39
httpipecamericasorgsystemfilesKeyNoteEF13May11LawrenceYu(FDA)pdf
Recent challenges
3122015 Ajaz S Hussain PhD 40
Th
e V
oic
e o
f th
eA
mer
ican
P
sych
iatr
ic A
sso
ciat
ion
and
th
e P
sych
iatr
ic C
om
mu
nit
y
Physicians Question FDAs Confidence in Generic Drugs Safety Efficacy (OCTOBER 24 2014)
bull ldquomost patientsrdquo is not the same asldquo all patientsrdquo and whether the 24 to 36 normal subjects used in the agencys bioequivalency tests represents the full range of individual variation in the way drugs are absorbed across the pharmaceutical using population is uncertain
bull Individuals can sometimes be allergic and react differently to whatever substance goes into making up the capsule or the tablet
FDA Flags Generic Versions of ADHD Medication(NOVEMBER 14 2014)
bull FDA changed the therapeutic equivalence (TE) rating from AB to BXmdashmeaning that the products are still approved and can be prescribed but are no longer recommended as automatic substitutes
RLD Variability Can be a block-buster opportunityFocus on lsquocontrol strategyrsquo
bull Overcoming CP amp IP provide FDA a submission they need to address CP
bull Then begin with QTPP CQArsquos hellip skip lsquodesign spacersquo and focus on lsquocontrol strategy
bull The entire development team should read the complete package insert of RLD
bull Discuss to ensure a common understandingbull Failure modes amp intended use
bull Pharmaceutical Equivalence
bull Bioequivalence
bull Other studies
QbD Challenges
3122015 Ajaz S Hussain PhD 41
NewRegulators are not prepared to handle QbD applications
NewMisalignment of international regulatory authorities
New and Generics
RampD incentivized for lsquoshots on the goalrsquo not QbD
GenericsLack of belief in business case ndash lsquoGenerics are all about file first figure out laterrsquo
Biologics Lack of technology to execute
Ted Fuhr Mackinsey amp Company June 2010 FDA Advisory Committee
Summary
bull Excipient functionality can contribute in critical ways to product quality amp performance adequate control is necessary
bull Our databases tools and knowledge are lagging behind the rapidly increasing complexity and uncertainty
bull Risk to quality and to business is increasing and regulatory transitions pose additional difficulties
bull Effective knowledge management ndash IT and Human practices ndash is critical for organizational lsquobottom-linersquo
bull We all must come together collaboratively to address the urgent needs we owe it to the patients we serve
3122015 Ajaz S Hussain PhD 42
Knowledge Management amp Culture of Quality
Ajaz S Hussain PhD
Insight Advice amp Solutions LLCMaryland USA
Executive Director the National Institute for Pharmaceutical Technology amp Education
3122015 Ajaz S Hussain PhD 43
3122015 Ajaz S Hussain PhD 44
Life-cycle approach needed for knowledge management
Investigational ProductscGMPs
DevelopmentTechnology
TransferCommercial
ManufacturingDiscontinuation
Management Responsibility
Process Performance amp Product Quality Monitoring SystemCAPA Change Management Management Review
PQS Elements
Knowledge ManagementQuality Risk ManagementEnablers
ICH Q10 KM is a systematic approach to acquiring analyzing storing and disseminating information related to products manufacturing processes and components
Based on ICH Q10
ldquowe can be blind to the obvious and we are also blind to our blindnessrdquo
Daniel Kahneman Thinking Fast and Slow
3142015 Ajazajazhussaincom 45
httpwebmiteduperscipeopleadelsoncheckershadow_proofhtml
3122015 Ajaz S Hussain PhD 46
1938 The Federal Food Drug and Cosmetic (FDC)
bull 1937 Elixir of Sulfanilamide
1962 Kefauver-Harris Drug Amendments
bull 1962 Thalidomide
bull 1960 Color Additive Amendment
bull 1958 Food Additives Amendment GRAS
bull 1960 Color Additive Amendment
bull 1958 Food Additives Amendment GRAS
1992 Generic Drug Enforcement Act
bull1989 L-Tryptophan
bull 1989 Generic Drug Scandal
bull 1988 Food and Drug Administration Act
bull 1984 Fines Enhancement Laws Drug Price Competition and Patent Term Restoration Act
2012 Food and Drug Administration Safety and Innovation Act (FDASIA)
bull 2007 Heparin Disaster
2013 Pandemic and All-Hazards Preparedness Reauthorization Act (PAHPRA) Drug Quality and Security Act
bull 2012 The Deadly Meningitis Outbreak
Past 70 years 1937 ndash 2007 The diethylene glycol (DEG) narrative
3122015 Ajaz S Hussain PhD 47
0
5
10
15
20
25
30
35
Yea
rs
DEG Years since the previous incident
0
50
100
150
200
250
300
350
Number of Reported Deaths
1937
Eli
xir
of
Sulf
anil
amid
e
2007T
ootp
aste
conta
min
atio
n
0 70 years 0 70 years
Frequent reports
Mumbai Mumbai
Data from Excipient Fest Janeen Skutnik Chair ndashIPECAmericas 2009
Past 70+ years DEG contamination or economically motivated adulteration
3122015 Ajaz S Hussain PhD 48
Reported cases underestimate the real tragedy rapid intervention may not occur
Epidemic of Pediatric Deaths From Acute Renal Failure Caused by
Diethylene Glycol Poisoning JAMA 1998279(15)1175-1180
doi101001jama279151175
Month of hospital admission for children with
acute renal failure Haiti
October 1995-October 1996
Diethylene glycol poisoning in Gurgaon India 1998Bulletin of the World Health Organization 2001 79 88ndash95
We report a second episode of poisoning occurring in 1998 in
India as a result of children ingesting diethylene glycol at
least 33 children are known to have died
At the beginning of the investigation we never imagined that
contaminated medicine was causing acute renal failure in
children
A brand of cough expectorant manufactured by a local
pharmaceutical company was found by the Central Drugs
Laboratory Calcutta to contain 175 (vv) diethylene
glycol
The district and state drug controller had tested many
samples using thin layer chromatography before a sample of
medicine tested positive for diethylene glycol at the Central
Drugs Laboratory None of the earlier samples was found to
be contaminated
3122015 Ajaz S Hussain PhD 49
Guidance for Industry Testing of
Glycerin for Diethylene Glycol
CDER May 2007 Compliance
1 Manufacturers did not perform full
identity testing on the glycerin raw
material including tests to quantify
the amount of DEG
2 Relied on the certificate of analysis
(COA)
3 The origin of the glycerin was not
easily apparent from the COA
4 The COA was often a copy of a COA
on the letterhead of the distributor
5 The chain of custody or distribution
history of the glycerin was also not
readily known
USP Glycerin Monograph
Type of Posting Revision Bulletin
Posting Date 04ndashFebndash2009
Official Date 01ndashMayndash2009
Because of the serious hazards
associated withhellip and in response to
recommendations set forth in the
FDA Guidance for Industry Testing
of Glycerin for Diethylene Glycol
published in May 2007 USP has
revised the USP Glycerin monograph
Because diethylene glycol and
ethylene glycol are considered
unacceptable toxic substances the
testing of USP Glycerin should
demonstrate the absence of these
substances
April 2007 FDA request to
USP to revise the Glycerin
monographrsquos
IDENTIFICATION section
Revision includes adding ndash
Identification test B LIMIT OF
DIETHYLENE GLYCOL AND
ETHYLENE GLYCOL to detect
and quantify DEGEG in Glycerin
minus Is no longer part of the impurity
testing
ldquoLimit of DEG and Related
Compoundsrdquo minus Introduces a
capillary gas-chromatographic
(GC) method with flame ionization
detection (FID) minus Limit of NMT
010 each for diethylene glycol
and ethylene glycol is found
70+ years to get here how difficult will it be to change habits such as lsquoblind reliance of COArsquo
3122015 Ajaz S Hussain PhD 50
Personality and Habitual Frame Biases
Myers Brigs ENTJ (first tested at FDA)
S
TF
Expanded frame
future
possibilities
objective lsquocause
and effectrsquo
Expanded frame
future
possibilities
people and
relationships
Narrow frame
the present
individuals and
relationships
Narrow frame
the present
objective
cause and
effect
N
Based on Stanford Webinar - How to Overcome the Top 3 MegaBiases in Decision-Making
Stanford Universityrsquos Strategic Decision and Risk Management certificate program
From Mapping a Managers Brain on Incentives
Social
influences
Relative
thinking
UncertaintyComplexity
By Design Intention to act consciously
bull In the interest of patients and to continually improve this ability bull To provide a healing touch ndash one life at a time in what we do and how we
do it
1292014 Ajazajazhussaincom 51
Consciously
Scientific methodology
Engineering Design
Plan-Do-Check-Act
Subconsciously
Habits (work to get rid of bad ones)
Habits (work to cultivate good one)
Keystone habits (Safety Alcoa ALCOA of data integrity)
The Power of Habit Why We Do What We Do in Life and Business Charles Duhigg (2012)
httpwwwslideshareneta2zpharmscipharmaceutical-culture-of-quality
What does it take to come out of the cGMP crisis
Persuasive demonstration of
(1) Ability to face facts
(2) Legal amp regulatory requirements
3) Systems approach to quality
4) Changing behavior amp culture
What is often missed or is unconvincing is how you will strengthen culture of quality
ldquoLet one who wants to move and convince others first be convinced and moved themselvesrdquo Thomas Carlyle
Signals that question the competence motivation andor integrity of company personnel
Do not defend the plainly indefensible it adds further serious credibility costs
3142015 Ajazajazhussaincom 52
Quality is everyones responsibility
Lack of knowledge that is
the problem
If you do not know how to ask the
right question you discover nothing
If you cant describe what you
are doing as a process you dont know what youre
doing
Rational behavior requires theory
Reactive behavior requires only reflex
action
Whenever there is fear you will get wrong figures
3142015 Ajazajazhussaincom 53
Selected quotes W Edwards Deming
3142015 Ajazajazhussaincom 54
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
ldquoWE CANNOT CHANGE THE HUMAN CONDITION BUThellipWE CAN CHANGE THE CONDITIONS UNDER WHICH HUMANS WORKrdquo JAMES REASON
Disregard to Malice
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 55
ldquohelliprecords not completed
contemporaneouslyrdquo
ldquohellipobserved analyst back-date logbooksrdquo
ldquohelliptrial injectionshelliprdquo
ldquohellipresults failing specifications are
retested until acceptable results are obtainedhelliprdquo
ldquohellipover-writing electronic raw datahelliprdquo
ldquohellipOOS not investigates per XYZ SOPrdquo
ldquohellipappropriate controls not establishedhelliprdquo
Each additional observation adds
reasons to confirm that this is very likely a system
with intentional lsquoholesrsquo in its
defenses
Preconditions
Rationalization amp Attitude
Pressure amp Incentive
Opportunity ndashlsquoholes in the QMSrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 56
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 57
Attitude towards the behavior
Subjective norm
Perceived behavioral
control
IntentionFuture
Behavior
usually found to predict behavioral intentions with a high degree of accuracy
intentions in combination with perceived behavioral control can account for a considerable proportion of variance in behavior
PastBehavior
Ajen I The theory of planned behavior ORGANIZATIONAL BEHAVIOR AND HUMAN DECISION PROCESSES 50 179-211 (1991)
Heparin tragedy 2007 and 2008
FDA reports 149 deaths with allergic or hypersensitivity symptoms during that period
bull Contaminated heparin from China
QC Testing
bull Initial testing failed to detect the contaminant
Pharmacovigilence
bull Signals in the pharmacovigilence systems responded slowly and
Eventually the severity of reactions associated made it likely that the contamination would be detected
bull too late for those who died or were injured
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 58
Congressman Shimkus When the drug safety system fails people get sick Some die
bull Some of these people are already very vulnerable and proving the cause of harm from impurities adulteration and counterfeits can be elusive
It is hard to detect harm
bull Certainly the companies are obligated to ensure a culture of quality and maintain vigilance as well This reflects a systems approach to safety
FDA inspectors look for a culture of quality at
manufacturing facilities
bull FDA policies led to the failure to inspect the Chinese plantThis system approach wasnt at
play here
bull While it doesnt deny the counterfeit source tries to say that counterfeits didnt cause the reaction as if the adulteration itself was no big deal Is this an acceptable mindset helliphelliphellip
This brings me to China and its quality culture or lack thereof
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 59
ONE HUNDRED TENTH CONGRESS SECOND SESSION APRIL 29 2008 Serial No 110-109
21 CFR PART 211 SUBPARTS -Deviations signal gaps in CoQ
bullGENERAL PROVISIONSA
bullORGANIZATION AND PERSONNELB
bullBUILDINGS AND FACILITIESC
bullEQUIPMENTD
bullCONTROL OF COMPONENTS AND DRUG PRODUCT CONTAINERS AND CLOSURESE
bullPRODUCTION AND PROCESS CONTROLSF
bullPACKAGING AND LABELING CONTROLG
bullHOLDING AND DISTRIBUTIONH
bullLABORATORY CONTROLSI
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 60
For example the combinationhellip
The Power of Habit Why We Do What We Do in Life and Business Charles Duhigg (2012)
bull Scientific methodology
bull Engineering Design
bull Plan-Do-Check-ActConsciously
bull Habits (work to get rid of bad ones)
bull Habits (work to cultivate good one)
bull Keystone habits (Safety Alcoa ALCOA of data integrity)
Subconsciously
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 61
CoQ How
bull What are the predictors of CoQCoQ Manifests by Design -
lsquoquality by designrsquo the foundation
bull 1 2 3When do people change their behaviors
bull A B C D (any body can dance)What makes a QMS effective
bull X Y ZWhen proactive compliance occurs
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 62
Going beyond rules pays
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 63
Human behavior Connecting the Dots With the Right Connectors
GXPs ndash rational behaviors
How proactive compliance is achieved X Y Z
Quality Management System
What makes a QMS reliable A B C D
Culture of Quality
Why people change their behavior 1 2 3
Human Behaviors Beyond GXPs
Predictors of Culture of Quality
Why What and How of Culture of Quality
9192014 copy Ajaz S Hussain | INSIGHT ADVICE amp SOLUTIONS LLC 64
Predictors of CoQ Act consciously in the interest of patients ndash when no one is looking
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 65
Only four attributes
actually predict a culture of
quality
Leadership Emphasis
Message Credibility
Peer Involvement
Employee Empower-ment
People will change their
behavior if they see the new behavior as
Normal
(1)
Rewarding
(2)
Easy
(3)
Dr W Edwards Demingrsquos - ldquoOut of the crisisrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 66
The journey requires leadership
with Profound Knowledge as a
guide
bull As leaders responsible for system change top management is most in need of profound knowledge
bull Quality is often determined in the boardroom
bull Problems arise when management reacts to common cause or chance variation as if it were special cause variation
bull Prediction based in theory provides a foundation for planning a course of action Plan ndash Do ndash Check ndash Act
bull The leader serves the people with clear vision and guidance to empower them To be empowered is to share ownership in the identity
bull Giving people a certain degree of control over their work fulfills the need for freedom and provides opportunity for taking joy in work
Profound Knowledge as a guide
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 67
Appreciation for a System
Theory of Knowledge
Knowledge about
Variation
Human Behavior -Psychology of Change
A
B
C
D+
Systems Approach for ErrorDeviation Management
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 68
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
Human error models and management J Reason BMJ 320 768ndash770 (2000)
D+
Culture of Error Management परबधनbull Error strain
bull Covering upFear of Errors
bull Anticipation
bull Risk takingAwareness
bull Development QbDRFT
bull Error detection Communication
bull Analyzing errors Correction
Mastery orientation
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 69
Dots amp Connections
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 70
CoQ
1
2
3
QMS
A
B
C
D
GXP Behaviors
X
Y
Z
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 71
Culture of Quality
Normal
Rewarding
Easy
QMS
System
Knowledge
Variation
Behavior
Behavior -GXPs
Fear Removed
Mastery
Awareness
EnvironmentLeadership Emphasis
Message Credibility
Peer Involvement
Employee Empowerment
Connect to CoQ
Connect to GXPs
A Framework and a Tool (for gap analysis)
Excipient Functionality Can be critical for safety efficacy and quality
3122015 Ajaz S Hussain PhD 37
July 15 2005 FDA Public Health Advisory Safety Warnings Regarding Use of Fentanyl Transdermal (Skin) Patches
A pattern of failure Pharmaceutical Equivalence by Design (2004)
3122015 Ajaz S Hussain PhD 38
httpwwwnihsgojpdrugPhForumdocuments041122Hussain041122pdf
An attempt to correct
3122015 Ajaz S Hussain PhD 39
httpipecamericasorgsystemfilesKeyNoteEF13May11LawrenceYu(FDA)pdf
Recent challenges
3122015 Ajaz S Hussain PhD 40
Th
e V
oic
e o
f th
eA
mer
ican
P
sych
iatr
ic A
sso
ciat
ion
and
th
e P
sych
iatr
ic C
om
mu
nit
y
Physicians Question FDAs Confidence in Generic Drugs Safety Efficacy (OCTOBER 24 2014)
bull ldquomost patientsrdquo is not the same asldquo all patientsrdquo and whether the 24 to 36 normal subjects used in the agencys bioequivalency tests represents the full range of individual variation in the way drugs are absorbed across the pharmaceutical using population is uncertain
bull Individuals can sometimes be allergic and react differently to whatever substance goes into making up the capsule or the tablet
FDA Flags Generic Versions of ADHD Medication(NOVEMBER 14 2014)
bull FDA changed the therapeutic equivalence (TE) rating from AB to BXmdashmeaning that the products are still approved and can be prescribed but are no longer recommended as automatic substitutes
RLD Variability Can be a block-buster opportunityFocus on lsquocontrol strategyrsquo
bull Overcoming CP amp IP provide FDA a submission they need to address CP
bull Then begin with QTPP CQArsquos hellip skip lsquodesign spacersquo and focus on lsquocontrol strategy
bull The entire development team should read the complete package insert of RLD
bull Discuss to ensure a common understandingbull Failure modes amp intended use
bull Pharmaceutical Equivalence
bull Bioequivalence
bull Other studies
QbD Challenges
3122015 Ajaz S Hussain PhD 41
NewRegulators are not prepared to handle QbD applications
NewMisalignment of international regulatory authorities
New and Generics
RampD incentivized for lsquoshots on the goalrsquo not QbD
GenericsLack of belief in business case ndash lsquoGenerics are all about file first figure out laterrsquo
Biologics Lack of technology to execute
Ted Fuhr Mackinsey amp Company June 2010 FDA Advisory Committee
Summary
bull Excipient functionality can contribute in critical ways to product quality amp performance adequate control is necessary
bull Our databases tools and knowledge are lagging behind the rapidly increasing complexity and uncertainty
bull Risk to quality and to business is increasing and regulatory transitions pose additional difficulties
bull Effective knowledge management ndash IT and Human practices ndash is critical for organizational lsquobottom-linersquo
bull We all must come together collaboratively to address the urgent needs we owe it to the patients we serve
3122015 Ajaz S Hussain PhD 42
Knowledge Management amp Culture of Quality
Ajaz S Hussain PhD
Insight Advice amp Solutions LLCMaryland USA
Executive Director the National Institute for Pharmaceutical Technology amp Education
3122015 Ajaz S Hussain PhD 43
3122015 Ajaz S Hussain PhD 44
Life-cycle approach needed for knowledge management
Investigational ProductscGMPs
DevelopmentTechnology
TransferCommercial
ManufacturingDiscontinuation
Management Responsibility
Process Performance amp Product Quality Monitoring SystemCAPA Change Management Management Review
PQS Elements
Knowledge ManagementQuality Risk ManagementEnablers
ICH Q10 KM is a systematic approach to acquiring analyzing storing and disseminating information related to products manufacturing processes and components
Based on ICH Q10
ldquowe can be blind to the obvious and we are also blind to our blindnessrdquo
Daniel Kahneman Thinking Fast and Slow
3142015 Ajazajazhussaincom 45
httpwebmiteduperscipeopleadelsoncheckershadow_proofhtml
3122015 Ajaz S Hussain PhD 46
1938 The Federal Food Drug and Cosmetic (FDC)
bull 1937 Elixir of Sulfanilamide
1962 Kefauver-Harris Drug Amendments
bull 1962 Thalidomide
bull 1960 Color Additive Amendment
bull 1958 Food Additives Amendment GRAS
bull 1960 Color Additive Amendment
bull 1958 Food Additives Amendment GRAS
1992 Generic Drug Enforcement Act
bull1989 L-Tryptophan
bull 1989 Generic Drug Scandal
bull 1988 Food and Drug Administration Act
bull 1984 Fines Enhancement Laws Drug Price Competition and Patent Term Restoration Act
2012 Food and Drug Administration Safety and Innovation Act (FDASIA)
bull 2007 Heparin Disaster
2013 Pandemic and All-Hazards Preparedness Reauthorization Act (PAHPRA) Drug Quality and Security Act
bull 2012 The Deadly Meningitis Outbreak
Past 70 years 1937 ndash 2007 The diethylene glycol (DEG) narrative
3122015 Ajaz S Hussain PhD 47
0
5
10
15
20
25
30
35
Yea
rs
DEG Years since the previous incident
0
50
100
150
200
250
300
350
Number of Reported Deaths
1937
Eli
xir
of
Sulf
anil
amid
e
2007T
ootp
aste
conta
min
atio
n
0 70 years 0 70 years
Frequent reports
Mumbai Mumbai
Data from Excipient Fest Janeen Skutnik Chair ndashIPECAmericas 2009
Past 70+ years DEG contamination or economically motivated adulteration
3122015 Ajaz S Hussain PhD 48
Reported cases underestimate the real tragedy rapid intervention may not occur
Epidemic of Pediatric Deaths From Acute Renal Failure Caused by
Diethylene Glycol Poisoning JAMA 1998279(15)1175-1180
doi101001jama279151175
Month of hospital admission for children with
acute renal failure Haiti
October 1995-October 1996
Diethylene glycol poisoning in Gurgaon India 1998Bulletin of the World Health Organization 2001 79 88ndash95
We report a second episode of poisoning occurring in 1998 in
India as a result of children ingesting diethylene glycol at
least 33 children are known to have died
At the beginning of the investigation we never imagined that
contaminated medicine was causing acute renal failure in
children
A brand of cough expectorant manufactured by a local
pharmaceutical company was found by the Central Drugs
Laboratory Calcutta to contain 175 (vv) diethylene
glycol
The district and state drug controller had tested many
samples using thin layer chromatography before a sample of
medicine tested positive for diethylene glycol at the Central
Drugs Laboratory None of the earlier samples was found to
be contaminated
3122015 Ajaz S Hussain PhD 49
Guidance for Industry Testing of
Glycerin for Diethylene Glycol
CDER May 2007 Compliance
1 Manufacturers did not perform full
identity testing on the glycerin raw
material including tests to quantify
the amount of DEG
2 Relied on the certificate of analysis
(COA)
3 The origin of the glycerin was not
easily apparent from the COA
4 The COA was often a copy of a COA
on the letterhead of the distributor
5 The chain of custody or distribution
history of the glycerin was also not
readily known
USP Glycerin Monograph
Type of Posting Revision Bulletin
Posting Date 04ndashFebndash2009
Official Date 01ndashMayndash2009
Because of the serious hazards
associated withhellip and in response to
recommendations set forth in the
FDA Guidance for Industry Testing
of Glycerin for Diethylene Glycol
published in May 2007 USP has
revised the USP Glycerin monograph
Because diethylene glycol and
ethylene glycol are considered
unacceptable toxic substances the
testing of USP Glycerin should
demonstrate the absence of these
substances
April 2007 FDA request to
USP to revise the Glycerin
monographrsquos
IDENTIFICATION section
Revision includes adding ndash
Identification test B LIMIT OF
DIETHYLENE GLYCOL AND
ETHYLENE GLYCOL to detect
and quantify DEGEG in Glycerin
minus Is no longer part of the impurity
testing
ldquoLimit of DEG and Related
Compoundsrdquo minus Introduces a
capillary gas-chromatographic
(GC) method with flame ionization
detection (FID) minus Limit of NMT
010 each for diethylene glycol
and ethylene glycol is found
70+ years to get here how difficult will it be to change habits such as lsquoblind reliance of COArsquo
3122015 Ajaz S Hussain PhD 50
Personality and Habitual Frame Biases
Myers Brigs ENTJ (first tested at FDA)
S
TF
Expanded frame
future
possibilities
objective lsquocause
and effectrsquo
Expanded frame
future
possibilities
people and
relationships
Narrow frame
the present
individuals and
relationships
Narrow frame
the present
objective
cause and
effect
N
Based on Stanford Webinar - How to Overcome the Top 3 MegaBiases in Decision-Making
Stanford Universityrsquos Strategic Decision and Risk Management certificate program
From Mapping a Managers Brain on Incentives
Social
influences
Relative
thinking
UncertaintyComplexity
By Design Intention to act consciously
bull In the interest of patients and to continually improve this ability bull To provide a healing touch ndash one life at a time in what we do and how we
do it
1292014 Ajazajazhussaincom 51
Consciously
Scientific methodology
Engineering Design
Plan-Do-Check-Act
Subconsciously
Habits (work to get rid of bad ones)
Habits (work to cultivate good one)
Keystone habits (Safety Alcoa ALCOA of data integrity)
The Power of Habit Why We Do What We Do in Life and Business Charles Duhigg (2012)
httpwwwslideshareneta2zpharmscipharmaceutical-culture-of-quality
What does it take to come out of the cGMP crisis
Persuasive demonstration of
(1) Ability to face facts
(2) Legal amp regulatory requirements
3) Systems approach to quality
4) Changing behavior amp culture
What is often missed or is unconvincing is how you will strengthen culture of quality
ldquoLet one who wants to move and convince others first be convinced and moved themselvesrdquo Thomas Carlyle
Signals that question the competence motivation andor integrity of company personnel
Do not defend the plainly indefensible it adds further serious credibility costs
3142015 Ajazajazhussaincom 52
Quality is everyones responsibility
Lack of knowledge that is
the problem
If you do not know how to ask the
right question you discover nothing
If you cant describe what you
are doing as a process you dont know what youre
doing
Rational behavior requires theory
Reactive behavior requires only reflex
action
Whenever there is fear you will get wrong figures
3142015 Ajazajazhussaincom 53
Selected quotes W Edwards Deming
3142015 Ajazajazhussaincom 54
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
ldquoWE CANNOT CHANGE THE HUMAN CONDITION BUThellipWE CAN CHANGE THE CONDITIONS UNDER WHICH HUMANS WORKrdquo JAMES REASON
Disregard to Malice
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 55
ldquohelliprecords not completed
contemporaneouslyrdquo
ldquohellipobserved analyst back-date logbooksrdquo
ldquohelliptrial injectionshelliprdquo
ldquohellipresults failing specifications are
retested until acceptable results are obtainedhelliprdquo
ldquohellipover-writing electronic raw datahelliprdquo
ldquohellipOOS not investigates per XYZ SOPrdquo
ldquohellipappropriate controls not establishedhelliprdquo
Each additional observation adds
reasons to confirm that this is very likely a system
with intentional lsquoholesrsquo in its
defenses
Preconditions
Rationalization amp Attitude
Pressure amp Incentive
Opportunity ndashlsquoholes in the QMSrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 56
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 57
Attitude towards the behavior
Subjective norm
Perceived behavioral
control
IntentionFuture
Behavior
usually found to predict behavioral intentions with a high degree of accuracy
intentions in combination with perceived behavioral control can account for a considerable proportion of variance in behavior
PastBehavior
Ajen I The theory of planned behavior ORGANIZATIONAL BEHAVIOR AND HUMAN DECISION PROCESSES 50 179-211 (1991)
Heparin tragedy 2007 and 2008
FDA reports 149 deaths with allergic or hypersensitivity symptoms during that period
bull Contaminated heparin from China
QC Testing
bull Initial testing failed to detect the contaminant
Pharmacovigilence
bull Signals in the pharmacovigilence systems responded slowly and
Eventually the severity of reactions associated made it likely that the contamination would be detected
bull too late for those who died or were injured
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 58
Congressman Shimkus When the drug safety system fails people get sick Some die
bull Some of these people are already very vulnerable and proving the cause of harm from impurities adulteration and counterfeits can be elusive
It is hard to detect harm
bull Certainly the companies are obligated to ensure a culture of quality and maintain vigilance as well This reflects a systems approach to safety
FDA inspectors look for a culture of quality at
manufacturing facilities
bull FDA policies led to the failure to inspect the Chinese plantThis system approach wasnt at
play here
bull While it doesnt deny the counterfeit source tries to say that counterfeits didnt cause the reaction as if the adulteration itself was no big deal Is this an acceptable mindset helliphelliphellip
This brings me to China and its quality culture or lack thereof
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 59
ONE HUNDRED TENTH CONGRESS SECOND SESSION APRIL 29 2008 Serial No 110-109
21 CFR PART 211 SUBPARTS -Deviations signal gaps in CoQ
bullGENERAL PROVISIONSA
bullORGANIZATION AND PERSONNELB
bullBUILDINGS AND FACILITIESC
bullEQUIPMENTD
bullCONTROL OF COMPONENTS AND DRUG PRODUCT CONTAINERS AND CLOSURESE
bullPRODUCTION AND PROCESS CONTROLSF
bullPACKAGING AND LABELING CONTROLG
bullHOLDING AND DISTRIBUTIONH
bullLABORATORY CONTROLSI
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 60
For example the combinationhellip
The Power of Habit Why We Do What We Do in Life and Business Charles Duhigg (2012)
bull Scientific methodology
bull Engineering Design
bull Plan-Do-Check-ActConsciously
bull Habits (work to get rid of bad ones)
bull Habits (work to cultivate good one)
bull Keystone habits (Safety Alcoa ALCOA of data integrity)
Subconsciously
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 61
CoQ How
bull What are the predictors of CoQCoQ Manifests by Design -
lsquoquality by designrsquo the foundation
bull 1 2 3When do people change their behaviors
bull A B C D (any body can dance)What makes a QMS effective
bull X Y ZWhen proactive compliance occurs
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 62
Going beyond rules pays
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 63
Human behavior Connecting the Dots With the Right Connectors
GXPs ndash rational behaviors
How proactive compliance is achieved X Y Z
Quality Management System
What makes a QMS reliable A B C D
Culture of Quality
Why people change their behavior 1 2 3
Human Behaviors Beyond GXPs
Predictors of Culture of Quality
Why What and How of Culture of Quality
9192014 copy Ajaz S Hussain | INSIGHT ADVICE amp SOLUTIONS LLC 64
Predictors of CoQ Act consciously in the interest of patients ndash when no one is looking
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 65
Only four attributes
actually predict a culture of
quality
Leadership Emphasis
Message Credibility
Peer Involvement
Employee Empower-ment
People will change their
behavior if they see the new behavior as
Normal
(1)
Rewarding
(2)
Easy
(3)
Dr W Edwards Demingrsquos - ldquoOut of the crisisrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 66
The journey requires leadership
with Profound Knowledge as a
guide
bull As leaders responsible for system change top management is most in need of profound knowledge
bull Quality is often determined in the boardroom
bull Problems arise when management reacts to common cause or chance variation as if it were special cause variation
bull Prediction based in theory provides a foundation for planning a course of action Plan ndash Do ndash Check ndash Act
bull The leader serves the people with clear vision and guidance to empower them To be empowered is to share ownership in the identity
bull Giving people a certain degree of control over their work fulfills the need for freedom and provides opportunity for taking joy in work
Profound Knowledge as a guide
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 67
Appreciation for a System
Theory of Knowledge
Knowledge about
Variation
Human Behavior -Psychology of Change
A
B
C
D+
Systems Approach for ErrorDeviation Management
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 68
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
Human error models and management J Reason BMJ 320 768ndash770 (2000)
D+
Culture of Error Management परबधनbull Error strain
bull Covering upFear of Errors
bull Anticipation
bull Risk takingAwareness
bull Development QbDRFT
bull Error detection Communication
bull Analyzing errors Correction
Mastery orientation
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 69
Dots amp Connections
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 70
CoQ
1
2
3
QMS
A
B
C
D
GXP Behaviors
X
Y
Z
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 71
Culture of Quality
Normal
Rewarding
Easy
QMS
System
Knowledge
Variation
Behavior
Behavior -GXPs
Fear Removed
Mastery
Awareness
EnvironmentLeadership Emphasis
Message Credibility
Peer Involvement
Employee Empowerment
Connect to CoQ
Connect to GXPs
A Framework and a Tool (for gap analysis)
A pattern of failure Pharmaceutical Equivalence by Design (2004)
3122015 Ajaz S Hussain PhD 38
httpwwwnihsgojpdrugPhForumdocuments041122Hussain041122pdf
An attempt to correct
3122015 Ajaz S Hussain PhD 39
httpipecamericasorgsystemfilesKeyNoteEF13May11LawrenceYu(FDA)pdf
Recent challenges
3122015 Ajaz S Hussain PhD 40
Th
e V
oic
e o
f th
eA
mer
ican
P
sych
iatr
ic A
sso
ciat
ion
and
th
e P
sych
iatr
ic C
om
mu
nit
y
Physicians Question FDAs Confidence in Generic Drugs Safety Efficacy (OCTOBER 24 2014)
bull ldquomost patientsrdquo is not the same asldquo all patientsrdquo and whether the 24 to 36 normal subjects used in the agencys bioequivalency tests represents the full range of individual variation in the way drugs are absorbed across the pharmaceutical using population is uncertain
bull Individuals can sometimes be allergic and react differently to whatever substance goes into making up the capsule or the tablet
FDA Flags Generic Versions of ADHD Medication(NOVEMBER 14 2014)
bull FDA changed the therapeutic equivalence (TE) rating from AB to BXmdashmeaning that the products are still approved and can be prescribed but are no longer recommended as automatic substitutes
RLD Variability Can be a block-buster opportunityFocus on lsquocontrol strategyrsquo
bull Overcoming CP amp IP provide FDA a submission they need to address CP
bull Then begin with QTPP CQArsquos hellip skip lsquodesign spacersquo and focus on lsquocontrol strategy
bull The entire development team should read the complete package insert of RLD
bull Discuss to ensure a common understandingbull Failure modes amp intended use
bull Pharmaceutical Equivalence
bull Bioequivalence
bull Other studies
QbD Challenges
3122015 Ajaz S Hussain PhD 41
NewRegulators are not prepared to handle QbD applications
NewMisalignment of international regulatory authorities
New and Generics
RampD incentivized for lsquoshots on the goalrsquo not QbD
GenericsLack of belief in business case ndash lsquoGenerics are all about file first figure out laterrsquo
Biologics Lack of technology to execute
Ted Fuhr Mackinsey amp Company June 2010 FDA Advisory Committee
Summary
bull Excipient functionality can contribute in critical ways to product quality amp performance adequate control is necessary
bull Our databases tools and knowledge are lagging behind the rapidly increasing complexity and uncertainty
bull Risk to quality and to business is increasing and regulatory transitions pose additional difficulties
bull Effective knowledge management ndash IT and Human practices ndash is critical for organizational lsquobottom-linersquo
bull We all must come together collaboratively to address the urgent needs we owe it to the patients we serve
3122015 Ajaz S Hussain PhD 42
Knowledge Management amp Culture of Quality
Ajaz S Hussain PhD
Insight Advice amp Solutions LLCMaryland USA
Executive Director the National Institute for Pharmaceutical Technology amp Education
3122015 Ajaz S Hussain PhD 43
3122015 Ajaz S Hussain PhD 44
Life-cycle approach needed for knowledge management
Investigational ProductscGMPs
DevelopmentTechnology
TransferCommercial
ManufacturingDiscontinuation
Management Responsibility
Process Performance amp Product Quality Monitoring SystemCAPA Change Management Management Review
PQS Elements
Knowledge ManagementQuality Risk ManagementEnablers
ICH Q10 KM is a systematic approach to acquiring analyzing storing and disseminating information related to products manufacturing processes and components
Based on ICH Q10
ldquowe can be blind to the obvious and we are also blind to our blindnessrdquo
Daniel Kahneman Thinking Fast and Slow
3142015 Ajazajazhussaincom 45
httpwebmiteduperscipeopleadelsoncheckershadow_proofhtml
3122015 Ajaz S Hussain PhD 46
1938 The Federal Food Drug and Cosmetic (FDC)
bull 1937 Elixir of Sulfanilamide
1962 Kefauver-Harris Drug Amendments
bull 1962 Thalidomide
bull 1960 Color Additive Amendment
bull 1958 Food Additives Amendment GRAS
bull 1960 Color Additive Amendment
bull 1958 Food Additives Amendment GRAS
1992 Generic Drug Enforcement Act
bull1989 L-Tryptophan
bull 1989 Generic Drug Scandal
bull 1988 Food and Drug Administration Act
bull 1984 Fines Enhancement Laws Drug Price Competition and Patent Term Restoration Act
2012 Food and Drug Administration Safety and Innovation Act (FDASIA)
bull 2007 Heparin Disaster
2013 Pandemic and All-Hazards Preparedness Reauthorization Act (PAHPRA) Drug Quality and Security Act
bull 2012 The Deadly Meningitis Outbreak
Past 70 years 1937 ndash 2007 The diethylene glycol (DEG) narrative
3122015 Ajaz S Hussain PhD 47
0
5
10
15
20
25
30
35
Yea
rs
DEG Years since the previous incident
0
50
100
150
200
250
300
350
Number of Reported Deaths
1937
Eli
xir
of
Sulf
anil
amid
e
2007T
ootp
aste
conta
min
atio
n
0 70 years 0 70 years
Frequent reports
Mumbai Mumbai
Data from Excipient Fest Janeen Skutnik Chair ndashIPECAmericas 2009
Past 70+ years DEG contamination or economically motivated adulteration
3122015 Ajaz S Hussain PhD 48
Reported cases underestimate the real tragedy rapid intervention may not occur
Epidemic of Pediatric Deaths From Acute Renal Failure Caused by
Diethylene Glycol Poisoning JAMA 1998279(15)1175-1180
doi101001jama279151175
Month of hospital admission for children with
acute renal failure Haiti
October 1995-October 1996
Diethylene glycol poisoning in Gurgaon India 1998Bulletin of the World Health Organization 2001 79 88ndash95
We report a second episode of poisoning occurring in 1998 in
India as a result of children ingesting diethylene glycol at
least 33 children are known to have died
At the beginning of the investigation we never imagined that
contaminated medicine was causing acute renal failure in
children
A brand of cough expectorant manufactured by a local
pharmaceutical company was found by the Central Drugs
Laboratory Calcutta to contain 175 (vv) diethylene
glycol
The district and state drug controller had tested many
samples using thin layer chromatography before a sample of
medicine tested positive for diethylene glycol at the Central
Drugs Laboratory None of the earlier samples was found to
be contaminated
3122015 Ajaz S Hussain PhD 49
Guidance for Industry Testing of
Glycerin for Diethylene Glycol
CDER May 2007 Compliance
1 Manufacturers did not perform full
identity testing on the glycerin raw
material including tests to quantify
the amount of DEG
2 Relied on the certificate of analysis
(COA)
3 The origin of the glycerin was not
easily apparent from the COA
4 The COA was often a copy of a COA
on the letterhead of the distributor
5 The chain of custody or distribution
history of the glycerin was also not
readily known
USP Glycerin Monograph
Type of Posting Revision Bulletin
Posting Date 04ndashFebndash2009
Official Date 01ndashMayndash2009
Because of the serious hazards
associated withhellip and in response to
recommendations set forth in the
FDA Guidance for Industry Testing
of Glycerin for Diethylene Glycol
published in May 2007 USP has
revised the USP Glycerin monograph
Because diethylene glycol and
ethylene glycol are considered
unacceptable toxic substances the
testing of USP Glycerin should
demonstrate the absence of these
substances
April 2007 FDA request to
USP to revise the Glycerin
monographrsquos
IDENTIFICATION section
Revision includes adding ndash
Identification test B LIMIT OF
DIETHYLENE GLYCOL AND
ETHYLENE GLYCOL to detect
and quantify DEGEG in Glycerin
minus Is no longer part of the impurity
testing
ldquoLimit of DEG and Related
Compoundsrdquo minus Introduces a
capillary gas-chromatographic
(GC) method with flame ionization
detection (FID) minus Limit of NMT
010 each for diethylene glycol
and ethylene glycol is found
70+ years to get here how difficult will it be to change habits such as lsquoblind reliance of COArsquo
3122015 Ajaz S Hussain PhD 50
Personality and Habitual Frame Biases
Myers Brigs ENTJ (first tested at FDA)
S
TF
Expanded frame
future
possibilities
objective lsquocause
and effectrsquo
Expanded frame
future
possibilities
people and
relationships
Narrow frame
the present
individuals and
relationships
Narrow frame
the present
objective
cause and
effect
N
Based on Stanford Webinar - How to Overcome the Top 3 MegaBiases in Decision-Making
Stanford Universityrsquos Strategic Decision and Risk Management certificate program
From Mapping a Managers Brain on Incentives
Social
influences
Relative
thinking
UncertaintyComplexity
By Design Intention to act consciously
bull In the interest of patients and to continually improve this ability bull To provide a healing touch ndash one life at a time in what we do and how we
do it
1292014 Ajazajazhussaincom 51
Consciously
Scientific methodology
Engineering Design
Plan-Do-Check-Act
Subconsciously
Habits (work to get rid of bad ones)
Habits (work to cultivate good one)
Keystone habits (Safety Alcoa ALCOA of data integrity)
The Power of Habit Why We Do What We Do in Life and Business Charles Duhigg (2012)
httpwwwslideshareneta2zpharmscipharmaceutical-culture-of-quality
What does it take to come out of the cGMP crisis
Persuasive demonstration of
(1) Ability to face facts
(2) Legal amp regulatory requirements
3) Systems approach to quality
4) Changing behavior amp culture
What is often missed or is unconvincing is how you will strengthen culture of quality
ldquoLet one who wants to move and convince others first be convinced and moved themselvesrdquo Thomas Carlyle
Signals that question the competence motivation andor integrity of company personnel
Do not defend the plainly indefensible it adds further serious credibility costs
3142015 Ajazajazhussaincom 52
Quality is everyones responsibility
Lack of knowledge that is
the problem
If you do not know how to ask the
right question you discover nothing
If you cant describe what you
are doing as a process you dont know what youre
doing
Rational behavior requires theory
Reactive behavior requires only reflex
action
Whenever there is fear you will get wrong figures
3142015 Ajazajazhussaincom 53
Selected quotes W Edwards Deming
3142015 Ajazajazhussaincom 54
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
ldquoWE CANNOT CHANGE THE HUMAN CONDITION BUThellipWE CAN CHANGE THE CONDITIONS UNDER WHICH HUMANS WORKrdquo JAMES REASON
Disregard to Malice
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 55
ldquohelliprecords not completed
contemporaneouslyrdquo
ldquohellipobserved analyst back-date logbooksrdquo
ldquohelliptrial injectionshelliprdquo
ldquohellipresults failing specifications are
retested until acceptable results are obtainedhelliprdquo
ldquohellipover-writing electronic raw datahelliprdquo
ldquohellipOOS not investigates per XYZ SOPrdquo
ldquohellipappropriate controls not establishedhelliprdquo
Each additional observation adds
reasons to confirm that this is very likely a system
with intentional lsquoholesrsquo in its
defenses
Preconditions
Rationalization amp Attitude
Pressure amp Incentive
Opportunity ndashlsquoholes in the QMSrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 56
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 57
Attitude towards the behavior
Subjective norm
Perceived behavioral
control
IntentionFuture
Behavior
usually found to predict behavioral intentions with a high degree of accuracy
intentions in combination with perceived behavioral control can account for a considerable proportion of variance in behavior
PastBehavior
Ajen I The theory of planned behavior ORGANIZATIONAL BEHAVIOR AND HUMAN DECISION PROCESSES 50 179-211 (1991)
Heparin tragedy 2007 and 2008
FDA reports 149 deaths with allergic or hypersensitivity symptoms during that period
bull Contaminated heparin from China
QC Testing
bull Initial testing failed to detect the contaminant
Pharmacovigilence
bull Signals in the pharmacovigilence systems responded slowly and
Eventually the severity of reactions associated made it likely that the contamination would be detected
bull too late for those who died or were injured
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 58
Congressman Shimkus When the drug safety system fails people get sick Some die
bull Some of these people are already very vulnerable and proving the cause of harm from impurities adulteration and counterfeits can be elusive
It is hard to detect harm
bull Certainly the companies are obligated to ensure a culture of quality and maintain vigilance as well This reflects a systems approach to safety
FDA inspectors look for a culture of quality at
manufacturing facilities
bull FDA policies led to the failure to inspect the Chinese plantThis system approach wasnt at
play here
bull While it doesnt deny the counterfeit source tries to say that counterfeits didnt cause the reaction as if the adulteration itself was no big deal Is this an acceptable mindset helliphelliphellip
This brings me to China and its quality culture or lack thereof
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 59
ONE HUNDRED TENTH CONGRESS SECOND SESSION APRIL 29 2008 Serial No 110-109
21 CFR PART 211 SUBPARTS -Deviations signal gaps in CoQ
bullGENERAL PROVISIONSA
bullORGANIZATION AND PERSONNELB
bullBUILDINGS AND FACILITIESC
bullEQUIPMENTD
bullCONTROL OF COMPONENTS AND DRUG PRODUCT CONTAINERS AND CLOSURESE
bullPRODUCTION AND PROCESS CONTROLSF
bullPACKAGING AND LABELING CONTROLG
bullHOLDING AND DISTRIBUTIONH
bullLABORATORY CONTROLSI
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 60
For example the combinationhellip
The Power of Habit Why We Do What We Do in Life and Business Charles Duhigg (2012)
bull Scientific methodology
bull Engineering Design
bull Plan-Do-Check-ActConsciously
bull Habits (work to get rid of bad ones)
bull Habits (work to cultivate good one)
bull Keystone habits (Safety Alcoa ALCOA of data integrity)
Subconsciously
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 61
CoQ How
bull What are the predictors of CoQCoQ Manifests by Design -
lsquoquality by designrsquo the foundation
bull 1 2 3When do people change their behaviors
bull A B C D (any body can dance)What makes a QMS effective
bull X Y ZWhen proactive compliance occurs
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 62
Going beyond rules pays
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 63
Human behavior Connecting the Dots With the Right Connectors
GXPs ndash rational behaviors
How proactive compliance is achieved X Y Z
Quality Management System
What makes a QMS reliable A B C D
Culture of Quality
Why people change their behavior 1 2 3
Human Behaviors Beyond GXPs
Predictors of Culture of Quality
Why What and How of Culture of Quality
9192014 copy Ajaz S Hussain | INSIGHT ADVICE amp SOLUTIONS LLC 64
Predictors of CoQ Act consciously in the interest of patients ndash when no one is looking
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 65
Only four attributes
actually predict a culture of
quality
Leadership Emphasis
Message Credibility
Peer Involvement
Employee Empower-ment
People will change their
behavior if they see the new behavior as
Normal
(1)
Rewarding
(2)
Easy
(3)
Dr W Edwards Demingrsquos - ldquoOut of the crisisrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 66
The journey requires leadership
with Profound Knowledge as a
guide
bull As leaders responsible for system change top management is most in need of profound knowledge
bull Quality is often determined in the boardroom
bull Problems arise when management reacts to common cause or chance variation as if it were special cause variation
bull Prediction based in theory provides a foundation for planning a course of action Plan ndash Do ndash Check ndash Act
bull The leader serves the people with clear vision and guidance to empower them To be empowered is to share ownership in the identity
bull Giving people a certain degree of control over their work fulfills the need for freedom and provides opportunity for taking joy in work
Profound Knowledge as a guide
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 67
Appreciation for a System
Theory of Knowledge
Knowledge about
Variation
Human Behavior -Psychology of Change
A
B
C
D+
Systems Approach for ErrorDeviation Management
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 68
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
Human error models and management J Reason BMJ 320 768ndash770 (2000)
D+
Culture of Error Management परबधनbull Error strain
bull Covering upFear of Errors
bull Anticipation
bull Risk takingAwareness
bull Development QbDRFT
bull Error detection Communication
bull Analyzing errors Correction
Mastery orientation
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 69
Dots amp Connections
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 70
CoQ
1
2
3
QMS
A
B
C
D
GXP Behaviors
X
Y
Z
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 71
Culture of Quality
Normal
Rewarding
Easy
QMS
System
Knowledge
Variation
Behavior
Behavior -GXPs
Fear Removed
Mastery
Awareness
EnvironmentLeadership Emphasis
Message Credibility
Peer Involvement
Employee Empowerment
Connect to CoQ
Connect to GXPs
A Framework and a Tool (for gap analysis)
An attempt to correct
3122015 Ajaz S Hussain PhD 39
httpipecamericasorgsystemfilesKeyNoteEF13May11LawrenceYu(FDA)pdf
Recent challenges
3122015 Ajaz S Hussain PhD 40
Th
e V
oic
e o
f th
eA
mer
ican
P
sych
iatr
ic A
sso
ciat
ion
and
th
e P
sych
iatr
ic C
om
mu
nit
y
Physicians Question FDAs Confidence in Generic Drugs Safety Efficacy (OCTOBER 24 2014)
bull ldquomost patientsrdquo is not the same asldquo all patientsrdquo and whether the 24 to 36 normal subjects used in the agencys bioequivalency tests represents the full range of individual variation in the way drugs are absorbed across the pharmaceutical using population is uncertain
bull Individuals can sometimes be allergic and react differently to whatever substance goes into making up the capsule or the tablet
FDA Flags Generic Versions of ADHD Medication(NOVEMBER 14 2014)
bull FDA changed the therapeutic equivalence (TE) rating from AB to BXmdashmeaning that the products are still approved and can be prescribed but are no longer recommended as automatic substitutes
RLD Variability Can be a block-buster opportunityFocus on lsquocontrol strategyrsquo
bull Overcoming CP amp IP provide FDA a submission they need to address CP
bull Then begin with QTPP CQArsquos hellip skip lsquodesign spacersquo and focus on lsquocontrol strategy
bull The entire development team should read the complete package insert of RLD
bull Discuss to ensure a common understandingbull Failure modes amp intended use
bull Pharmaceutical Equivalence
bull Bioequivalence
bull Other studies
QbD Challenges
3122015 Ajaz S Hussain PhD 41
NewRegulators are not prepared to handle QbD applications
NewMisalignment of international regulatory authorities
New and Generics
RampD incentivized for lsquoshots on the goalrsquo not QbD
GenericsLack of belief in business case ndash lsquoGenerics are all about file first figure out laterrsquo
Biologics Lack of technology to execute
Ted Fuhr Mackinsey amp Company June 2010 FDA Advisory Committee
Summary
bull Excipient functionality can contribute in critical ways to product quality amp performance adequate control is necessary
bull Our databases tools and knowledge are lagging behind the rapidly increasing complexity and uncertainty
bull Risk to quality and to business is increasing and regulatory transitions pose additional difficulties
bull Effective knowledge management ndash IT and Human practices ndash is critical for organizational lsquobottom-linersquo
bull We all must come together collaboratively to address the urgent needs we owe it to the patients we serve
3122015 Ajaz S Hussain PhD 42
Knowledge Management amp Culture of Quality
Ajaz S Hussain PhD
Insight Advice amp Solutions LLCMaryland USA
Executive Director the National Institute for Pharmaceutical Technology amp Education
3122015 Ajaz S Hussain PhD 43
3122015 Ajaz S Hussain PhD 44
Life-cycle approach needed for knowledge management
Investigational ProductscGMPs
DevelopmentTechnology
TransferCommercial
ManufacturingDiscontinuation
Management Responsibility
Process Performance amp Product Quality Monitoring SystemCAPA Change Management Management Review
PQS Elements
Knowledge ManagementQuality Risk ManagementEnablers
ICH Q10 KM is a systematic approach to acquiring analyzing storing and disseminating information related to products manufacturing processes and components
Based on ICH Q10
ldquowe can be blind to the obvious and we are also blind to our blindnessrdquo
Daniel Kahneman Thinking Fast and Slow
3142015 Ajazajazhussaincom 45
httpwebmiteduperscipeopleadelsoncheckershadow_proofhtml
3122015 Ajaz S Hussain PhD 46
1938 The Federal Food Drug and Cosmetic (FDC)
bull 1937 Elixir of Sulfanilamide
1962 Kefauver-Harris Drug Amendments
bull 1962 Thalidomide
bull 1960 Color Additive Amendment
bull 1958 Food Additives Amendment GRAS
bull 1960 Color Additive Amendment
bull 1958 Food Additives Amendment GRAS
1992 Generic Drug Enforcement Act
bull1989 L-Tryptophan
bull 1989 Generic Drug Scandal
bull 1988 Food and Drug Administration Act
bull 1984 Fines Enhancement Laws Drug Price Competition and Patent Term Restoration Act
2012 Food and Drug Administration Safety and Innovation Act (FDASIA)
bull 2007 Heparin Disaster
2013 Pandemic and All-Hazards Preparedness Reauthorization Act (PAHPRA) Drug Quality and Security Act
bull 2012 The Deadly Meningitis Outbreak
Past 70 years 1937 ndash 2007 The diethylene glycol (DEG) narrative
3122015 Ajaz S Hussain PhD 47
0
5
10
15
20
25
30
35
Yea
rs
DEG Years since the previous incident
0
50
100
150
200
250
300
350
Number of Reported Deaths
1937
Eli
xir
of
Sulf
anil
amid
e
2007T
ootp
aste
conta
min
atio
n
0 70 years 0 70 years
Frequent reports
Mumbai Mumbai
Data from Excipient Fest Janeen Skutnik Chair ndashIPECAmericas 2009
Past 70+ years DEG contamination or economically motivated adulteration
3122015 Ajaz S Hussain PhD 48
Reported cases underestimate the real tragedy rapid intervention may not occur
Epidemic of Pediatric Deaths From Acute Renal Failure Caused by
Diethylene Glycol Poisoning JAMA 1998279(15)1175-1180
doi101001jama279151175
Month of hospital admission for children with
acute renal failure Haiti
October 1995-October 1996
Diethylene glycol poisoning in Gurgaon India 1998Bulletin of the World Health Organization 2001 79 88ndash95
We report a second episode of poisoning occurring in 1998 in
India as a result of children ingesting diethylene glycol at
least 33 children are known to have died
At the beginning of the investigation we never imagined that
contaminated medicine was causing acute renal failure in
children
A brand of cough expectorant manufactured by a local
pharmaceutical company was found by the Central Drugs
Laboratory Calcutta to contain 175 (vv) diethylene
glycol
The district and state drug controller had tested many
samples using thin layer chromatography before a sample of
medicine tested positive for diethylene glycol at the Central
Drugs Laboratory None of the earlier samples was found to
be contaminated
3122015 Ajaz S Hussain PhD 49
Guidance for Industry Testing of
Glycerin for Diethylene Glycol
CDER May 2007 Compliance
1 Manufacturers did not perform full
identity testing on the glycerin raw
material including tests to quantify
the amount of DEG
2 Relied on the certificate of analysis
(COA)
3 The origin of the glycerin was not
easily apparent from the COA
4 The COA was often a copy of a COA
on the letterhead of the distributor
5 The chain of custody or distribution
history of the glycerin was also not
readily known
USP Glycerin Monograph
Type of Posting Revision Bulletin
Posting Date 04ndashFebndash2009
Official Date 01ndashMayndash2009
Because of the serious hazards
associated withhellip and in response to
recommendations set forth in the
FDA Guidance for Industry Testing
of Glycerin for Diethylene Glycol
published in May 2007 USP has
revised the USP Glycerin monograph
Because diethylene glycol and
ethylene glycol are considered
unacceptable toxic substances the
testing of USP Glycerin should
demonstrate the absence of these
substances
April 2007 FDA request to
USP to revise the Glycerin
monographrsquos
IDENTIFICATION section
Revision includes adding ndash
Identification test B LIMIT OF
DIETHYLENE GLYCOL AND
ETHYLENE GLYCOL to detect
and quantify DEGEG in Glycerin
minus Is no longer part of the impurity
testing
ldquoLimit of DEG and Related
Compoundsrdquo minus Introduces a
capillary gas-chromatographic
(GC) method with flame ionization
detection (FID) minus Limit of NMT
010 each for diethylene glycol
and ethylene glycol is found
70+ years to get here how difficult will it be to change habits such as lsquoblind reliance of COArsquo
3122015 Ajaz S Hussain PhD 50
Personality and Habitual Frame Biases
Myers Brigs ENTJ (first tested at FDA)
S
TF
Expanded frame
future
possibilities
objective lsquocause
and effectrsquo
Expanded frame
future
possibilities
people and
relationships
Narrow frame
the present
individuals and
relationships
Narrow frame
the present
objective
cause and
effect
N
Based on Stanford Webinar - How to Overcome the Top 3 MegaBiases in Decision-Making
Stanford Universityrsquos Strategic Decision and Risk Management certificate program
From Mapping a Managers Brain on Incentives
Social
influences
Relative
thinking
UncertaintyComplexity
By Design Intention to act consciously
bull In the interest of patients and to continually improve this ability bull To provide a healing touch ndash one life at a time in what we do and how we
do it
1292014 Ajazajazhussaincom 51
Consciously
Scientific methodology
Engineering Design
Plan-Do-Check-Act
Subconsciously
Habits (work to get rid of bad ones)
Habits (work to cultivate good one)
Keystone habits (Safety Alcoa ALCOA of data integrity)
The Power of Habit Why We Do What We Do in Life and Business Charles Duhigg (2012)
httpwwwslideshareneta2zpharmscipharmaceutical-culture-of-quality
What does it take to come out of the cGMP crisis
Persuasive demonstration of
(1) Ability to face facts
(2) Legal amp regulatory requirements
3) Systems approach to quality
4) Changing behavior amp culture
What is often missed or is unconvincing is how you will strengthen culture of quality
ldquoLet one who wants to move and convince others first be convinced and moved themselvesrdquo Thomas Carlyle
Signals that question the competence motivation andor integrity of company personnel
Do not defend the plainly indefensible it adds further serious credibility costs
3142015 Ajazajazhussaincom 52
Quality is everyones responsibility
Lack of knowledge that is
the problem
If you do not know how to ask the
right question you discover nothing
If you cant describe what you
are doing as a process you dont know what youre
doing
Rational behavior requires theory
Reactive behavior requires only reflex
action
Whenever there is fear you will get wrong figures
3142015 Ajazajazhussaincom 53
Selected quotes W Edwards Deming
3142015 Ajazajazhussaincom 54
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
ldquoWE CANNOT CHANGE THE HUMAN CONDITION BUThellipWE CAN CHANGE THE CONDITIONS UNDER WHICH HUMANS WORKrdquo JAMES REASON
Disregard to Malice
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 55
ldquohelliprecords not completed
contemporaneouslyrdquo
ldquohellipobserved analyst back-date logbooksrdquo
ldquohelliptrial injectionshelliprdquo
ldquohellipresults failing specifications are
retested until acceptable results are obtainedhelliprdquo
ldquohellipover-writing electronic raw datahelliprdquo
ldquohellipOOS not investigates per XYZ SOPrdquo
ldquohellipappropriate controls not establishedhelliprdquo
Each additional observation adds
reasons to confirm that this is very likely a system
with intentional lsquoholesrsquo in its
defenses
Preconditions
Rationalization amp Attitude
Pressure amp Incentive
Opportunity ndashlsquoholes in the QMSrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 56
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 57
Attitude towards the behavior
Subjective norm
Perceived behavioral
control
IntentionFuture
Behavior
usually found to predict behavioral intentions with a high degree of accuracy
intentions in combination with perceived behavioral control can account for a considerable proportion of variance in behavior
PastBehavior
Ajen I The theory of planned behavior ORGANIZATIONAL BEHAVIOR AND HUMAN DECISION PROCESSES 50 179-211 (1991)
Heparin tragedy 2007 and 2008
FDA reports 149 deaths with allergic or hypersensitivity symptoms during that period
bull Contaminated heparin from China
QC Testing
bull Initial testing failed to detect the contaminant
Pharmacovigilence
bull Signals in the pharmacovigilence systems responded slowly and
Eventually the severity of reactions associated made it likely that the contamination would be detected
bull too late for those who died or were injured
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 58
Congressman Shimkus When the drug safety system fails people get sick Some die
bull Some of these people are already very vulnerable and proving the cause of harm from impurities adulteration and counterfeits can be elusive
It is hard to detect harm
bull Certainly the companies are obligated to ensure a culture of quality and maintain vigilance as well This reflects a systems approach to safety
FDA inspectors look for a culture of quality at
manufacturing facilities
bull FDA policies led to the failure to inspect the Chinese plantThis system approach wasnt at
play here
bull While it doesnt deny the counterfeit source tries to say that counterfeits didnt cause the reaction as if the adulteration itself was no big deal Is this an acceptable mindset helliphelliphellip
This brings me to China and its quality culture or lack thereof
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 59
ONE HUNDRED TENTH CONGRESS SECOND SESSION APRIL 29 2008 Serial No 110-109
21 CFR PART 211 SUBPARTS -Deviations signal gaps in CoQ
bullGENERAL PROVISIONSA
bullORGANIZATION AND PERSONNELB
bullBUILDINGS AND FACILITIESC
bullEQUIPMENTD
bullCONTROL OF COMPONENTS AND DRUG PRODUCT CONTAINERS AND CLOSURESE
bullPRODUCTION AND PROCESS CONTROLSF
bullPACKAGING AND LABELING CONTROLG
bullHOLDING AND DISTRIBUTIONH
bullLABORATORY CONTROLSI
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 60
For example the combinationhellip
The Power of Habit Why We Do What We Do in Life and Business Charles Duhigg (2012)
bull Scientific methodology
bull Engineering Design
bull Plan-Do-Check-ActConsciously
bull Habits (work to get rid of bad ones)
bull Habits (work to cultivate good one)
bull Keystone habits (Safety Alcoa ALCOA of data integrity)
Subconsciously
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 61
CoQ How
bull What are the predictors of CoQCoQ Manifests by Design -
lsquoquality by designrsquo the foundation
bull 1 2 3When do people change their behaviors
bull A B C D (any body can dance)What makes a QMS effective
bull X Y ZWhen proactive compliance occurs
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 62
Going beyond rules pays
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 63
Human behavior Connecting the Dots With the Right Connectors
GXPs ndash rational behaviors
How proactive compliance is achieved X Y Z
Quality Management System
What makes a QMS reliable A B C D
Culture of Quality
Why people change their behavior 1 2 3
Human Behaviors Beyond GXPs
Predictors of Culture of Quality
Why What and How of Culture of Quality
9192014 copy Ajaz S Hussain | INSIGHT ADVICE amp SOLUTIONS LLC 64
Predictors of CoQ Act consciously in the interest of patients ndash when no one is looking
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 65
Only four attributes
actually predict a culture of
quality
Leadership Emphasis
Message Credibility
Peer Involvement
Employee Empower-ment
People will change their
behavior if they see the new behavior as
Normal
(1)
Rewarding
(2)
Easy
(3)
Dr W Edwards Demingrsquos - ldquoOut of the crisisrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 66
The journey requires leadership
with Profound Knowledge as a
guide
bull As leaders responsible for system change top management is most in need of profound knowledge
bull Quality is often determined in the boardroom
bull Problems arise when management reacts to common cause or chance variation as if it were special cause variation
bull Prediction based in theory provides a foundation for planning a course of action Plan ndash Do ndash Check ndash Act
bull The leader serves the people with clear vision and guidance to empower them To be empowered is to share ownership in the identity
bull Giving people a certain degree of control over their work fulfills the need for freedom and provides opportunity for taking joy in work
Profound Knowledge as a guide
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 67
Appreciation for a System
Theory of Knowledge
Knowledge about
Variation
Human Behavior -Psychology of Change
A
B
C
D+
Systems Approach for ErrorDeviation Management
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 68
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
Human error models and management J Reason BMJ 320 768ndash770 (2000)
D+
Culture of Error Management परबधनbull Error strain
bull Covering upFear of Errors
bull Anticipation
bull Risk takingAwareness
bull Development QbDRFT
bull Error detection Communication
bull Analyzing errors Correction
Mastery orientation
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 69
Dots amp Connections
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 70
CoQ
1
2
3
QMS
A
B
C
D
GXP Behaviors
X
Y
Z
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 71
Culture of Quality
Normal
Rewarding
Easy
QMS
System
Knowledge
Variation
Behavior
Behavior -GXPs
Fear Removed
Mastery
Awareness
EnvironmentLeadership Emphasis
Message Credibility
Peer Involvement
Employee Empowerment
Connect to CoQ
Connect to GXPs
A Framework and a Tool (for gap analysis)
Recent challenges
3122015 Ajaz S Hussain PhD 40
Th
e V
oic
e o
f th
eA
mer
ican
P
sych
iatr
ic A
sso
ciat
ion
and
th
e P
sych
iatr
ic C
om
mu
nit
y
Physicians Question FDAs Confidence in Generic Drugs Safety Efficacy (OCTOBER 24 2014)
bull ldquomost patientsrdquo is not the same asldquo all patientsrdquo and whether the 24 to 36 normal subjects used in the agencys bioequivalency tests represents the full range of individual variation in the way drugs are absorbed across the pharmaceutical using population is uncertain
bull Individuals can sometimes be allergic and react differently to whatever substance goes into making up the capsule or the tablet
FDA Flags Generic Versions of ADHD Medication(NOVEMBER 14 2014)
bull FDA changed the therapeutic equivalence (TE) rating from AB to BXmdashmeaning that the products are still approved and can be prescribed but are no longer recommended as automatic substitutes
RLD Variability Can be a block-buster opportunityFocus on lsquocontrol strategyrsquo
bull Overcoming CP amp IP provide FDA a submission they need to address CP
bull Then begin with QTPP CQArsquos hellip skip lsquodesign spacersquo and focus on lsquocontrol strategy
bull The entire development team should read the complete package insert of RLD
bull Discuss to ensure a common understandingbull Failure modes amp intended use
bull Pharmaceutical Equivalence
bull Bioequivalence
bull Other studies
QbD Challenges
3122015 Ajaz S Hussain PhD 41
NewRegulators are not prepared to handle QbD applications
NewMisalignment of international regulatory authorities
New and Generics
RampD incentivized for lsquoshots on the goalrsquo not QbD
GenericsLack of belief in business case ndash lsquoGenerics are all about file first figure out laterrsquo
Biologics Lack of technology to execute
Ted Fuhr Mackinsey amp Company June 2010 FDA Advisory Committee
Summary
bull Excipient functionality can contribute in critical ways to product quality amp performance adequate control is necessary
bull Our databases tools and knowledge are lagging behind the rapidly increasing complexity and uncertainty
bull Risk to quality and to business is increasing and regulatory transitions pose additional difficulties
bull Effective knowledge management ndash IT and Human practices ndash is critical for organizational lsquobottom-linersquo
bull We all must come together collaboratively to address the urgent needs we owe it to the patients we serve
3122015 Ajaz S Hussain PhD 42
Knowledge Management amp Culture of Quality
Ajaz S Hussain PhD
Insight Advice amp Solutions LLCMaryland USA
Executive Director the National Institute for Pharmaceutical Technology amp Education
3122015 Ajaz S Hussain PhD 43
3122015 Ajaz S Hussain PhD 44
Life-cycle approach needed for knowledge management
Investigational ProductscGMPs
DevelopmentTechnology
TransferCommercial
ManufacturingDiscontinuation
Management Responsibility
Process Performance amp Product Quality Monitoring SystemCAPA Change Management Management Review
PQS Elements
Knowledge ManagementQuality Risk ManagementEnablers
ICH Q10 KM is a systematic approach to acquiring analyzing storing and disseminating information related to products manufacturing processes and components
Based on ICH Q10
ldquowe can be blind to the obvious and we are also blind to our blindnessrdquo
Daniel Kahneman Thinking Fast and Slow
3142015 Ajazajazhussaincom 45
httpwebmiteduperscipeopleadelsoncheckershadow_proofhtml
3122015 Ajaz S Hussain PhD 46
1938 The Federal Food Drug and Cosmetic (FDC)
bull 1937 Elixir of Sulfanilamide
1962 Kefauver-Harris Drug Amendments
bull 1962 Thalidomide
bull 1960 Color Additive Amendment
bull 1958 Food Additives Amendment GRAS
bull 1960 Color Additive Amendment
bull 1958 Food Additives Amendment GRAS
1992 Generic Drug Enforcement Act
bull1989 L-Tryptophan
bull 1989 Generic Drug Scandal
bull 1988 Food and Drug Administration Act
bull 1984 Fines Enhancement Laws Drug Price Competition and Patent Term Restoration Act
2012 Food and Drug Administration Safety and Innovation Act (FDASIA)
bull 2007 Heparin Disaster
2013 Pandemic and All-Hazards Preparedness Reauthorization Act (PAHPRA) Drug Quality and Security Act
bull 2012 The Deadly Meningitis Outbreak
Past 70 years 1937 ndash 2007 The diethylene glycol (DEG) narrative
3122015 Ajaz S Hussain PhD 47
0
5
10
15
20
25
30
35
Yea
rs
DEG Years since the previous incident
0
50
100
150
200
250
300
350
Number of Reported Deaths
1937
Eli
xir
of
Sulf
anil
amid
e
2007T
ootp
aste
conta
min
atio
n
0 70 years 0 70 years
Frequent reports
Mumbai Mumbai
Data from Excipient Fest Janeen Skutnik Chair ndashIPECAmericas 2009
Past 70+ years DEG contamination or economically motivated adulteration
3122015 Ajaz S Hussain PhD 48
Reported cases underestimate the real tragedy rapid intervention may not occur
Epidemic of Pediatric Deaths From Acute Renal Failure Caused by
Diethylene Glycol Poisoning JAMA 1998279(15)1175-1180
doi101001jama279151175
Month of hospital admission for children with
acute renal failure Haiti
October 1995-October 1996
Diethylene glycol poisoning in Gurgaon India 1998Bulletin of the World Health Organization 2001 79 88ndash95
We report a second episode of poisoning occurring in 1998 in
India as a result of children ingesting diethylene glycol at
least 33 children are known to have died
At the beginning of the investigation we never imagined that
contaminated medicine was causing acute renal failure in
children
A brand of cough expectorant manufactured by a local
pharmaceutical company was found by the Central Drugs
Laboratory Calcutta to contain 175 (vv) diethylene
glycol
The district and state drug controller had tested many
samples using thin layer chromatography before a sample of
medicine tested positive for diethylene glycol at the Central
Drugs Laboratory None of the earlier samples was found to
be contaminated
3122015 Ajaz S Hussain PhD 49
Guidance for Industry Testing of
Glycerin for Diethylene Glycol
CDER May 2007 Compliance
1 Manufacturers did not perform full
identity testing on the glycerin raw
material including tests to quantify
the amount of DEG
2 Relied on the certificate of analysis
(COA)
3 The origin of the glycerin was not
easily apparent from the COA
4 The COA was often a copy of a COA
on the letterhead of the distributor
5 The chain of custody or distribution
history of the glycerin was also not
readily known
USP Glycerin Monograph
Type of Posting Revision Bulletin
Posting Date 04ndashFebndash2009
Official Date 01ndashMayndash2009
Because of the serious hazards
associated withhellip and in response to
recommendations set forth in the
FDA Guidance for Industry Testing
of Glycerin for Diethylene Glycol
published in May 2007 USP has
revised the USP Glycerin monograph
Because diethylene glycol and
ethylene glycol are considered
unacceptable toxic substances the
testing of USP Glycerin should
demonstrate the absence of these
substances
April 2007 FDA request to
USP to revise the Glycerin
monographrsquos
IDENTIFICATION section
Revision includes adding ndash
Identification test B LIMIT OF
DIETHYLENE GLYCOL AND
ETHYLENE GLYCOL to detect
and quantify DEGEG in Glycerin
minus Is no longer part of the impurity
testing
ldquoLimit of DEG and Related
Compoundsrdquo minus Introduces a
capillary gas-chromatographic
(GC) method with flame ionization
detection (FID) minus Limit of NMT
010 each for diethylene glycol
and ethylene glycol is found
70+ years to get here how difficult will it be to change habits such as lsquoblind reliance of COArsquo
3122015 Ajaz S Hussain PhD 50
Personality and Habitual Frame Biases
Myers Brigs ENTJ (first tested at FDA)
S
TF
Expanded frame
future
possibilities
objective lsquocause
and effectrsquo
Expanded frame
future
possibilities
people and
relationships
Narrow frame
the present
individuals and
relationships
Narrow frame
the present
objective
cause and
effect
N
Based on Stanford Webinar - How to Overcome the Top 3 MegaBiases in Decision-Making
Stanford Universityrsquos Strategic Decision and Risk Management certificate program
From Mapping a Managers Brain on Incentives
Social
influences
Relative
thinking
UncertaintyComplexity
By Design Intention to act consciously
bull In the interest of patients and to continually improve this ability bull To provide a healing touch ndash one life at a time in what we do and how we
do it
1292014 Ajazajazhussaincom 51
Consciously
Scientific methodology
Engineering Design
Plan-Do-Check-Act
Subconsciously
Habits (work to get rid of bad ones)
Habits (work to cultivate good one)
Keystone habits (Safety Alcoa ALCOA of data integrity)
The Power of Habit Why We Do What We Do in Life and Business Charles Duhigg (2012)
httpwwwslideshareneta2zpharmscipharmaceutical-culture-of-quality
What does it take to come out of the cGMP crisis
Persuasive demonstration of
(1) Ability to face facts
(2) Legal amp regulatory requirements
3) Systems approach to quality
4) Changing behavior amp culture
What is often missed or is unconvincing is how you will strengthen culture of quality
ldquoLet one who wants to move and convince others first be convinced and moved themselvesrdquo Thomas Carlyle
Signals that question the competence motivation andor integrity of company personnel
Do not defend the plainly indefensible it adds further serious credibility costs
3142015 Ajazajazhussaincom 52
Quality is everyones responsibility
Lack of knowledge that is
the problem
If you do not know how to ask the
right question you discover nothing
If you cant describe what you
are doing as a process you dont know what youre
doing
Rational behavior requires theory
Reactive behavior requires only reflex
action
Whenever there is fear you will get wrong figures
3142015 Ajazajazhussaincom 53
Selected quotes W Edwards Deming
3142015 Ajazajazhussaincom 54
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
ldquoWE CANNOT CHANGE THE HUMAN CONDITION BUThellipWE CAN CHANGE THE CONDITIONS UNDER WHICH HUMANS WORKrdquo JAMES REASON
Disregard to Malice
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 55
ldquohelliprecords not completed
contemporaneouslyrdquo
ldquohellipobserved analyst back-date logbooksrdquo
ldquohelliptrial injectionshelliprdquo
ldquohellipresults failing specifications are
retested until acceptable results are obtainedhelliprdquo
ldquohellipover-writing electronic raw datahelliprdquo
ldquohellipOOS not investigates per XYZ SOPrdquo
ldquohellipappropriate controls not establishedhelliprdquo
Each additional observation adds
reasons to confirm that this is very likely a system
with intentional lsquoholesrsquo in its
defenses
Preconditions
Rationalization amp Attitude
Pressure amp Incentive
Opportunity ndashlsquoholes in the QMSrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 56
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 57
Attitude towards the behavior
Subjective norm
Perceived behavioral
control
IntentionFuture
Behavior
usually found to predict behavioral intentions with a high degree of accuracy
intentions in combination with perceived behavioral control can account for a considerable proportion of variance in behavior
PastBehavior
Ajen I The theory of planned behavior ORGANIZATIONAL BEHAVIOR AND HUMAN DECISION PROCESSES 50 179-211 (1991)
Heparin tragedy 2007 and 2008
FDA reports 149 deaths with allergic or hypersensitivity symptoms during that period
bull Contaminated heparin from China
QC Testing
bull Initial testing failed to detect the contaminant
Pharmacovigilence
bull Signals in the pharmacovigilence systems responded slowly and
Eventually the severity of reactions associated made it likely that the contamination would be detected
bull too late for those who died or were injured
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 58
Congressman Shimkus When the drug safety system fails people get sick Some die
bull Some of these people are already very vulnerable and proving the cause of harm from impurities adulteration and counterfeits can be elusive
It is hard to detect harm
bull Certainly the companies are obligated to ensure a culture of quality and maintain vigilance as well This reflects a systems approach to safety
FDA inspectors look for a culture of quality at
manufacturing facilities
bull FDA policies led to the failure to inspect the Chinese plantThis system approach wasnt at
play here
bull While it doesnt deny the counterfeit source tries to say that counterfeits didnt cause the reaction as if the adulteration itself was no big deal Is this an acceptable mindset helliphelliphellip
This brings me to China and its quality culture or lack thereof
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 59
ONE HUNDRED TENTH CONGRESS SECOND SESSION APRIL 29 2008 Serial No 110-109
21 CFR PART 211 SUBPARTS -Deviations signal gaps in CoQ
bullGENERAL PROVISIONSA
bullORGANIZATION AND PERSONNELB
bullBUILDINGS AND FACILITIESC
bullEQUIPMENTD
bullCONTROL OF COMPONENTS AND DRUG PRODUCT CONTAINERS AND CLOSURESE
bullPRODUCTION AND PROCESS CONTROLSF
bullPACKAGING AND LABELING CONTROLG
bullHOLDING AND DISTRIBUTIONH
bullLABORATORY CONTROLSI
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 60
For example the combinationhellip
The Power of Habit Why We Do What We Do in Life and Business Charles Duhigg (2012)
bull Scientific methodology
bull Engineering Design
bull Plan-Do-Check-ActConsciously
bull Habits (work to get rid of bad ones)
bull Habits (work to cultivate good one)
bull Keystone habits (Safety Alcoa ALCOA of data integrity)
Subconsciously
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 61
CoQ How
bull What are the predictors of CoQCoQ Manifests by Design -
lsquoquality by designrsquo the foundation
bull 1 2 3When do people change their behaviors
bull A B C D (any body can dance)What makes a QMS effective
bull X Y ZWhen proactive compliance occurs
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 62
Going beyond rules pays
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 63
Human behavior Connecting the Dots With the Right Connectors
GXPs ndash rational behaviors
How proactive compliance is achieved X Y Z
Quality Management System
What makes a QMS reliable A B C D
Culture of Quality
Why people change their behavior 1 2 3
Human Behaviors Beyond GXPs
Predictors of Culture of Quality
Why What and How of Culture of Quality
9192014 copy Ajaz S Hussain | INSIGHT ADVICE amp SOLUTIONS LLC 64
Predictors of CoQ Act consciously in the interest of patients ndash when no one is looking
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 65
Only four attributes
actually predict a culture of
quality
Leadership Emphasis
Message Credibility
Peer Involvement
Employee Empower-ment
People will change their
behavior if they see the new behavior as
Normal
(1)
Rewarding
(2)
Easy
(3)
Dr W Edwards Demingrsquos - ldquoOut of the crisisrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 66
The journey requires leadership
with Profound Knowledge as a
guide
bull As leaders responsible for system change top management is most in need of profound knowledge
bull Quality is often determined in the boardroom
bull Problems arise when management reacts to common cause or chance variation as if it were special cause variation
bull Prediction based in theory provides a foundation for planning a course of action Plan ndash Do ndash Check ndash Act
bull The leader serves the people with clear vision and guidance to empower them To be empowered is to share ownership in the identity
bull Giving people a certain degree of control over their work fulfills the need for freedom and provides opportunity for taking joy in work
Profound Knowledge as a guide
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 67
Appreciation for a System
Theory of Knowledge
Knowledge about
Variation
Human Behavior -Psychology of Change
A
B
C
D+
Systems Approach for ErrorDeviation Management
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 68
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
Human error models and management J Reason BMJ 320 768ndash770 (2000)
D+
Culture of Error Management परबधनbull Error strain
bull Covering upFear of Errors
bull Anticipation
bull Risk takingAwareness
bull Development QbDRFT
bull Error detection Communication
bull Analyzing errors Correction
Mastery orientation
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 69
Dots amp Connections
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 70
CoQ
1
2
3
QMS
A
B
C
D
GXP Behaviors
X
Y
Z
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 71
Culture of Quality
Normal
Rewarding
Easy
QMS
System
Knowledge
Variation
Behavior
Behavior -GXPs
Fear Removed
Mastery
Awareness
EnvironmentLeadership Emphasis
Message Credibility
Peer Involvement
Employee Empowerment
Connect to CoQ
Connect to GXPs
A Framework and a Tool (for gap analysis)
RLD Variability Can be a block-buster opportunityFocus on lsquocontrol strategyrsquo
bull Overcoming CP amp IP provide FDA a submission they need to address CP
bull Then begin with QTPP CQArsquos hellip skip lsquodesign spacersquo and focus on lsquocontrol strategy
bull The entire development team should read the complete package insert of RLD
bull Discuss to ensure a common understandingbull Failure modes amp intended use
bull Pharmaceutical Equivalence
bull Bioequivalence
bull Other studies
QbD Challenges
3122015 Ajaz S Hussain PhD 41
NewRegulators are not prepared to handle QbD applications
NewMisalignment of international regulatory authorities
New and Generics
RampD incentivized for lsquoshots on the goalrsquo not QbD
GenericsLack of belief in business case ndash lsquoGenerics are all about file first figure out laterrsquo
Biologics Lack of technology to execute
Ted Fuhr Mackinsey amp Company June 2010 FDA Advisory Committee
Summary
bull Excipient functionality can contribute in critical ways to product quality amp performance adequate control is necessary
bull Our databases tools and knowledge are lagging behind the rapidly increasing complexity and uncertainty
bull Risk to quality and to business is increasing and regulatory transitions pose additional difficulties
bull Effective knowledge management ndash IT and Human practices ndash is critical for organizational lsquobottom-linersquo
bull We all must come together collaboratively to address the urgent needs we owe it to the patients we serve
3122015 Ajaz S Hussain PhD 42
Knowledge Management amp Culture of Quality
Ajaz S Hussain PhD
Insight Advice amp Solutions LLCMaryland USA
Executive Director the National Institute for Pharmaceutical Technology amp Education
3122015 Ajaz S Hussain PhD 43
3122015 Ajaz S Hussain PhD 44
Life-cycle approach needed for knowledge management
Investigational ProductscGMPs
DevelopmentTechnology
TransferCommercial
ManufacturingDiscontinuation
Management Responsibility
Process Performance amp Product Quality Monitoring SystemCAPA Change Management Management Review
PQS Elements
Knowledge ManagementQuality Risk ManagementEnablers
ICH Q10 KM is a systematic approach to acquiring analyzing storing and disseminating information related to products manufacturing processes and components
Based on ICH Q10
ldquowe can be blind to the obvious and we are also blind to our blindnessrdquo
Daniel Kahneman Thinking Fast and Slow
3142015 Ajazajazhussaincom 45
httpwebmiteduperscipeopleadelsoncheckershadow_proofhtml
3122015 Ajaz S Hussain PhD 46
1938 The Federal Food Drug and Cosmetic (FDC)
bull 1937 Elixir of Sulfanilamide
1962 Kefauver-Harris Drug Amendments
bull 1962 Thalidomide
bull 1960 Color Additive Amendment
bull 1958 Food Additives Amendment GRAS
bull 1960 Color Additive Amendment
bull 1958 Food Additives Amendment GRAS
1992 Generic Drug Enforcement Act
bull1989 L-Tryptophan
bull 1989 Generic Drug Scandal
bull 1988 Food and Drug Administration Act
bull 1984 Fines Enhancement Laws Drug Price Competition and Patent Term Restoration Act
2012 Food and Drug Administration Safety and Innovation Act (FDASIA)
bull 2007 Heparin Disaster
2013 Pandemic and All-Hazards Preparedness Reauthorization Act (PAHPRA) Drug Quality and Security Act
bull 2012 The Deadly Meningitis Outbreak
Past 70 years 1937 ndash 2007 The diethylene glycol (DEG) narrative
3122015 Ajaz S Hussain PhD 47
0
5
10
15
20
25
30
35
Yea
rs
DEG Years since the previous incident
0
50
100
150
200
250
300
350
Number of Reported Deaths
1937
Eli
xir
of
Sulf
anil
amid
e
2007T
ootp
aste
conta
min
atio
n
0 70 years 0 70 years
Frequent reports
Mumbai Mumbai
Data from Excipient Fest Janeen Skutnik Chair ndashIPECAmericas 2009
Past 70+ years DEG contamination or economically motivated adulteration
3122015 Ajaz S Hussain PhD 48
Reported cases underestimate the real tragedy rapid intervention may not occur
Epidemic of Pediatric Deaths From Acute Renal Failure Caused by
Diethylene Glycol Poisoning JAMA 1998279(15)1175-1180
doi101001jama279151175
Month of hospital admission for children with
acute renal failure Haiti
October 1995-October 1996
Diethylene glycol poisoning in Gurgaon India 1998Bulletin of the World Health Organization 2001 79 88ndash95
We report a second episode of poisoning occurring in 1998 in
India as a result of children ingesting diethylene glycol at
least 33 children are known to have died
At the beginning of the investigation we never imagined that
contaminated medicine was causing acute renal failure in
children
A brand of cough expectorant manufactured by a local
pharmaceutical company was found by the Central Drugs
Laboratory Calcutta to contain 175 (vv) diethylene
glycol
The district and state drug controller had tested many
samples using thin layer chromatography before a sample of
medicine tested positive for diethylene glycol at the Central
Drugs Laboratory None of the earlier samples was found to
be contaminated
3122015 Ajaz S Hussain PhD 49
Guidance for Industry Testing of
Glycerin for Diethylene Glycol
CDER May 2007 Compliance
1 Manufacturers did not perform full
identity testing on the glycerin raw
material including tests to quantify
the amount of DEG
2 Relied on the certificate of analysis
(COA)
3 The origin of the glycerin was not
easily apparent from the COA
4 The COA was often a copy of a COA
on the letterhead of the distributor
5 The chain of custody or distribution
history of the glycerin was also not
readily known
USP Glycerin Monograph
Type of Posting Revision Bulletin
Posting Date 04ndashFebndash2009
Official Date 01ndashMayndash2009
Because of the serious hazards
associated withhellip and in response to
recommendations set forth in the
FDA Guidance for Industry Testing
of Glycerin for Diethylene Glycol
published in May 2007 USP has
revised the USP Glycerin monograph
Because diethylene glycol and
ethylene glycol are considered
unacceptable toxic substances the
testing of USP Glycerin should
demonstrate the absence of these
substances
April 2007 FDA request to
USP to revise the Glycerin
monographrsquos
IDENTIFICATION section
Revision includes adding ndash
Identification test B LIMIT OF
DIETHYLENE GLYCOL AND
ETHYLENE GLYCOL to detect
and quantify DEGEG in Glycerin
minus Is no longer part of the impurity
testing
ldquoLimit of DEG and Related
Compoundsrdquo minus Introduces a
capillary gas-chromatographic
(GC) method with flame ionization
detection (FID) minus Limit of NMT
010 each for diethylene glycol
and ethylene glycol is found
70+ years to get here how difficult will it be to change habits such as lsquoblind reliance of COArsquo
3122015 Ajaz S Hussain PhD 50
Personality and Habitual Frame Biases
Myers Brigs ENTJ (first tested at FDA)
S
TF
Expanded frame
future
possibilities
objective lsquocause
and effectrsquo
Expanded frame
future
possibilities
people and
relationships
Narrow frame
the present
individuals and
relationships
Narrow frame
the present
objective
cause and
effect
N
Based on Stanford Webinar - How to Overcome the Top 3 MegaBiases in Decision-Making
Stanford Universityrsquos Strategic Decision and Risk Management certificate program
From Mapping a Managers Brain on Incentives
Social
influences
Relative
thinking
UncertaintyComplexity
By Design Intention to act consciously
bull In the interest of patients and to continually improve this ability bull To provide a healing touch ndash one life at a time in what we do and how we
do it
1292014 Ajazajazhussaincom 51
Consciously
Scientific methodology
Engineering Design
Plan-Do-Check-Act
Subconsciously
Habits (work to get rid of bad ones)
Habits (work to cultivate good one)
Keystone habits (Safety Alcoa ALCOA of data integrity)
The Power of Habit Why We Do What We Do in Life and Business Charles Duhigg (2012)
httpwwwslideshareneta2zpharmscipharmaceutical-culture-of-quality
What does it take to come out of the cGMP crisis
Persuasive demonstration of
(1) Ability to face facts
(2) Legal amp regulatory requirements
3) Systems approach to quality
4) Changing behavior amp culture
What is often missed or is unconvincing is how you will strengthen culture of quality
ldquoLet one who wants to move and convince others first be convinced and moved themselvesrdquo Thomas Carlyle
Signals that question the competence motivation andor integrity of company personnel
Do not defend the plainly indefensible it adds further serious credibility costs
3142015 Ajazajazhussaincom 52
Quality is everyones responsibility
Lack of knowledge that is
the problem
If you do not know how to ask the
right question you discover nothing
If you cant describe what you
are doing as a process you dont know what youre
doing
Rational behavior requires theory
Reactive behavior requires only reflex
action
Whenever there is fear you will get wrong figures
3142015 Ajazajazhussaincom 53
Selected quotes W Edwards Deming
3142015 Ajazajazhussaincom 54
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
ldquoWE CANNOT CHANGE THE HUMAN CONDITION BUThellipWE CAN CHANGE THE CONDITIONS UNDER WHICH HUMANS WORKrdquo JAMES REASON
Disregard to Malice
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 55
ldquohelliprecords not completed
contemporaneouslyrdquo
ldquohellipobserved analyst back-date logbooksrdquo
ldquohelliptrial injectionshelliprdquo
ldquohellipresults failing specifications are
retested until acceptable results are obtainedhelliprdquo
ldquohellipover-writing electronic raw datahelliprdquo
ldquohellipOOS not investigates per XYZ SOPrdquo
ldquohellipappropriate controls not establishedhelliprdquo
Each additional observation adds
reasons to confirm that this is very likely a system
with intentional lsquoholesrsquo in its
defenses
Preconditions
Rationalization amp Attitude
Pressure amp Incentive
Opportunity ndashlsquoholes in the QMSrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 56
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 57
Attitude towards the behavior
Subjective norm
Perceived behavioral
control
IntentionFuture
Behavior
usually found to predict behavioral intentions with a high degree of accuracy
intentions in combination with perceived behavioral control can account for a considerable proportion of variance in behavior
PastBehavior
Ajen I The theory of planned behavior ORGANIZATIONAL BEHAVIOR AND HUMAN DECISION PROCESSES 50 179-211 (1991)
Heparin tragedy 2007 and 2008
FDA reports 149 deaths with allergic or hypersensitivity symptoms during that period
bull Contaminated heparin from China
QC Testing
bull Initial testing failed to detect the contaminant
Pharmacovigilence
bull Signals in the pharmacovigilence systems responded slowly and
Eventually the severity of reactions associated made it likely that the contamination would be detected
bull too late for those who died or were injured
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 58
Congressman Shimkus When the drug safety system fails people get sick Some die
bull Some of these people are already very vulnerable and proving the cause of harm from impurities adulteration and counterfeits can be elusive
It is hard to detect harm
bull Certainly the companies are obligated to ensure a culture of quality and maintain vigilance as well This reflects a systems approach to safety
FDA inspectors look for a culture of quality at
manufacturing facilities
bull FDA policies led to the failure to inspect the Chinese plantThis system approach wasnt at
play here
bull While it doesnt deny the counterfeit source tries to say that counterfeits didnt cause the reaction as if the adulteration itself was no big deal Is this an acceptable mindset helliphelliphellip
This brings me to China and its quality culture or lack thereof
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 59
ONE HUNDRED TENTH CONGRESS SECOND SESSION APRIL 29 2008 Serial No 110-109
21 CFR PART 211 SUBPARTS -Deviations signal gaps in CoQ
bullGENERAL PROVISIONSA
bullORGANIZATION AND PERSONNELB
bullBUILDINGS AND FACILITIESC
bullEQUIPMENTD
bullCONTROL OF COMPONENTS AND DRUG PRODUCT CONTAINERS AND CLOSURESE
bullPRODUCTION AND PROCESS CONTROLSF
bullPACKAGING AND LABELING CONTROLG
bullHOLDING AND DISTRIBUTIONH
bullLABORATORY CONTROLSI
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 60
For example the combinationhellip
The Power of Habit Why We Do What We Do in Life and Business Charles Duhigg (2012)
bull Scientific methodology
bull Engineering Design
bull Plan-Do-Check-ActConsciously
bull Habits (work to get rid of bad ones)
bull Habits (work to cultivate good one)
bull Keystone habits (Safety Alcoa ALCOA of data integrity)
Subconsciously
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 61
CoQ How
bull What are the predictors of CoQCoQ Manifests by Design -
lsquoquality by designrsquo the foundation
bull 1 2 3When do people change their behaviors
bull A B C D (any body can dance)What makes a QMS effective
bull X Y ZWhen proactive compliance occurs
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 62
Going beyond rules pays
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 63
Human behavior Connecting the Dots With the Right Connectors
GXPs ndash rational behaviors
How proactive compliance is achieved X Y Z
Quality Management System
What makes a QMS reliable A B C D
Culture of Quality
Why people change their behavior 1 2 3
Human Behaviors Beyond GXPs
Predictors of Culture of Quality
Why What and How of Culture of Quality
9192014 copy Ajaz S Hussain | INSIGHT ADVICE amp SOLUTIONS LLC 64
Predictors of CoQ Act consciously in the interest of patients ndash when no one is looking
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 65
Only four attributes
actually predict a culture of
quality
Leadership Emphasis
Message Credibility
Peer Involvement
Employee Empower-ment
People will change their
behavior if they see the new behavior as
Normal
(1)
Rewarding
(2)
Easy
(3)
Dr W Edwards Demingrsquos - ldquoOut of the crisisrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 66
The journey requires leadership
with Profound Knowledge as a
guide
bull As leaders responsible for system change top management is most in need of profound knowledge
bull Quality is often determined in the boardroom
bull Problems arise when management reacts to common cause or chance variation as if it were special cause variation
bull Prediction based in theory provides a foundation for planning a course of action Plan ndash Do ndash Check ndash Act
bull The leader serves the people with clear vision and guidance to empower them To be empowered is to share ownership in the identity
bull Giving people a certain degree of control over their work fulfills the need for freedom and provides opportunity for taking joy in work
Profound Knowledge as a guide
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 67
Appreciation for a System
Theory of Knowledge
Knowledge about
Variation
Human Behavior -Psychology of Change
A
B
C
D+
Systems Approach for ErrorDeviation Management
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 68
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
Human error models and management J Reason BMJ 320 768ndash770 (2000)
D+
Culture of Error Management परबधनbull Error strain
bull Covering upFear of Errors
bull Anticipation
bull Risk takingAwareness
bull Development QbDRFT
bull Error detection Communication
bull Analyzing errors Correction
Mastery orientation
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 69
Dots amp Connections
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 70
CoQ
1
2
3
QMS
A
B
C
D
GXP Behaviors
X
Y
Z
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 71
Culture of Quality
Normal
Rewarding
Easy
QMS
System
Knowledge
Variation
Behavior
Behavior -GXPs
Fear Removed
Mastery
Awareness
EnvironmentLeadership Emphasis
Message Credibility
Peer Involvement
Employee Empowerment
Connect to CoQ
Connect to GXPs
A Framework and a Tool (for gap analysis)
Summary
bull Excipient functionality can contribute in critical ways to product quality amp performance adequate control is necessary
bull Our databases tools and knowledge are lagging behind the rapidly increasing complexity and uncertainty
bull Risk to quality and to business is increasing and regulatory transitions pose additional difficulties
bull Effective knowledge management ndash IT and Human practices ndash is critical for organizational lsquobottom-linersquo
bull We all must come together collaboratively to address the urgent needs we owe it to the patients we serve
3122015 Ajaz S Hussain PhD 42
Knowledge Management amp Culture of Quality
Ajaz S Hussain PhD
Insight Advice amp Solutions LLCMaryland USA
Executive Director the National Institute for Pharmaceutical Technology amp Education
3122015 Ajaz S Hussain PhD 43
3122015 Ajaz S Hussain PhD 44
Life-cycle approach needed for knowledge management
Investigational ProductscGMPs
DevelopmentTechnology
TransferCommercial
ManufacturingDiscontinuation
Management Responsibility
Process Performance amp Product Quality Monitoring SystemCAPA Change Management Management Review
PQS Elements
Knowledge ManagementQuality Risk ManagementEnablers
ICH Q10 KM is a systematic approach to acquiring analyzing storing and disseminating information related to products manufacturing processes and components
Based on ICH Q10
ldquowe can be blind to the obvious and we are also blind to our blindnessrdquo
Daniel Kahneman Thinking Fast and Slow
3142015 Ajazajazhussaincom 45
httpwebmiteduperscipeopleadelsoncheckershadow_proofhtml
3122015 Ajaz S Hussain PhD 46
1938 The Federal Food Drug and Cosmetic (FDC)
bull 1937 Elixir of Sulfanilamide
1962 Kefauver-Harris Drug Amendments
bull 1962 Thalidomide
bull 1960 Color Additive Amendment
bull 1958 Food Additives Amendment GRAS
bull 1960 Color Additive Amendment
bull 1958 Food Additives Amendment GRAS
1992 Generic Drug Enforcement Act
bull1989 L-Tryptophan
bull 1989 Generic Drug Scandal
bull 1988 Food and Drug Administration Act
bull 1984 Fines Enhancement Laws Drug Price Competition and Patent Term Restoration Act
2012 Food and Drug Administration Safety and Innovation Act (FDASIA)
bull 2007 Heparin Disaster
2013 Pandemic and All-Hazards Preparedness Reauthorization Act (PAHPRA) Drug Quality and Security Act
bull 2012 The Deadly Meningitis Outbreak
Past 70 years 1937 ndash 2007 The diethylene glycol (DEG) narrative
3122015 Ajaz S Hussain PhD 47
0
5
10
15
20
25
30
35
Yea
rs
DEG Years since the previous incident
0
50
100
150
200
250
300
350
Number of Reported Deaths
1937
Eli
xir
of
Sulf
anil
amid
e
2007T
ootp
aste
conta
min
atio
n
0 70 years 0 70 years
Frequent reports
Mumbai Mumbai
Data from Excipient Fest Janeen Skutnik Chair ndashIPECAmericas 2009
Past 70+ years DEG contamination or economically motivated adulteration
3122015 Ajaz S Hussain PhD 48
Reported cases underestimate the real tragedy rapid intervention may not occur
Epidemic of Pediatric Deaths From Acute Renal Failure Caused by
Diethylene Glycol Poisoning JAMA 1998279(15)1175-1180
doi101001jama279151175
Month of hospital admission for children with
acute renal failure Haiti
October 1995-October 1996
Diethylene glycol poisoning in Gurgaon India 1998Bulletin of the World Health Organization 2001 79 88ndash95
We report a second episode of poisoning occurring in 1998 in
India as a result of children ingesting diethylene glycol at
least 33 children are known to have died
At the beginning of the investigation we never imagined that
contaminated medicine was causing acute renal failure in
children
A brand of cough expectorant manufactured by a local
pharmaceutical company was found by the Central Drugs
Laboratory Calcutta to contain 175 (vv) diethylene
glycol
The district and state drug controller had tested many
samples using thin layer chromatography before a sample of
medicine tested positive for diethylene glycol at the Central
Drugs Laboratory None of the earlier samples was found to
be contaminated
3122015 Ajaz S Hussain PhD 49
Guidance for Industry Testing of
Glycerin for Diethylene Glycol
CDER May 2007 Compliance
1 Manufacturers did not perform full
identity testing on the glycerin raw
material including tests to quantify
the amount of DEG
2 Relied on the certificate of analysis
(COA)
3 The origin of the glycerin was not
easily apparent from the COA
4 The COA was often a copy of a COA
on the letterhead of the distributor
5 The chain of custody or distribution
history of the glycerin was also not
readily known
USP Glycerin Monograph
Type of Posting Revision Bulletin
Posting Date 04ndashFebndash2009
Official Date 01ndashMayndash2009
Because of the serious hazards
associated withhellip and in response to
recommendations set forth in the
FDA Guidance for Industry Testing
of Glycerin for Diethylene Glycol
published in May 2007 USP has
revised the USP Glycerin monograph
Because diethylene glycol and
ethylene glycol are considered
unacceptable toxic substances the
testing of USP Glycerin should
demonstrate the absence of these
substances
April 2007 FDA request to
USP to revise the Glycerin
monographrsquos
IDENTIFICATION section
Revision includes adding ndash
Identification test B LIMIT OF
DIETHYLENE GLYCOL AND
ETHYLENE GLYCOL to detect
and quantify DEGEG in Glycerin
minus Is no longer part of the impurity
testing
ldquoLimit of DEG and Related
Compoundsrdquo minus Introduces a
capillary gas-chromatographic
(GC) method with flame ionization
detection (FID) minus Limit of NMT
010 each for diethylene glycol
and ethylene glycol is found
70+ years to get here how difficult will it be to change habits such as lsquoblind reliance of COArsquo
3122015 Ajaz S Hussain PhD 50
Personality and Habitual Frame Biases
Myers Brigs ENTJ (first tested at FDA)
S
TF
Expanded frame
future
possibilities
objective lsquocause
and effectrsquo
Expanded frame
future
possibilities
people and
relationships
Narrow frame
the present
individuals and
relationships
Narrow frame
the present
objective
cause and
effect
N
Based on Stanford Webinar - How to Overcome the Top 3 MegaBiases in Decision-Making
Stanford Universityrsquos Strategic Decision and Risk Management certificate program
From Mapping a Managers Brain on Incentives
Social
influences
Relative
thinking
UncertaintyComplexity
By Design Intention to act consciously
bull In the interest of patients and to continually improve this ability bull To provide a healing touch ndash one life at a time in what we do and how we
do it
1292014 Ajazajazhussaincom 51
Consciously
Scientific methodology
Engineering Design
Plan-Do-Check-Act
Subconsciously
Habits (work to get rid of bad ones)
Habits (work to cultivate good one)
Keystone habits (Safety Alcoa ALCOA of data integrity)
The Power of Habit Why We Do What We Do in Life and Business Charles Duhigg (2012)
httpwwwslideshareneta2zpharmscipharmaceutical-culture-of-quality
What does it take to come out of the cGMP crisis
Persuasive demonstration of
(1) Ability to face facts
(2) Legal amp regulatory requirements
3) Systems approach to quality
4) Changing behavior amp culture
What is often missed or is unconvincing is how you will strengthen culture of quality
ldquoLet one who wants to move and convince others first be convinced and moved themselvesrdquo Thomas Carlyle
Signals that question the competence motivation andor integrity of company personnel
Do not defend the plainly indefensible it adds further serious credibility costs
3142015 Ajazajazhussaincom 52
Quality is everyones responsibility
Lack of knowledge that is
the problem
If you do not know how to ask the
right question you discover nothing
If you cant describe what you
are doing as a process you dont know what youre
doing
Rational behavior requires theory
Reactive behavior requires only reflex
action
Whenever there is fear you will get wrong figures
3142015 Ajazajazhussaincom 53
Selected quotes W Edwards Deming
3142015 Ajazajazhussaincom 54
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
ldquoWE CANNOT CHANGE THE HUMAN CONDITION BUThellipWE CAN CHANGE THE CONDITIONS UNDER WHICH HUMANS WORKrdquo JAMES REASON
Disregard to Malice
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 55
ldquohelliprecords not completed
contemporaneouslyrdquo
ldquohellipobserved analyst back-date logbooksrdquo
ldquohelliptrial injectionshelliprdquo
ldquohellipresults failing specifications are
retested until acceptable results are obtainedhelliprdquo
ldquohellipover-writing electronic raw datahelliprdquo
ldquohellipOOS not investigates per XYZ SOPrdquo
ldquohellipappropriate controls not establishedhelliprdquo
Each additional observation adds
reasons to confirm that this is very likely a system
with intentional lsquoholesrsquo in its
defenses
Preconditions
Rationalization amp Attitude
Pressure amp Incentive
Opportunity ndashlsquoholes in the QMSrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 56
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 57
Attitude towards the behavior
Subjective norm
Perceived behavioral
control
IntentionFuture
Behavior
usually found to predict behavioral intentions with a high degree of accuracy
intentions in combination with perceived behavioral control can account for a considerable proportion of variance in behavior
PastBehavior
Ajen I The theory of planned behavior ORGANIZATIONAL BEHAVIOR AND HUMAN DECISION PROCESSES 50 179-211 (1991)
Heparin tragedy 2007 and 2008
FDA reports 149 deaths with allergic or hypersensitivity symptoms during that period
bull Contaminated heparin from China
QC Testing
bull Initial testing failed to detect the contaminant
Pharmacovigilence
bull Signals in the pharmacovigilence systems responded slowly and
Eventually the severity of reactions associated made it likely that the contamination would be detected
bull too late for those who died or were injured
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 58
Congressman Shimkus When the drug safety system fails people get sick Some die
bull Some of these people are already very vulnerable and proving the cause of harm from impurities adulteration and counterfeits can be elusive
It is hard to detect harm
bull Certainly the companies are obligated to ensure a culture of quality and maintain vigilance as well This reflects a systems approach to safety
FDA inspectors look for a culture of quality at
manufacturing facilities
bull FDA policies led to the failure to inspect the Chinese plantThis system approach wasnt at
play here
bull While it doesnt deny the counterfeit source tries to say that counterfeits didnt cause the reaction as if the adulteration itself was no big deal Is this an acceptable mindset helliphelliphellip
This brings me to China and its quality culture or lack thereof
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 59
ONE HUNDRED TENTH CONGRESS SECOND SESSION APRIL 29 2008 Serial No 110-109
21 CFR PART 211 SUBPARTS -Deviations signal gaps in CoQ
bullGENERAL PROVISIONSA
bullORGANIZATION AND PERSONNELB
bullBUILDINGS AND FACILITIESC
bullEQUIPMENTD
bullCONTROL OF COMPONENTS AND DRUG PRODUCT CONTAINERS AND CLOSURESE
bullPRODUCTION AND PROCESS CONTROLSF
bullPACKAGING AND LABELING CONTROLG
bullHOLDING AND DISTRIBUTIONH
bullLABORATORY CONTROLSI
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 60
For example the combinationhellip
The Power of Habit Why We Do What We Do in Life and Business Charles Duhigg (2012)
bull Scientific methodology
bull Engineering Design
bull Plan-Do-Check-ActConsciously
bull Habits (work to get rid of bad ones)
bull Habits (work to cultivate good one)
bull Keystone habits (Safety Alcoa ALCOA of data integrity)
Subconsciously
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 61
CoQ How
bull What are the predictors of CoQCoQ Manifests by Design -
lsquoquality by designrsquo the foundation
bull 1 2 3When do people change their behaviors
bull A B C D (any body can dance)What makes a QMS effective
bull X Y ZWhen proactive compliance occurs
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 62
Going beyond rules pays
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 63
Human behavior Connecting the Dots With the Right Connectors
GXPs ndash rational behaviors
How proactive compliance is achieved X Y Z
Quality Management System
What makes a QMS reliable A B C D
Culture of Quality
Why people change their behavior 1 2 3
Human Behaviors Beyond GXPs
Predictors of Culture of Quality
Why What and How of Culture of Quality
9192014 copy Ajaz S Hussain | INSIGHT ADVICE amp SOLUTIONS LLC 64
Predictors of CoQ Act consciously in the interest of patients ndash when no one is looking
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 65
Only four attributes
actually predict a culture of
quality
Leadership Emphasis
Message Credibility
Peer Involvement
Employee Empower-ment
People will change their
behavior if they see the new behavior as
Normal
(1)
Rewarding
(2)
Easy
(3)
Dr W Edwards Demingrsquos - ldquoOut of the crisisrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 66
The journey requires leadership
with Profound Knowledge as a
guide
bull As leaders responsible for system change top management is most in need of profound knowledge
bull Quality is often determined in the boardroom
bull Problems arise when management reacts to common cause or chance variation as if it were special cause variation
bull Prediction based in theory provides a foundation for planning a course of action Plan ndash Do ndash Check ndash Act
bull The leader serves the people with clear vision and guidance to empower them To be empowered is to share ownership in the identity
bull Giving people a certain degree of control over their work fulfills the need for freedom and provides opportunity for taking joy in work
Profound Knowledge as a guide
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 67
Appreciation for a System
Theory of Knowledge
Knowledge about
Variation
Human Behavior -Psychology of Change
A
B
C
D+
Systems Approach for ErrorDeviation Management
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 68
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
Human error models and management J Reason BMJ 320 768ndash770 (2000)
D+
Culture of Error Management परबधनbull Error strain
bull Covering upFear of Errors
bull Anticipation
bull Risk takingAwareness
bull Development QbDRFT
bull Error detection Communication
bull Analyzing errors Correction
Mastery orientation
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 69
Dots amp Connections
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 70
CoQ
1
2
3
QMS
A
B
C
D
GXP Behaviors
X
Y
Z
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 71
Culture of Quality
Normal
Rewarding
Easy
QMS
System
Knowledge
Variation
Behavior
Behavior -GXPs
Fear Removed
Mastery
Awareness
EnvironmentLeadership Emphasis
Message Credibility
Peer Involvement
Employee Empowerment
Connect to CoQ
Connect to GXPs
A Framework and a Tool (for gap analysis)
Knowledge Management amp Culture of Quality
Ajaz S Hussain PhD
Insight Advice amp Solutions LLCMaryland USA
Executive Director the National Institute for Pharmaceutical Technology amp Education
3122015 Ajaz S Hussain PhD 43
3122015 Ajaz S Hussain PhD 44
Life-cycle approach needed for knowledge management
Investigational ProductscGMPs
DevelopmentTechnology
TransferCommercial
ManufacturingDiscontinuation
Management Responsibility
Process Performance amp Product Quality Monitoring SystemCAPA Change Management Management Review
PQS Elements
Knowledge ManagementQuality Risk ManagementEnablers
ICH Q10 KM is a systematic approach to acquiring analyzing storing and disseminating information related to products manufacturing processes and components
Based on ICH Q10
ldquowe can be blind to the obvious and we are also blind to our blindnessrdquo
Daniel Kahneman Thinking Fast and Slow
3142015 Ajazajazhussaincom 45
httpwebmiteduperscipeopleadelsoncheckershadow_proofhtml
3122015 Ajaz S Hussain PhD 46
1938 The Federal Food Drug and Cosmetic (FDC)
bull 1937 Elixir of Sulfanilamide
1962 Kefauver-Harris Drug Amendments
bull 1962 Thalidomide
bull 1960 Color Additive Amendment
bull 1958 Food Additives Amendment GRAS
bull 1960 Color Additive Amendment
bull 1958 Food Additives Amendment GRAS
1992 Generic Drug Enforcement Act
bull1989 L-Tryptophan
bull 1989 Generic Drug Scandal
bull 1988 Food and Drug Administration Act
bull 1984 Fines Enhancement Laws Drug Price Competition and Patent Term Restoration Act
2012 Food and Drug Administration Safety and Innovation Act (FDASIA)
bull 2007 Heparin Disaster
2013 Pandemic and All-Hazards Preparedness Reauthorization Act (PAHPRA) Drug Quality and Security Act
bull 2012 The Deadly Meningitis Outbreak
Past 70 years 1937 ndash 2007 The diethylene glycol (DEG) narrative
3122015 Ajaz S Hussain PhD 47
0
5
10
15
20
25
30
35
Yea
rs
DEG Years since the previous incident
0
50
100
150
200
250
300
350
Number of Reported Deaths
1937
Eli
xir
of
Sulf
anil
amid
e
2007T
ootp
aste
conta
min
atio
n
0 70 years 0 70 years
Frequent reports
Mumbai Mumbai
Data from Excipient Fest Janeen Skutnik Chair ndashIPECAmericas 2009
Past 70+ years DEG contamination or economically motivated adulteration
3122015 Ajaz S Hussain PhD 48
Reported cases underestimate the real tragedy rapid intervention may not occur
Epidemic of Pediatric Deaths From Acute Renal Failure Caused by
Diethylene Glycol Poisoning JAMA 1998279(15)1175-1180
doi101001jama279151175
Month of hospital admission for children with
acute renal failure Haiti
October 1995-October 1996
Diethylene glycol poisoning in Gurgaon India 1998Bulletin of the World Health Organization 2001 79 88ndash95
We report a second episode of poisoning occurring in 1998 in
India as a result of children ingesting diethylene glycol at
least 33 children are known to have died
At the beginning of the investigation we never imagined that
contaminated medicine was causing acute renal failure in
children
A brand of cough expectorant manufactured by a local
pharmaceutical company was found by the Central Drugs
Laboratory Calcutta to contain 175 (vv) diethylene
glycol
The district and state drug controller had tested many
samples using thin layer chromatography before a sample of
medicine tested positive for diethylene glycol at the Central
Drugs Laboratory None of the earlier samples was found to
be contaminated
3122015 Ajaz S Hussain PhD 49
Guidance for Industry Testing of
Glycerin for Diethylene Glycol
CDER May 2007 Compliance
1 Manufacturers did not perform full
identity testing on the glycerin raw
material including tests to quantify
the amount of DEG
2 Relied on the certificate of analysis
(COA)
3 The origin of the glycerin was not
easily apparent from the COA
4 The COA was often a copy of a COA
on the letterhead of the distributor
5 The chain of custody or distribution
history of the glycerin was also not
readily known
USP Glycerin Monograph
Type of Posting Revision Bulletin
Posting Date 04ndashFebndash2009
Official Date 01ndashMayndash2009
Because of the serious hazards
associated withhellip and in response to
recommendations set forth in the
FDA Guidance for Industry Testing
of Glycerin for Diethylene Glycol
published in May 2007 USP has
revised the USP Glycerin monograph
Because diethylene glycol and
ethylene glycol are considered
unacceptable toxic substances the
testing of USP Glycerin should
demonstrate the absence of these
substances
April 2007 FDA request to
USP to revise the Glycerin
monographrsquos
IDENTIFICATION section
Revision includes adding ndash
Identification test B LIMIT OF
DIETHYLENE GLYCOL AND
ETHYLENE GLYCOL to detect
and quantify DEGEG in Glycerin
minus Is no longer part of the impurity
testing
ldquoLimit of DEG and Related
Compoundsrdquo minus Introduces a
capillary gas-chromatographic
(GC) method with flame ionization
detection (FID) minus Limit of NMT
010 each for diethylene glycol
and ethylene glycol is found
70+ years to get here how difficult will it be to change habits such as lsquoblind reliance of COArsquo
3122015 Ajaz S Hussain PhD 50
Personality and Habitual Frame Biases
Myers Brigs ENTJ (first tested at FDA)
S
TF
Expanded frame
future
possibilities
objective lsquocause
and effectrsquo
Expanded frame
future
possibilities
people and
relationships
Narrow frame
the present
individuals and
relationships
Narrow frame
the present
objective
cause and
effect
N
Based on Stanford Webinar - How to Overcome the Top 3 MegaBiases in Decision-Making
Stanford Universityrsquos Strategic Decision and Risk Management certificate program
From Mapping a Managers Brain on Incentives
Social
influences
Relative
thinking
UncertaintyComplexity
By Design Intention to act consciously
bull In the interest of patients and to continually improve this ability bull To provide a healing touch ndash one life at a time in what we do and how we
do it
1292014 Ajazajazhussaincom 51
Consciously
Scientific methodology
Engineering Design
Plan-Do-Check-Act
Subconsciously
Habits (work to get rid of bad ones)
Habits (work to cultivate good one)
Keystone habits (Safety Alcoa ALCOA of data integrity)
The Power of Habit Why We Do What We Do in Life and Business Charles Duhigg (2012)
httpwwwslideshareneta2zpharmscipharmaceutical-culture-of-quality
What does it take to come out of the cGMP crisis
Persuasive demonstration of
(1) Ability to face facts
(2) Legal amp regulatory requirements
3) Systems approach to quality
4) Changing behavior amp culture
What is often missed or is unconvincing is how you will strengthen culture of quality
ldquoLet one who wants to move and convince others first be convinced and moved themselvesrdquo Thomas Carlyle
Signals that question the competence motivation andor integrity of company personnel
Do not defend the plainly indefensible it adds further serious credibility costs
3142015 Ajazajazhussaincom 52
Quality is everyones responsibility
Lack of knowledge that is
the problem
If you do not know how to ask the
right question you discover nothing
If you cant describe what you
are doing as a process you dont know what youre
doing
Rational behavior requires theory
Reactive behavior requires only reflex
action
Whenever there is fear you will get wrong figures
3142015 Ajazajazhussaincom 53
Selected quotes W Edwards Deming
3142015 Ajazajazhussaincom 54
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
ldquoWE CANNOT CHANGE THE HUMAN CONDITION BUThellipWE CAN CHANGE THE CONDITIONS UNDER WHICH HUMANS WORKrdquo JAMES REASON
Disregard to Malice
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 55
ldquohelliprecords not completed
contemporaneouslyrdquo
ldquohellipobserved analyst back-date logbooksrdquo
ldquohelliptrial injectionshelliprdquo
ldquohellipresults failing specifications are
retested until acceptable results are obtainedhelliprdquo
ldquohellipover-writing electronic raw datahelliprdquo
ldquohellipOOS not investigates per XYZ SOPrdquo
ldquohellipappropriate controls not establishedhelliprdquo
Each additional observation adds
reasons to confirm that this is very likely a system
with intentional lsquoholesrsquo in its
defenses
Preconditions
Rationalization amp Attitude
Pressure amp Incentive
Opportunity ndashlsquoholes in the QMSrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 56
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 57
Attitude towards the behavior
Subjective norm
Perceived behavioral
control
IntentionFuture
Behavior
usually found to predict behavioral intentions with a high degree of accuracy
intentions in combination with perceived behavioral control can account for a considerable proportion of variance in behavior
PastBehavior
Ajen I The theory of planned behavior ORGANIZATIONAL BEHAVIOR AND HUMAN DECISION PROCESSES 50 179-211 (1991)
Heparin tragedy 2007 and 2008
FDA reports 149 deaths with allergic or hypersensitivity symptoms during that period
bull Contaminated heparin from China
QC Testing
bull Initial testing failed to detect the contaminant
Pharmacovigilence
bull Signals in the pharmacovigilence systems responded slowly and
Eventually the severity of reactions associated made it likely that the contamination would be detected
bull too late for those who died or were injured
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 58
Congressman Shimkus When the drug safety system fails people get sick Some die
bull Some of these people are already very vulnerable and proving the cause of harm from impurities adulteration and counterfeits can be elusive
It is hard to detect harm
bull Certainly the companies are obligated to ensure a culture of quality and maintain vigilance as well This reflects a systems approach to safety
FDA inspectors look for a culture of quality at
manufacturing facilities
bull FDA policies led to the failure to inspect the Chinese plantThis system approach wasnt at
play here
bull While it doesnt deny the counterfeit source tries to say that counterfeits didnt cause the reaction as if the adulteration itself was no big deal Is this an acceptable mindset helliphelliphellip
This brings me to China and its quality culture or lack thereof
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 59
ONE HUNDRED TENTH CONGRESS SECOND SESSION APRIL 29 2008 Serial No 110-109
21 CFR PART 211 SUBPARTS -Deviations signal gaps in CoQ
bullGENERAL PROVISIONSA
bullORGANIZATION AND PERSONNELB
bullBUILDINGS AND FACILITIESC
bullEQUIPMENTD
bullCONTROL OF COMPONENTS AND DRUG PRODUCT CONTAINERS AND CLOSURESE
bullPRODUCTION AND PROCESS CONTROLSF
bullPACKAGING AND LABELING CONTROLG
bullHOLDING AND DISTRIBUTIONH
bullLABORATORY CONTROLSI
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 60
For example the combinationhellip
The Power of Habit Why We Do What We Do in Life and Business Charles Duhigg (2012)
bull Scientific methodology
bull Engineering Design
bull Plan-Do-Check-ActConsciously
bull Habits (work to get rid of bad ones)
bull Habits (work to cultivate good one)
bull Keystone habits (Safety Alcoa ALCOA of data integrity)
Subconsciously
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 61
CoQ How
bull What are the predictors of CoQCoQ Manifests by Design -
lsquoquality by designrsquo the foundation
bull 1 2 3When do people change their behaviors
bull A B C D (any body can dance)What makes a QMS effective
bull X Y ZWhen proactive compliance occurs
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 62
Going beyond rules pays
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 63
Human behavior Connecting the Dots With the Right Connectors
GXPs ndash rational behaviors
How proactive compliance is achieved X Y Z
Quality Management System
What makes a QMS reliable A B C D
Culture of Quality
Why people change their behavior 1 2 3
Human Behaviors Beyond GXPs
Predictors of Culture of Quality
Why What and How of Culture of Quality
9192014 copy Ajaz S Hussain | INSIGHT ADVICE amp SOLUTIONS LLC 64
Predictors of CoQ Act consciously in the interest of patients ndash when no one is looking
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 65
Only four attributes
actually predict a culture of
quality
Leadership Emphasis
Message Credibility
Peer Involvement
Employee Empower-ment
People will change their
behavior if they see the new behavior as
Normal
(1)
Rewarding
(2)
Easy
(3)
Dr W Edwards Demingrsquos - ldquoOut of the crisisrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 66
The journey requires leadership
with Profound Knowledge as a
guide
bull As leaders responsible for system change top management is most in need of profound knowledge
bull Quality is often determined in the boardroom
bull Problems arise when management reacts to common cause or chance variation as if it were special cause variation
bull Prediction based in theory provides a foundation for planning a course of action Plan ndash Do ndash Check ndash Act
bull The leader serves the people with clear vision and guidance to empower them To be empowered is to share ownership in the identity
bull Giving people a certain degree of control over their work fulfills the need for freedom and provides opportunity for taking joy in work
Profound Knowledge as a guide
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 67
Appreciation for a System
Theory of Knowledge
Knowledge about
Variation
Human Behavior -Psychology of Change
A
B
C
D+
Systems Approach for ErrorDeviation Management
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 68
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
Human error models and management J Reason BMJ 320 768ndash770 (2000)
D+
Culture of Error Management परबधनbull Error strain
bull Covering upFear of Errors
bull Anticipation
bull Risk takingAwareness
bull Development QbDRFT
bull Error detection Communication
bull Analyzing errors Correction
Mastery orientation
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 69
Dots amp Connections
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 70
CoQ
1
2
3
QMS
A
B
C
D
GXP Behaviors
X
Y
Z
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 71
Culture of Quality
Normal
Rewarding
Easy
QMS
System
Knowledge
Variation
Behavior
Behavior -GXPs
Fear Removed
Mastery
Awareness
EnvironmentLeadership Emphasis
Message Credibility
Peer Involvement
Employee Empowerment
Connect to CoQ
Connect to GXPs
A Framework and a Tool (for gap analysis)
3122015 Ajaz S Hussain PhD 44
Life-cycle approach needed for knowledge management
Investigational ProductscGMPs
DevelopmentTechnology
TransferCommercial
ManufacturingDiscontinuation
Management Responsibility
Process Performance amp Product Quality Monitoring SystemCAPA Change Management Management Review
PQS Elements
Knowledge ManagementQuality Risk ManagementEnablers
ICH Q10 KM is a systematic approach to acquiring analyzing storing and disseminating information related to products manufacturing processes and components
Based on ICH Q10
ldquowe can be blind to the obvious and we are also blind to our blindnessrdquo
Daniel Kahneman Thinking Fast and Slow
3142015 Ajazajazhussaincom 45
httpwebmiteduperscipeopleadelsoncheckershadow_proofhtml
3122015 Ajaz S Hussain PhD 46
1938 The Federal Food Drug and Cosmetic (FDC)
bull 1937 Elixir of Sulfanilamide
1962 Kefauver-Harris Drug Amendments
bull 1962 Thalidomide
bull 1960 Color Additive Amendment
bull 1958 Food Additives Amendment GRAS
bull 1960 Color Additive Amendment
bull 1958 Food Additives Amendment GRAS
1992 Generic Drug Enforcement Act
bull1989 L-Tryptophan
bull 1989 Generic Drug Scandal
bull 1988 Food and Drug Administration Act
bull 1984 Fines Enhancement Laws Drug Price Competition and Patent Term Restoration Act
2012 Food and Drug Administration Safety and Innovation Act (FDASIA)
bull 2007 Heparin Disaster
2013 Pandemic and All-Hazards Preparedness Reauthorization Act (PAHPRA) Drug Quality and Security Act
bull 2012 The Deadly Meningitis Outbreak
Past 70 years 1937 ndash 2007 The diethylene glycol (DEG) narrative
3122015 Ajaz S Hussain PhD 47
0
5
10
15
20
25
30
35
Yea
rs
DEG Years since the previous incident
0
50
100
150
200
250
300
350
Number of Reported Deaths
1937
Eli
xir
of
Sulf
anil
amid
e
2007T
ootp
aste
conta
min
atio
n
0 70 years 0 70 years
Frequent reports
Mumbai Mumbai
Data from Excipient Fest Janeen Skutnik Chair ndashIPECAmericas 2009
Past 70+ years DEG contamination or economically motivated adulteration
3122015 Ajaz S Hussain PhD 48
Reported cases underestimate the real tragedy rapid intervention may not occur
Epidemic of Pediatric Deaths From Acute Renal Failure Caused by
Diethylene Glycol Poisoning JAMA 1998279(15)1175-1180
doi101001jama279151175
Month of hospital admission for children with
acute renal failure Haiti
October 1995-October 1996
Diethylene glycol poisoning in Gurgaon India 1998Bulletin of the World Health Organization 2001 79 88ndash95
We report a second episode of poisoning occurring in 1998 in
India as a result of children ingesting diethylene glycol at
least 33 children are known to have died
At the beginning of the investigation we never imagined that
contaminated medicine was causing acute renal failure in
children
A brand of cough expectorant manufactured by a local
pharmaceutical company was found by the Central Drugs
Laboratory Calcutta to contain 175 (vv) diethylene
glycol
The district and state drug controller had tested many
samples using thin layer chromatography before a sample of
medicine tested positive for diethylene glycol at the Central
Drugs Laboratory None of the earlier samples was found to
be contaminated
3122015 Ajaz S Hussain PhD 49
Guidance for Industry Testing of
Glycerin for Diethylene Glycol
CDER May 2007 Compliance
1 Manufacturers did not perform full
identity testing on the glycerin raw
material including tests to quantify
the amount of DEG
2 Relied on the certificate of analysis
(COA)
3 The origin of the glycerin was not
easily apparent from the COA
4 The COA was often a copy of a COA
on the letterhead of the distributor
5 The chain of custody or distribution
history of the glycerin was also not
readily known
USP Glycerin Monograph
Type of Posting Revision Bulletin
Posting Date 04ndashFebndash2009
Official Date 01ndashMayndash2009
Because of the serious hazards
associated withhellip and in response to
recommendations set forth in the
FDA Guidance for Industry Testing
of Glycerin for Diethylene Glycol
published in May 2007 USP has
revised the USP Glycerin monograph
Because diethylene glycol and
ethylene glycol are considered
unacceptable toxic substances the
testing of USP Glycerin should
demonstrate the absence of these
substances
April 2007 FDA request to
USP to revise the Glycerin
monographrsquos
IDENTIFICATION section
Revision includes adding ndash
Identification test B LIMIT OF
DIETHYLENE GLYCOL AND
ETHYLENE GLYCOL to detect
and quantify DEGEG in Glycerin
minus Is no longer part of the impurity
testing
ldquoLimit of DEG and Related
Compoundsrdquo minus Introduces a
capillary gas-chromatographic
(GC) method with flame ionization
detection (FID) minus Limit of NMT
010 each for diethylene glycol
and ethylene glycol is found
70+ years to get here how difficult will it be to change habits such as lsquoblind reliance of COArsquo
3122015 Ajaz S Hussain PhD 50
Personality and Habitual Frame Biases
Myers Brigs ENTJ (first tested at FDA)
S
TF
Expanded frame
future
possibilities
objective lsquocause
and effectrsquo
Expanded frame
future
possibilities
people and
relationships
Narrow frame
the present
individuals and
relationships
Narrow frame
the present
objective
cause and
effect
N
Based on Stanford Webinar - How to Overcome the Top 3 MegaBiases in Decision-Making
Stanford Universityrsquos Strategic Decision and Risk Management certificate program
From Mapping a Managers Brain on Incentives
Social
influences
Relative
thinking
UncertaintyComplexity
By Design Intention to act consciously
bull In the interest of patients and to continually improve this ability bull To provide a healing touch ndash one life at a time in what we do and how we
do it
1292014 Ajazajazhussaincom 51
Consciously
Scientific methodology
Engineering Design
Plan-Do-Check-Act
Subconsciously
Habits (work to get rid of bad ones)
Habits (work to cultivate good one)
Keystone habits (Safety Alcoa ALCOA of data integrity)
The Power of Habit Why We Do What We Do in Life and Business Charles Duhigg (2012)
httpwwwslideshareneta2zpharmscipharmaceutical-culture-of-quality
What does it take to come out of the cGMP crisis
Persuasive demonstration of
(1) Ability to face facts
(2) Legal amp regulatory requirements
3) Systems approach to quality
4) Changing behavior amp culture
What is often missed or is unconvincing is how you will strengthen culture of quality
ldquoLet one who wants to move and convince others first be convinced and moved themselvesrdquo Thomas Carlyle
Signals that question the competence motivation andor integrity of company personnel
Do not defend the plainly indefensible it adds further serious credibility costs
3142015 Ajazajazhussaincom 52
Quality is everyones responsibility
Lack of knowledge that is
the problem
If you do not know how to ask the
right question you discover nothing
If you cant describe what you
are doing as a process you dont know what youre
doing
Rational behavior requires theory
Reactive behavior requires only reflex
action
Whenever there is fear you will get wrong figures
3142015 Ajazajazhussaincom 53
Selected quotes W Edwards Deming
3142015 Ajazajazhussaincom 54
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
ldquoWE CANNOT CHANGE THE HUMAN CONDITION BUThellipWE CAN CHANGE THE CONDITIONS UNDER WHICH HUMANS WORKrdquo JAMES REASON
Disregard to Malice
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 55
ldquohelliprecords not completed
contemporaneouslyrdquo
ldquohellipobserved analyst back-date logbooksrdquo
ldquohelliptrial injectionshelliprdquo
ldquohellipresults failing specifications are
retested until acceptable results are obtainedhelliprdquo
ldquohellipover-writing electronic raw datahelliprdquo
ldquohellipOOS not investigates per XYZ SOPrdquo
ldquohellipappropriate controls not establishedhelliprdquo
Each additional observation adds
reasons to confirm that this is very likely a system
with intentional lsquoholesrsquo in its
defenses
Preconditions
Rationalization amp Attitude
Pressure amp Incentive
Opportunity ndashlsquoholes in the QMSrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 56
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 57
Attitude towards the behavior
Subjective norm
Perceived behavioral
control
IntentionFuture
Behavior
usually found to predict behavioral intentions with a high degree of accuracy
intentions in combination with perceived behavioral control can account for a considerable proportion of variance in behavior
PastBehavior
Ajen I The theory of planned behavior ORGANIZATIONAL BEHAVIOR AND HUMAN DECISION PROCESSES 50 179-211 (1991)
Heparin tragedy 2007 and 2008
FDA reports 149 deaths with allergic or hypersensitivity symptoms during that period
bull Contaminated heparin from China
QC Testing
bull Initial testing failed to detect the contaminant
Pharmacovigilence
bull Signals in the pharmacovigilence systems responded slowly and
Eventually the severity of reactions associated made it likely that the contamination would be detected
bull too late for those who died or were injured
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 58
Congressman Shimkus When the drug safety system fails people get sick Some die
bull Some of these people are already very vulnerable and proving the cause of harm from impurities adulteration and counterfeits can be elusive
It is hard to detect harm
bull Certainly the companies are obligated to ensure a culture of quality and maintain vigilance as well This reflects a systems approach to safety
FDA inspectors look for a culture of quality at
manufacturing facilities
bull FDA policies led to the failure to inspect the Chinese plantThis system approach wasnt at
play here
bull While it doesnt deny the counterfeit source tries to say that counterfeits didnt cause the reaction as if the adulteration itself was no big deal Is this an acceptable mindset helliphelliphellip
This brings me to China and its quality culture or lack thereof
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 59
ONE HUNDRED TENTH CONGRESS SECOND SESSION APRIL 29 2008 Serial No 110-109
21 CFR PART 211 SUBPARTS -Deviations signal gaps in CoQ
bullGENERAL PROVISIONSA
bullORGANIZATION AND PERSONNELB
bullBUILDINGS AND FACILITIESC
bullEQUIPMENTD
bullCONTROL OF COMPONENTS AND DRUG PRODUCT CONTAINERS AND CLOSURESE
bullPRODUCTION AND PROCESS CONTROLSF
bullPACKAGING AND LABELING CONTROLG
bullHOLDING AND DISTRIBUTIONH
bullLABORATORY CONTROLSI
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 60
For example the combinationhellip
The Power of Habit Why We Do What We Do in Life and Business Charles Duhigg (2012)
bull Scientific methodology
bull Engineering Design
bull Plan-Do-Check-ActConsciously
bull Habits (work to get rid of bad ones)
bull Habits (work to cultivate good one)
bull Keystone habits (Safety Alcoa ALCOA of data integrity)
Subconsciously
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 61
CoQ How
bull What are the predictors of CoQCoQ Manifests by Design -
lsquoquality by designrsquo the foundation
bull 1 2 3When do people change their behaviors
bull A B C D (any body can dance)What makes a QMS effective
bull X Y ZWhen proactive compliance occurs
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 62
Going beyond rules pays
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 63
Human behavior Connecting the Dots With the Right Connectors
GXPs ndash rational behaviors
How proactive compliance is achieved X Y Z
Quality Management System
What makes a QMS reliable A B C D
Culture of Quality
Why people change their behavior 1 2 3
Human Behaviors Beyond GXPs
Predictors of Culture of Quality
Why What and How of Culture of Quality
9192014 copy Ajaz S Hussain | INSIGHT ADVICE amp SOLUTIONS LLC 64
Predictors of CoQ Act consciously in the interest of patients ndash when no one is looking
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 65
Only four attributes
actually predict a culture of
quality
Leadership Emphasis
Message Credibility
Peer Involvement
Employee Empower-ment
People will change their
behavior if they see the new behavior as
Normal
(1)
Rewarding
(2)
Easy
(3)
Dr W Edwards Demingrsquos - ldquoOut of the crisisrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 66
The journey requires leadership
with Profound Knowledge as a
guide
bull As leaders responsible for system change top management is most in need of profound knowledge
bull Quality is often determined in the boardroom
bull Problems arise when management reacts to common cause or chance variation as if it were special cause variation
bull Prediction based in theory provides a foundation for planning a course of action Plan ndash Do ndash Check ndash Act
bull The leader serves the people with clear vision and guidance to empower them To be empowered is to share ownership in the identity
bull Giving people a certain degree of control over their work fulfills the need for freedom and provides opportunity for taking joy in work
Profound Knowledge as a guide
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 67
Appreciation for a System
Theory of Knowledge
Knowledge about
Variation
Human Behavior -Psychology of Change
A
B
C
D+
Systems Approach for ErrorDeviation Management
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 68
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
Human error models and management J Reason BMJ 320 768ndash770 (2000)
D+
Culture of Error Management परबधनbull Error strain
bull Covering upFear of Errors
bull Anticipation
bull Risk takingAwareness
bull Development QbDRFT
bull Error detection Communication
bull Analyzing errors Correction
Mastery orientation
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 69
Dots amp Connections
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 70
CoQ
1
2
3
QMS
A
B
C
D
GXP Behaviors
X
Y
Z
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 71
Culture of Quality
Normal
Rewarding
Easy
QMS
System
Knowledge
Variation
Behavior
Behavior -GXPs
Fear Removed
Mastery
Awareness
EnvironmentLeadership Emphasis
Message Credibility
Peer Involvement
Employee Empowerment
Connect to CoQ
Connect to GXPs
A Framework and a Tool (for gap analysis)
ldquowe can be blind to the obvious and we are also blind to our blindnessrdquo
Daniel Kahneman Thinking Fast and Slow
3142015 Ajazajazhussaincom 45
httpwebmiteduperscipeopleadelsoncheckershadow_proofhtml
3122015 Ajaz S Hussain PhD 46
1938 The Federal Food Drug and Cosmetic (FDC)
bull 1937 Elixir of Sulfanilamide
1962 Kefauver-Harris Drug Amendments
bull 1962 Thalidomide
bull 1960 Color Additive Amendment
bull 1958 Food Additives Amendment GRAS
bull 1960 Color Additive Amendment
bull 1958 Food Additives Amendment GRAS
1992 Generic Drug Enforcement Act
bull1989 L-Tryptophan
bull 1989 Generic Drug Scandal
bull 1988 Food and Drug Administration Act
bull 1984 Fines Enhancement Laws Drug Price Competition and Patent Term Restoration Act
2012 Food and Drug Administration Safety and Innovation Act (FDASIA)
bull 2007 Heparin Disaster
2013 Pandemic and All-Hazards Preparedness Reauthorization Act (PAHPRA) Drug Quality and Security Act
bull 2012 The Deadly Meningitis Outbreak
Past 70 years 1937 ndash 2007 The diethylene glycol (DEG) narrative
3122015 Ajaz S Hussain PhD 47
0
5
10
15
20
25
30
35
Yea
rs
DEG Years since the previous incident
0
50
100
150
200
250
300
350
Number of Reported Deaths
1937
Eli
xir
of
Sulf
anil
amid
e
2007T
ootp
aste
conta
min
atio
n
0 70 years 0 70 years
Frequent reports
Mumbai Mumbai
Data from Excipient Fest Janeen Skutnik Chair ndashIPECAmericas 2009
Past 70+ years DEG contamination or economically motivated adulteration
3122015 Ajaz S Hussain PhD 48
Reported cases underestimate the real tragedy rapid intervention may not occur
Epidemic of Pediatric Deaths From Acute Renal Failure Caused by
Diethylene Glycol Poisoning JAMA 1998279(15)1175-1180
doi101001jama279151175
Month of hospital admission for children with
acute renal failure Haiti
October 1995-October 1996
Diethylene glycol poisoning in Gurgaon India 1998Bulletin of the World Health Organization 2001 79 88ndash95
We report a second episode of poisoning occurring in 1998 in
India as a result of children ingesting diethylene glycol at
least 33 children are known to have died
At the beginning of the investigation we never imagined that
contaminated medicine was causing acute renal failure in
children
A brand of cough expectorant manufactured by a local
pharmaceutical company was found by the Central Drugs
Laboratory Calcutta to contain 175 (vv) diethylene
glycol
The district and state drug controller had tested many
samples using thin layer chromatography before a sample of
medicine tested positive for diethylene glycol at the Central
Drugs Laboratory None of the earlier samples was found to
be contaminated
3122015 Ajaz S Hussain PhD 49
Guidance for Industry Testing of
Glycerin for Diethylene Glycol
CDER May 2007 Compliance
1 Manufacturers did not perform full
identity testing on the glycerin raw
material including tests to quantify
the amount of DEG
2 Relied on the certificate of analysis
(COA)
3 The origin of the glycerin was not
easily apparent from the COA
4 The COA was often a copy of a COA
on the letterhead of the distributor
5 The chain of custody or distribution
history of the glycerin was also not
readily known
USP Glycerin Monograph
Type of Posting Revision Bulletin
Posting Date 04ndashFebndash2009
Official Date 01ndashMayndash2009
Because of the serious hazards
associated withhellip and in response to
recommendations set forth in the
FDA Guidance for Industry Testing
of Glycerin for Diethylene Glycol
published in May 2007 USP has
revised the USP Glycerin monograph
Because diethylene glycol and
ethylene glycol are considered
unacceptable toxic substances the
testing of USP Glycerin should
demonstrate the absence of these
substances
April 2007 FDA request to
USP to revise the Glycerin
monographrsquos
IDENTIFICATION section
Revision includes adding ndash
Identification test B LIMIT OF
DIETHYLENE GLYCOL AND
ETHYLENE GLYCOL to detect
and quantify DEGEG in Glycerin
minus Is no longer part of the impurity
testing
ldquoLimit of DEG and Related
Compoundsrdquo minus Introduces a
capillary gas-chromatographic
(GC) method with flame ionization
detection (FID) minus Limit of NMT
010 each for diethylene glycol
and ethylene glycol is found
70+ years to get here how difficult will it be to change habits such as lsquoblind reliance of COArsquo
3122015 Ajaz S Hussain PhD 50
Personality and Habitual Frame Biases
Myers Brigs ENTJ (first tested at FDA)
S
TF
Expanded frame
future
possibilities
objective lsquocause
and effectrsquo
Expanded frame
future
possibilities
people and
relationships
Narrow frame
the present
individuals and
relationships
Narrow frame
the present
objective
cause and
effect
N
Based on Stanford Webinar - How to Overcome the Top 3 MegaBiases in Decision-Making
Stanford Universityrsquos Strategic Decision and Risk Management certificate program
From Mapping a Managers Brain on Incentives
Social
influences
Relative
thinking
UncertaintyComplexity
By Design Intention to act consciously
bull In the interest of patients and to continually improve this ability bull To provide a healing touch ndash one life at a time in what we do and how we
do it
1292014 Ajazajazhussaincom 51
Consciously
Scientific methodology
Engineering Design
Plan-Do-Check-Act
Subconsciously
Habits (work to get rid of bad ones)
Habits (work to cultivate good one)
Keystone habits (Safety Alcoa ALCOA of data integrity)
The Power of Habit Why We Do What We Do in Life and Business Charles Duhigg (2012)
httpwwwslideshareneta2zpharmscipharmaceutical-culture-of-quality
What does it take to come out of the cGMP crisis
Persuasive demonstration of
(1) Ability to face facts
(2) Legal amp regulatory requirements
3) Systems approach to quality
4) Changing behavior amp culture
What is often missed or is unconvincing is how you will strengthen culture of quality
ldquoLet one who wants to move and convince others first be convinced and moved themselvesrdquo Thomas Carlyle
Signals that question the competence motivation andor integrity of company personnel
Do not defend the plainly indefensible it adds further serious credibility costs
3142015 Ajazajazhussaincom 52
Quality is everyones responsibility
Lack of knowledge that is
the problem
If you do not know how to ask the
right question you discover nothing
If you cant describe what you
are doing as a process you dont know what youre
doing
Rational behavior requires theory
Reactive behavior requires only reflex
action
Whenever there is fear you will get wrong figures
3142015 Ajazajazhussaincom 53
Selected quotes W Edwards Deming
3142015 Ajazajazhussaincom 54
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
ldquoWE CANNOT CHANGE THE HUMAN CONDITION BUThellipWE CAN CHANGE THE CONDITIONS UNDER WHICH HUMANS WORKrdquo JAMES REASON
Disregard to Malice
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 55
ldquohelliprecords not completed
contemporaneouslyrdquo
ldquohellipobserved analyst back-date logbooksrdquo
ldquohelliptrial injectionshelliprdquo
ldquohellipresults failing specifications are
retested until acceptable results are obtainedhelliprdquo
ldquohellipover-writing electronic raw datahelliprdquo
ldquohellipOOS not investigates per XYZ SOPrdquo
ldquohellipappropriate controls not establishedhelliprdquo
Each additional observation adds
reasons to confirm that this is very likely a system
with intentional lsquoholesrsquo in its
defenses
Preconditions
Rationalization amp Attitude
Pressure amp Incentive
Opportunity ndashlsquoholes in the QMSrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 56
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 57
Attitude towards the behavior
Subjective norm
Perceived behavioral
control
IntentionFuture
Behavior
usually found to predict behavioral intentions with a high degree of accuracy
intentions in combination with perceived behavioral control can account for a considerable proportion of variance in behavior
PastBehavior
Ajen I The theory of planned behavior ORGANIZATIONAL BEHAVIOR AND HUMAN DECISION PROCESSES 50 179-211 (1991)
Heparin tragedy 2007 and 2008
FDA reports 149 deaths with allergic or hypersensitivity symptoms during that period
bull Contaminated heparin from China
QC Testing
bull Initial testing failed to detect the contaminant
Pharmacovigilence
bull Signals in the pharmacovigilence systems responded slowly and
Eventually the severity of reactions associated made it likely that the contamination would be detected
bull too late for those who died or were injured
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 58
Congressman Shimkus When the drug safety system fails people get sick Some die
bull Some of these people are already very vulnerable and proving the cause of harm from impurities adulteration and counterfeits can be elusive
It is hard to detect harm
bull Certainly the companies are obligated to ensure a culture of quality and maintain vigilance as well This reflects a systems approach to safety
FDA inspectors look for a culture of quality at
manufacturing facilities
bull FDA policies led to the failure to inspect the Chinese plantThis system approach wasnt at
play here
bull While it doesnt deny the counterfeit source tries to say that counterfeits didnt cause the reaction as if the adulteration itself was no big deal Is this an acceptable mindset helliphelliphellip
This brings me to China and its quality culture or lack thereof
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 59
ONE HUNDRED TENTH CONGRESS SECOND SESSION APRIL 29 2008 Serial No 110-109
21 CFR PART 211 SUBPARTS -Deviations signal gaps in CoQ
bullGENERAL PROVISIONSA
bullORGANIZATION AND PERSONNELB
bullBUILDINGS AND FACILITIESC
bullEQUIPMENTD
bullCONTROL OF COMPONENTS AND DRUG PRODUCT CONTAINERS AND CLOSURESE
bullPRODUCTION AND PROCESS CONTROLSF
bullPACKAGING AND LABELING CONTROLG
bullHOLDING AND DISTRIBUTIONH
bullLABORATORY CONTROLSI
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 60
For example the combinationhellip
The Power of Habit Why We Do What We Do in Life and Business Charles Duhigg (2012)
bull Scientific methodology
bull Engineering Design
bull Plan-Do-Check-ActConsciously
bull Habits (work to get rid of bad ones)
bull Habits (work to cultivate good one)
bull Keystone habits (Safety Alcoa ALCOA of data integrity)
Subconsciously
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 61
CoQ How
bull What are the predictors of CoQCoQ Manifests by Design -
lsquoquality by designrsquo the foundation
bull 1 2 3When do people change their behaviors
bull A B C D (any body can dance)What makes a QMS effective
bull X Y ZWhen proactive compliance occurs
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 62
Going beyond rules pays
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 63
Human behavior Connecting the Dots With the Right Connectors
GXPs ndash rational behaviors
How proactive compliance is achieved X Y Z
Quality Management System
What makes a QMS reliable A B C D
Culture of Quality
Why people change their behavior 1 2 3
Human Behaviors Beyond GXPs
Predictors of Culture of Quality
Why What and How of Culture of Quality
9192014 copy Ajaz S Hussain | INSIGHT ADVICE amp SOLUTIONS LLC 64
Predictors of CoQ Act consciously in the interest of patients ndash when no one is looking
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 65
Only four attributes
actually predict a culture of
quality
Leadership Emphasis
Message Credibility
Peer Involvement
Employee Empower-ment
People will change their
behavior if they see the new behavior as
Normal
(1)
Rewarding
(2)
Easy
(3)
Dr W Edwards Demingrsquos - ldquoOut of the crisisrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 66
The journey requires leadership
with Profound Knowledge as a
guide
bull As leaders responsible for system change top management is most in need of profound knowledge
bull Quality is often determined in the boardroom
bull Problems arise when management reacts to common cause or chance variation as if it were special cause variation
bull Prediction based in theory provides a foundation for planning a course of action Plan ndash Do ndash Check ndash Act
bull The leader serves the people with clear vision and guidance to empower them To be empowered is to share ownership in the identity
bull Giving people a certain degree of control over their work fulfills the need for freedom and provides opportunity for taking joy in work
Profound Knowledge as a guide
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 67
Appreciation for a System
Theory of Knowledge
Knowledge about
Variation
Human Behavior -Psychology of Change
A
B
C
D+
Systems Approach for ErrorDeviation Management
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 68
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
Human error models and management J Reason BMJ 320 768ndash770 (2000)
D+
Culture of Error Management परबधनbull Error strain
bull Covering upFear of Errors
bull Anticipation
bull Risk takingAwareness
bull Development QbDRFT
bull Error detection Communication
bull Analyzing errors Correction
Mastery orientation
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 69
Dots amp Connections
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 70
CoQ
1
2
3
QMS
A
B
C
D
GXP Behaviors
X
Y
Z
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 71
Culture of Quality
Normal
Rewarding
Easy
QMS
System
Knowledge
Variation
Behavior
Behavior -GXPs
Fear Removed
Mastery
Awareness
EnvironmentLeadership Emphasis
Message Credibility
Peer Involvement
Employee Empowerment
Connect to CoQ
Connect to GXPs
A Framework and a Tool (for gap analysis)
3122015 Ajaz S Hussain PhD 46
1938 The Federal Food Drug and Cosmetic (FDC)
bull 1937 Elixir of Sulfanilamide
1962 Kefauver-Harris Drug Amendments
bull 1962 Thalidomide
bull 1960 Color Additive Amendment
bull 1958 Food Additives Amendment GRAS
bull 1960 Color Additive Amendment
bull 1958 Food Additives Amendment GRAS
1992 Generic Drug Enforcement Act
bull1989 L-Tryptophan
bull 1989 Generic Drug Scandal
bull 1988 Food and Drug Administration Act
bull 1984 Fines Enhancement Laws Drug Price Competition and Patent Term Restoration Act
2012 Food and Drug Administration Safety and Innovation Act (FDASIA)
bull 2007 Heparin Disaster
2013 Pandemic and All-Hazards Preparedness Reauthorization Act (PAHPRA) Drug Quality and Security Act
bull 2012 The Deadly Meningitis Outbreak
Past 70 years 1937 ndash 2007 The diethylene glycol (DEG) narrative
3122015 Ajaz S Hussain PhD 47
0
5
10
15
20
25
30
35
Yea
rs
DEG Years since the previous incident
0
50
100
150
200
250
300
350
Number of Reported Deaths
1937
Eli
xir
of
Sulf
anil
amid
e
2007T
ootp
aste
conta
min
atio
n
0 70 years 0 70 years
Frequent reports
Mumbai Mumbai
Data from Excipient Fest Janeen Skutnik Chair ndashIPECAmericas 2009
Past 70+ years DEG contamination or economically motivated adulteration
3122015 Ajaz S Hussain PhD 48
Reported cases underestimate the real tragedy rapid intervention may not occur
Epidemic of Pediatric Deaths From Acute Renal Failure Caused by
Diethylene Glycol Poisoning JAMA 1998279(15)1175-1180
doi101001jama279151175
Month of hospital admission for children with
acute renal failure Haiti
October 1995-October 1996
Diethylene glycol poisoning in Gurgaon India 1998Bulletin of the World Health Organization 2001 79 88ndash95
We report a second episode of poisoning occurring in 1998 in
India as a result of children ingesting diethylene glycol at
least 33 children are known to have died
At the beginning of the investigation we never imagined that
contaminated medicine was causing acute renal failure in
children
A brand of cough expectorant manufactured by a local
pharmaceutical company was found by the Central Drugs
Laboratory Calcutta to contain 175 (vv) diethylene
glycol
The district and state drug controller had tested many
samples using thin layer chromatography before a sample of
medicine tested positive for diethylene glycol at the Central
Drugs Laboratory None of the earlier samples was found to
be contaminated
3122015 Ajaz S Hussain PhD 49
Guidance for Industry Testing of
Glycerin for Diethylene Glycol
CDER May 2007 Compliance
1 Manufacturers did not perform full
identity testing on the glycerin raw
material including tests to quantify
the amount of DEG
2 Relied on the certificate of analysis
(COA)
3 The origin of the glycerin was not
easily apparent from the COA
4 The COA was often a copy of a COA
on the letterhead of the distributor
5 The chain of custody or distribution
history of the glycerin was also not
readily known
USP Glycerin Monograph
Type of Posting Revision Bulletin
Posting Date 04ndashFebndash2009
Official Date 01ndashMayndash2009
Because of the serious hazards
associated withhellip and in response to
recommendations set forth in the
FDA Guidance for Industry Testing
of Glycerin for Diethylene Glycol
published in May 2007 USP has
revised the USP Glycerin monograph
Because diethylene glycol and
ethylene glycol are considered
unacceptable toxic substances the
testing of USP Glycerin should
demonstrate the absence of these
substances
April 2007 FDA request to
USP to revise the Glycerin
monographrsquos
IDENTIFICATION section
Revision includes adding ndash
Identification test B LIMIT OF
DIETHYLENE GLYCOL AND
ETHYLENE GLYCOL to detect
and quantify DEGEG in Glycerin
minus Is no longer part of the impurity
testing
ldquoLimit of DEG and Related
Compoundsrdquo minus Introduces a
capillary gas-chromatographic
(GC) method with flame ionization
detection (FID) minus Limit of NMT
010 each for diethylene glycol
and ethylene glycol is found
70+ years to get here how difficult will it be to change habits such as lsquoblind reliance of COArsquo
3122015 Ajaz S Hussain PhD 50
Personality and Habitual Frame Biases
Myers Brigs ENTJ (first tested at FDA)
S
TF
Expanded frame
future
possibilities
objective lsquocause
and effectrsquo
Expanded frame
future
possibilities
people and
relationships
Narrow frame
the present
individuals and
relationships
Narrow frame
the present
objective
cause and
effect
N
Based on Stanford Webinar - How to Overcome the Top 3 MegaBiases in Decision-Making
Stanford Universityrsquos Strategic Decision and Risk Management certificate program
From Mapping a Managers Brain on Incentives
Social
influences
Relative
thinking
UncertaintyComplexity
By Design Intention to act consciously
bull In the interest of patients and to continually improve this ability bull To provide a healing touch ndash one life at a time in what we do and how we
do it
1292014 Ajazajazhussaincom 51
Consciously
Scientific methodology
Engineering Design
Plan-Do-Check-Act
Subconsciously
Habits (work to get rid of bad ones)
Habits (work to cultivate good one)
Keystone habits (Safety Alcoa ALCOA of data integrity)
The Power of Habit Why We Do What We Do in Life and Business Charles Duhigg (2012)
httpwwwslideshareneta2zpharmscipharmaceutical-culture-of-quality
What does it take to come out of the cGMP crisis
Persuasive demonstration of
(1) Ability to face facts
(2) Legal amp regulatory requirements
3) Systems approach to quality
4) Changing behavior amp culture
What is often missed or is unconvincing is how you will strengthen culture of quality
ldquoLet one who wants to move and convince others first be convinced and moved themselvesrdquo Thomas Carlyle
Signals that question the competence motivation andor integrity of company personnel
Do not defend the plainly indefensible it adds further serious credibility costs
3142015 Ajazajazhussaincom 52
Quality is everyones responsibility
Lack of knowledge that is
the problem
If you do not know how to ask the
right question you discover nothing
If you cant describe what you
are doing as a process you dont know what youre
doing
Rational behavior requires theory
Reactive behavior requires only reflex
action
Whenever there is fear you will get wrong figures
3142015 Ajazajazhussaincom 53
Selected quotes W Edwards Deming
3142015 Ajazajazhussaincom 54
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
ldquoWE CANNOT CHANGE THE HUMAN CONDITION BUThellipWE CAN CHANGE THE CONDITIONS UNDER WHICH HUMANS WORKrdquo JAMES REASON
Disregard to Malice
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 55
ldquohelliprecords not completed
contemporaneouslyrdquo
ldquohellipobserved analyst back-date logbooksrdquo
ldquohelliptrial injectionshelliprdquo
ldquohellipresults failing specifications are
retested until acceptable results are obtainedhelliprdquo
ldquohellipover-writing electronic raw datahelliprdquo
ldquohellipOOS not investigates per XYZ SOPrdquo
ldquohellipappropriate controls not establishedhelliprdquo
Each additional observation adds
reasons to confirm that this is very likely a system
with intentional lsquoholesrsquo in its
defenses
Preconditions
Rationalization amp Attitude
Pressure amp Incentive
Opportunity ndashlsquoholes in the QMSrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 56
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 57
Attitude towards the behavior
Subjective norm
Perceived behavioral
control
IntentionFuture
Behavior
usually found to predict behavioral intentions with a high degree of accuracy
intentions in combination with perceived behavioral control can account for a considerable proportion of variance in behavior
PastBehavior
Ajen I The theory of planned behavior ORGANIZATIONAL BEHAVIOR AND HUMAN DECISION PROCESSES 50 179-211 (1991)
Heparin tragedy 2007 and 2008
FDA reports 149 deaths with allergic or hypersensitivity symptoms during that period
bull Contaminated heparin from China
QC Testing
bull Initial testing failed to detect the contaminant
Pharmacovigilence
bull Signals in the pharmacovigilence systems responded slowly and
Eventually the severity of reactions associated made it likely that the contamination would be detected
bull too late for those who died or were injured
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 58
Congressman Shimkus When the drug safety system fails people get sick Some die
bull Some of these people are already very vulnerable and proving the cause of harm from impurities adulteration and counterfeits can be elusive
It is hard to detect harm
bull Certainly the companies are obligated to ensure a culture of quality and maintain vigilance as well This reflects a systems approach to safety
FDA inspectors look for a culture of quality at
manufacturing facilities
bull FDA policies led to the failure to inspect the Chinese plantThis system approach wasnt at
play here
bull While it doesnt deny the counterfeit source tries to say that counterfeits didnt cause the reaction as if the adulteration itself was no big deal Is this an acceptable mindset helliphelliphellip
This brings me to China and its quality culture or lack thereof
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 59
ONE HUNDRED TENTH CONGRESS SECOND SESSION APRIL 29 2008 Serial No 110-109
21 CFR PART 211 SUBPARTS -Deviations signal gaps in CoQ
bullGENERAL PROVISIONSA
bullORGANIZATION AND PERSONNELB
bullBUILDINGS AND FACILITIESC
bullEQUIPMENTD
bullCONTROL OF COMPONENTS AND DRUG PRODUCT CONTAINERS AND CLOSURESE
bullPRODUCTION AND PROCESS CONTROLSF
bullPACKAGING AND LABELING CONTROLG
bullHOLDING AND DISTRIBUTIONH
bullLABORATORY CONTROLSI
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 60
For example the combinationhellip
The Power of Habit Why We Do What We Do in Life and Business Charles Duhigg (2012)
bull Scientific methodology
bull Engineering Design
bull Plan-Do-Check-ActConsciously
bull Habits (work to get rid of bad ones)
bull Habits (work to cultivate good one)
bull Keystone habits (Safety Alcoa ALCOA of data integrity)
Subconsciously
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 61
CoQ How
bull What are the predictors of CoQCoQ Manifests by Design -
lsquoquality by designrsquo the foundation
bull 1 2 3When do people change their behaviors
bull A B C D (any body can dance)What makes a QMS effective
bull X Y ZWhen proactive compliance occurs
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 62
Going beyond rules pays
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 63
Human behavior Connecting the Dots With the Right Connectors
GXPs ndash rational behaviors
How proactive compliance is achieved X Y Z
Quality Management System
What makes a QMS reliable A B C D
Culture of Quality
Why people change their behavior 1 2 3
Human Behaviors Beyond GXPs
Predictors of Culture of Quality
Why What and How of Culture of Quality
9192014 copy Ajaz S Hussain | INSIGHT ADVICE amp SOLUTIONS LLC 64
Predictors of CoQ Act consciously in the interest of patients ndash when no one is looking
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 65
Only four attributes
actually predict a culture of
quality
Leadership Emphasis
Message Credibility
Peer Involvement
Employee Empower-ment
People will change their
behavior if they see the new behavior as
Normal
(1)
Rewarding
(2)
Easy
(3)
Dr W Edwards Demingrsquos - ldquoOut of the crisisrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 66
The journey requires leadership
with Profound Knowledge as a
guide
bull As leaders responsible for system change top management is most in need of profound knowledge
bull Quality is often determined in the boardroom
bull Problems arise when management reacts to common cause or chance variation as if it were special cause variation
bull Prediction based in theory provides a foundation for planning a course of action Plan ndash Do ndash Check ndash Act
bull The leader serves the people with clear vision and guidance to empower them To be empowered is to share ownership in the identity
bull Giving people a certain degree of control over their work fulfills the need for freedom and provides opportunity for taking joy in work
Profound Knowledge as a guide
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 67
Appreciation for a System
Theory of Knowledge
Knowledge about
Variation
Human Behavior -Psychology of Change
A
B
C
D+
Systems Approach for ErrorDeviation Management
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 68
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
Human error models and management J Reason BMJ 320 768ndash770 (2000)
D+
Culture of Error Management परबधनbull Error strain
bull Covering upFear of Errors
bull Anticipation
bull Risk takingAwareness
bull Development QbDRFT
bull Error detection Communication
bull Analyzing errors Correction
Mastery orientation
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 69
Dots amp Connections
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 70
CoQ
1
2
3
QMS
A
B
C
D
GXP Behaviors
X
Y
Z
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 71
Culture of Quality
Normal
Rewarding
Easy
QMS
System
Knowledge
Variation
Behavior
Behavior -GXPs
Fear Removed
Mastery
Awareness
EnvironmentLeadership Emphasis
Message Credibility
Peer Involvement
Employee Empowerment
Connect to CoQ
Connect to GXPs
A Framework and a Tool (for gap analysis)
3122015 Ajaz S Hussain PhD 47
0
5
10
15
20
25
30
35
Yea
rs
DEG Years since the previous incident
0
50
100
150
200
250
300
350
Number of Reported Deaths
1937
Eli
xir
of
Sulf
anil
amid
e
2007T
ootp
aste
conta
min
atio
n
0 70 years 0 70 years
Frequent reports
Mumbai Mumbai
Data from Excipient Fest Janeen Skutnik Chair ndashIPECAmericas 2009
Past 70+ years DEG contamination or economically motivated adulteration
3122015 Ajaz S Hussain PhD 48
Reported cases underestimate the real tragedy rapid intervention may not occur
Epidemic of Pediatric Deaths From Acute Renal Failure Caused by
Diethylene Glycol Poisoning JAMA 1998279(15)1175-1180
doi101001jama279151175
Month of hospital admission for children with
acute renal failure Haiti
October 1995-October 1996
Diethylene glycol poisoning in Gurgaon India 1998Bulletin of the World Health Organization 2001 79 88ndash95
We report a second episode of poisoning occurring in 1998 in
India as a result of children ingesting diethylene glycol at
least 33 children are known to have died
At the beginning of the investigation we never imagined that
contaminated medicine was causing acute renal failure in
children
A brand of cough expectorant manufactured by a local
pharmaceutical company was found by the Central Drugs
Laboratory Calcutta to contain 175 (vv) diethylene
glycol
The district and state drug controller had tested many
samples using thin layer chromatography before a sample of
medicine tested positive for diethylene glycol at the Central
Drugs Laboratory None of the earlier samples was found to
be contaminated
3122015 Ajaz S Hussain PhD 49
Guidance for Industry Testing of
Glycerin for Diethylene Glycol
CDER May 2007 Compliance
1 Manufacturers did not perform full
identity testing on the glycerin raw
material including tests to quantify
the amount of DEG
2 Relied on the certificate of analysis
(COA)
3 The origin of the glycerin was not
easily apparent from the COA
4 The COA was often a copy of a COA
on the letterhead of the distributor
5 The chain of custody or distribution
history of the glycerin was also not
readily known
USP Glycerin Monograph
Type of Posting Revision Bulletin
Posting Date 04ndashFebndash2009
Official Date 01ndashMayndash2009
Because of the serious hazards
associated withhellip and in response to
recommendations set forth in the
FDA Guidance for Industry Testing
of Glycerin for Diethylene Glycol
published in May 2007 USP has
revised the USP Glycerin monograph
Because diethylene glycol and
ethylene glycol are considered
unacceptable toxic substances the
testing of USP Glycerin should
demonstrate the absence of these
substances
April 2007 FDA request to
USP to revise the Glycerin
monographrsquos
IDENTIFICATION section
Revision includes adding ndash
Identification test B LIMIT OF
DIETHYLENE GLYCOL AND
ETHYLENE GLYCOL to detect
and quantify DEGEG in Glycerin
minus Is no longer part of the impurity
testing
ldquoLimit of DEG and Related
Compoundsrdquo minus Introduces a
capillary gas-chromatographic
(GC) method with flame ionization
detection (FID) minus Limit of NMT
010 each for diethylene glycol
and ethylene glycol is found
70+ years to get here how difficult will it be to change habits such as lsquoblind reliance of COArsquo
3122015 Ajaz S Hussain PhD 50
Personality and Habitual Frame Biases
Myers Brigs ENTJ (first tested at FDA)
S
TF
Expanded frame
future
possibilities
objective lsquocause
and effectrsquo
Expanded frame
future
possibilities
people and
relationships
Narrow frame
the present
individuals and
relationships
Narrow frame
the present
objective
cause and
effect
N
Based on Stanford Webinar - How to Overcome the Top 3 MegaBiases in Decision-Making
Stanford Universityrsquos Strategic Decision and Risk Management certificate program
From Mapping a Managers Brain on Incentives
Social
influences
Relative
thinking
UncertaintyComplexity
By Design Intention to act consciously
bull In the interest of patients and to continually improve this ability bull To provide a healing touch ndash one life at a time in what we do and how we
do it
1292014 Ajazajazhussaincom 51
Consciously
Scientific methodology
Engineering Design
Plan-Do-Check-Act
Subconsciously
Habits (work to get rid of bad ones)
Habits (work to cultivate good one)
Keystone habits (Safety Alcoa ALCOA of data integrity)
The Power of Habit Why We Do What We Do in Life and Business Charles Duhigg (2012)
httpwwwslideshareneta2zpharmscipharmaceutical-culture-of-quality
What does it take to come out of the cGMP crisis
Persuasive demonstration of
(1) Ability to face facts
(2) Legal amp regulatory requirements
3) Systems approach to quality
4) Changing behavior amp culture
What is often missed or is unconvincing is how you will strengthen culture of quality
ldquoLet one who wants to move and convince others first be convinced and moved themselvesrdquo Thomas Carlyle
Signals that question the competence motivation andor integrity of company personnel
Do not defend the plainly indefensible it adds further serious credibility costs
3142015 Ajazajazhussaincom 52
Quality is everyones responsibility
Lack of knowledge that is
the problem
If you do not know how to ask the
right question you discover nothing
If you cant describe what you
are doing as a process you dont know what youre
doing
Rational behavior requires theory
Reactive behavior requires only reflex
action
Whenever there is fear you will get wrong figures
3142015 Ajazajazhussaincom 53
Selected quotes W Edwards Deming
3142015 Ajazajazhussaincom 54
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
ldquoWE CANNOT CHANGE THE HUMAN CONDITION BUThellipWE CAN CHANGE THE CONDITIONS UNDER WHICH HUMANS WORKrdquo JAMES REASON
Disregard to Malice
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 55
ldquohelliprecords not completed
contemporaneouslyrdquo
ldquohellipobserved analyst back-date logbooksrdquo
ldquohelliptrial injectionshelliprdquo
ldquohellipresults failing specifications are
retested until acceptable results are obtainedhelliprdquo
ldquohellipover-writing electronic raw datahelliprdquo
ldquohellipOOS not investigates per XYZ SOPrdquo
ldquohellipappropriate controls not establishedhelliprdquo
Each additional observation adds
reasons to confirm that this is very likely a system
with intentional lsquoholesrsquo in its
defenses
Preconditions
Rationalization amp Attitude
Pressure amp Incentive
Opportunity ndashlsquoholes in the QMSrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 56
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 57
Attitude towards the behavior
Subjective norm
Perceived behavioral
control
IntentionFuture
Behavior
usually found to predict behavioral intentions with a high degree of accuracy
intentions in combination with perceived behavioral control can account for a considerable proportion of variance in behavior
PastBehavior
Ajen I The theory of planned behavior ORGANIZATIONAL BEHAVIOR AND HUMAN DECISION PROCESSES 50 179-211 (1991)
Heparin tragedy 2007 and 2008
FDA reports 149 deaths with allergic or hypersensitivity symptoms during that period
bull Contaminated heparin from China
QC Testing
bull Initial testing failed to detect the contaminant
Pharmacovigilence
bull Signals in the pharmacovigilence systems responded slowly and
Eventually the severity of reactions associated made it likely that the contamination would be detected
bull too late for those who died or were injured
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 58
Congressman Shimkus When the drug safety system fails people get sick Some die
bull Some of these people are already very vulnerable and proving the cause of harm from impurities adulteration and counterfeits can be elusive
It is hard to detect harm
bull Certainly the companies are obligated to ensure a culture of quality and maintain vigilance as well This reflects a systems approach to safety
FDA inspectors look for a culture of quality at
manufacturing facilities
bull FDA policies led to the failure to inspect the Chinese plantThis system approach wasnt at
play here
bull While it doesnt deny the counterfeit source tries to say that counterfeits didnt cause the reaction as if the adulteration itself was no big deal Is this an acceptable mindset helliphelliphellip
This brings me to China and its quality culture or lack thereof
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 59
ONE HUNDRED TENTH CONGRESS SECOND SESSION APRIL 29 2008 Serial No 110-109
21 CFR PART 211 SUBPARTS -Deviations signal gaps in CoQ
bullGENERAL PROVISIONSA
bullORGANIZATION AND PERSONNELB
bullBUILDINGS AND FACILITIESC
bullEQUIPMENTD
bullCONTROL OF COMPONENTS AND DRUG PRODUCT CONTAINERS AND CLOSURESE
bullPRODUCTION AND PROCESS CONTROLSF
bullPACKAGING AND LABELING CONTROLG
bullHOLDING AND DISTRIBUTIONH
bullLABORATORY CONTROLSI
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 60
For example the combinationhellip
The Power of Habit Why We Do What We Do in Life and Business Charles Duhigg (2012)
bull Scientific methodology
bull Engineering Design
bull Plan-Do-Check-ActConsciously
bull Habits (work to get rid of bad ones)
bull Habits (work to cultivate good one)
bull Keystone habits (Safety Alcoa ALCOA of data integrity)
Subconsciously
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 61
CoQ How
bull What are the predictors of CoQCoQ Manifests by Design -
lsquoquality by designrsquo the foundation
bull 1 2 3When do people change their behaviors
bull A B C D (any body can dance)What makes a QMS effective
bull X Y ZWhen proactive compliance occurs
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 62
Going beyond rules pays
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 63
Human behavior Connecting the Dots With the Right Connectors
GXPs ndash rational behaviors
How proactive compliance is achieved X Y Z
Quality Management System
What makes a QMS reliable A B C D
Culture of Quality
Why people change their behavior 1 2 3
Human Behaviors Beyond GXPs
Predictors of Culture of Quality
Why What and How of Culture of Quality
9192014 copy Ajaz S Hussain | INSIGHT ADVICE amp SOLUTIONS LLC 64
Predictors of CoQ Act consciously in the interest of patients ndash when no one is looking
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 65
Only four attributes
actually predict a culture of
quality
Leadership Emphasis
Message Credibility
Peer Involvement
Employee Empower-ment
People will change their
behavior if they see the new behavior as
Normal
(1)
Rewarding
(2)
Easy
(3)
Dr W Edwards Demingrsquos - ldquoOut of the crisisrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 66
The journey requires leadership
with Profound Knowledge as a
guide
bull As leaders responsible for system change top management is most in need of profound knowledge
bull Quality is often determined in the boardroom
bull Problems arise when management reacts to common cause or chance variation as if it were special cause variation
bull Prediction based in theory provides a foundation for planning a course of action Plan ndash Do ndash Check ndash Act
bull The leader serves the people with clear vision and guidance to empower them To be empowered is to share ownership in the identity
bull Giving people a certain degree of control over their work fulfills the need for freedom and provides opportunity for taking joy in work
Profound Knowledge as a guide
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 67
Appreciation for a System
Theory of Knowledge
Knowledge about
Variation
Human Behavior -Psychology of Change
A
B
C
D+
Systems Approach for ErrorDeviation Management
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 68
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
Human error models and management J Reason BMJ 320 768ndash770 (2000)
D+
Culture of Error Management परबधनbull Error strain
bull Covering upFear of Errors
bull Anticipation
bull Risk takingAwareness
bull Development QbDRFT
bull Error detection Communication
bull Analyzing errors Correction
Mastery orientation
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 69
Dots amp Connections
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 70
CoQ
1
2
3
QMS
A
B
C
D
GXP Behaviors
X
Y
Z
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 71
Culture of Quality
Normal
Rewarding
Easy
QMS
System
Knowledge
Variation
Behavior
Behavior -GXPs
Fear Removed
Mastery
Awareness
EnvironmentLeadership Emphasis
Message Credibility
Peer Involvement
Employee Empowerment
Connect to CoQ
Connect to GXPs
A Framework and a Tool (for gap analysis)
3122015 Ajaz S Hussain PhD 48
Reported cases underestimate the real tragedy rapid intervention may not occur
Epidemic of Pediatric Deaths From Acute Renal Failure Caused by
Diethylene Glycol Poisoning JAMA 1998279(15)1175-1180
doi101001jama279151175
Month of hospital admission for children with
acute renal failure Haiti
October 1995-October 1996
Diethylene glycol poisoning in Gurgaon India 1998Bulletin of the World Health Organization 2001 79 88ndash95
We report a second episode of poisoning occurring in 1998 in
India as a result of children ingesting diethylene glycol at
least 33 children are known to have died
At the beginning of the investigation we never imagined that
contaminated medicine was causing acute renal failure in
children
A brand of cough expectorant manufactured by a local
pharmaceutical company was found by the Central Drugs
Laboratory Calcutta to contain 175 (vv) diethylene
glycol
The district and state drug controller had tested many
samples using thin layer chromatography before a sample of
medicine tested positive for diethylene glycol at the Central
Drugs Laboratory None of the earlier samples was found to
be contaminated
3122015 Ajaz S Hussain PhD 49
Guidance for Industry Testing of
Glycerin for Diethylene Glycol
CDER May 2007 Compliance
1 Manufacturers did not perform full
identity testing on the glycerin raw
material including tests to quantify
the amount of DEG
2 Relied on the certificate of analysis
(COA)
3 The origin of the glycerin was not
easily apparent from the COA
4 The COA was often a copy of a COA
on the letterhead of the distributor
5 The chain of custody or distribution
history of the glycerin was also not
readily known
USP Glycerin Monograph
Type of Posting Revision Bulletin
Posting Date 04ndashFebndash2009
Official Date 01ndashMayndash2009
Because of the serious hazards
associated withhellip and in response to
recommendations set forth in the
FDA Guidance for Industry Testing
of Glycerin for Diethylene Glycol
published in May 2007 USP has
revised the USP Glycerin monograph
Because diethylene glycol and
ethylene glycol are considered
unacceptable toxic substances the
testing of USP Glycerin should
demonstrate the absence of these
substances
April 2007 FDA request to
USP to revise the Glycerin
monographrsquos
IDENTIFICATION section
Revision includes adding ndash
Identification test B LIMIT OF
DIETHYLENE GLYCOL AND
ETHYLENE GLYCOL to detect
and quantify DEGEG in Glycerin
minus Is no longer part of the impurity
testing
ldquoLimit of DEG and Related
Compoundsrdquo minus Introduces a
capillary gas-chromatographic
(GC) method with flame ionization
detection (FID) minus Limit of NMT
010 each for diethylene glycol
and ethylene glycol is found
70+ years to get here how difficult will it be to change habits such as lsquoblind reliance of COArsquo
3122015 Ajaz S Hussain PhD 50
Personality and Habitual Frame Biases
Myers Brigs ENTJ (first tested at FDA)
S
TF
Expanded frame
future
possibilities
objective lsquocause
and effectrsquo
Expanded frame
future
possibilities
people and
relationships
Narrow frame
the present
individuals and
relationships
Narrow frame
the present
objective
cause and
effect
N
Based on Stanford Webinar - How to Overcome the Top 3 MegaBiases in Decision-Making
Stanford Universityrsquos Strategic Decision and Risk Management certificate program
From Mapping a Managers Brain on Incentives
Social
influences
Relative
thinking
UncertaintyComplexity
By Design Intention to act consciously
bull In the interest of patients and to continually improve this ability bull To provide a healing touch ndash one life at a time in what we do and how we
do it
1292014 Ajazajazhussaincom 51
Consciously
Scientific methodology
Engineering Design
Plan-Do-Check-Act
Subconsciously
Habits (work to get rid of bad ones)
Habits (work to cultivate good one)
Keystone habits (Safety Alcoa ALCOA of data integrity)
The Power of Habit Why We Do What We Do in Life and Business Charles Duhigg (2012)
httpwwwslideshareneta2zpharmscipharmaceutical-culture-of-quality
What does it take to come out of the cGMP crisis
Persuasive demonstration of
(1) Ability to face facts
(2) Legal amp regulatory requirements
3) Systems approach to quality
4) Changing behavior amp culture
What is often missed or is unconvincing is how you will strengthen culture of quality
ldquoLet one who wants to move and convince others first be convinced and moved themselvesrdquo Thomas Carlyle
Signals that question the competence motivation andor integrity of company personnel
Do not defend the plainly indefensible it adds further serious credibility costs
3142015 Ajazajazhussaincom 52
Quality is everyones responsibility
Lack of knowledge that is
the problem
If you do not know how to ask the
right question you discover nothing
If you cant describe what you
are doing as a process you dont know what youre
doing
Rational behavior requires theory
Reactive behavior requires only reflex
action
Whenever there is fear you will get wrong figures
3142015 Ajazajazhussaincom 53
Selected quotes W Edwards Deming
3142015 Ajazajazhussaincom 54
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
ldquoWE CANNOT CHANGE THE HUMAN CONDITION BUThellipWE CAN CHANGE THE CONDITIONS UNDER WHICH HUMANS WORKrdquo JAMES REASON
Disregard to Malice
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 55
ldquohelliprecords not completed
contemporaneouslyrdquo
ldquohellipobserved analyst back-date logbooksrdquo
ldquohelliptrial injectionshelliprdquo
ldquohellipresults failing specifications are
retested until acceptable results are obtainedhelliprdquo
ldquohellipover-writing electronic raw datahelliprdquo
ldquohellipOOS not investigates per XYZ SOPrdquo
ldquohellipappropriate controls not establishedhelliprdquo
Each additional observation adds
reasons to confirm that this is very likely a system
with intentional lsquoholesrsquo in its
defenses
Preconditions
Rationalization amp Attitude
Pressure amp Incentive
Opportunity ndashlsquoholes in the QMSrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 56
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 57
Attitude towards the behavior
Subjective norm
Perceived behavioral
control
IntentionFuture
Behavior
usually found to predict behavioral intentions with a high degree of accuracy
intentions in combination with perceived behavioral control can account for a considerable proportion of variance in behavior
PastBehavior
Ajen I The theory of planned behavior ORGANIZATIONAL BEHAVIOR AND HUMAN DECISION PROCESSES 50 179-211 (1991)
Heparin tragedy 2007 and 2008
FDA reports 149 deaths with allergic or hypersensitivity symptoms during that period
bull Contaminated heparin from China
QC Testing
bull Initial testing failed to detect the contaminant
Pharmacovigilence
bull Signals in the pharmacovigilence systems responded slowly and
Eventually the severity of reactions associated made it likely that the contamination would be detected
bull too late for those who died or were injured
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 58
Congressman Shimkus When the drug safety system fails people get sick Some die
bull Some of these people are already very vulnerable and proving the cause of harm from impurities adulteration and counterfeits can be elusive
It is hard to detect harm
bull Certainly the companies are obligated to ensure a culture of quality and maintain vigilance as well This reflects a systems approach to safety
FDA inspectors look for a culture of quality at
manufacturing facilities
bull FDA policies led to the failure to inspect the Chinese plantThis system approach wasnt at
play here
bull While it doesnt deny the counterfeit source tries to say that counterfeits didnt cause the reaction as if the adulteration itself was no big deal Is this an acceptable mindset helliphelliphellip
This brings me to China and its quality culture or lack thereof
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 59
ONE HUNDRED TENTH CONGRESS SECOND SESSION APRIL 29 2008 Serial No 110-109
21 CFR PART 211 SUBPARTS -Deviations signal gaps in CoQ
bullGENERAL PROVISIONSA
bullORGANIZATION AND PERSONNELB
bullBUILDINGS AND FACILITIESC
bullEQUIPMENTD
bullCONTROL OF COMPONENTS AND DRUG PRODUCT CONTAINERS AND CLOSURESE
bullPRODUCTION AND PROCESS CONTROLSF
bullPACKAGING AND LABELING CONTROLG
bullHOLDING AND DISTRIBUTIONH
bullLABORATORY CONTROLSI
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 60
For example the combinationhellip
The Power of Habit Why We Do What We Do in Life and Business Charles Duhigg (2012)
bull Scientific methodology
bull Engineering Design
bull Plan-Do-Check-ActConsciously
bull Habits (work to get rid of bad ones)
bull Habits (work to cultivate good one)
bull Keystone habits (Safety Alcoa ALCOA of data integrity)
Subconsciously
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 61
CoQ How
bull What are the predictors of CoQCoQ Manifests by Design -
lsquoquality by designrsquo the foundation
bull 1 2 3When do people change their behaviors
bull A B C D (any body can dance)What makes a QMS effective
bull X Y ZWhen proactive compliance occurs
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 62
Going beyond rules pays
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 63
Human behavior Connecting the Dots With the Right Connectors
GXPs ndash rational behaviors
How proactive compliance is achieved X Y Z
Quality Management System
What makes a QMS reliable A B C D
Culture of Quality
Why people change their behavior 1 2 3
Human Behaviors Beyond GXPs
Predictors of Culture of Quality
Why What and How of Culture of Quality
9192014 copy Ajaz S Hussain | INSIGHT ADVICE amp SOLUTIONS LLC 64
Predictors of CoQ Act consciously in the interest of patients ndash when no one is looking
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 65
Only four attributes
actually predict a culture of
quality
Leadership Emphasis
Message Credibility
Peer Involvement
Employee Empower-ment
People will change their
behavior if they see the new behavior as
Normal
(1)
Rewarding
(2)
Easy
(3)
Dr W Edwards Demingrsquos - ldquoOut of the crisisrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 66
The journey requires leadership
with Profound Knowledge as a
guide
bull As leaders responsible for system change top management is most in need of profound knowledge
bull Quality is often determined in the boardroom
bull Problems arise when management reacts to common cause or chance variation as if it were special cause variation
bull Prediction based in theory provides a foundation for planning a course of action Plan ndash Do ndash Check ndash Act
bull The leader serves the people with clear vision and guidance to empower them To be empowered is to share ownership in the identity
bull Giving people a certain degree of control over their work fulfills the need for freedom and provides opportunity for taking joy in work
Profound Knowledge as a guide
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 67
Appreciation for a System
Theory of Knowledge
Knowledge about
Variation
Human Behavior -Psychology of Change
A
B
C
D+
Systems Approach for ErrorDeviation Management
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 68
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
Human error models and management J Reason BMJ 320 768ndash770 (2000)
D+
Culture of Error Management परबधनbull Error strain
bull Covering upFear of Errors
bull Anticipation
bull Risk takingAwareness
bull Development QbDRFT
bull Error detection Communication
bull Analyzing errors Correction
Mastery orientation
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 69
Dots amp Connections
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 70
CoQ
1
2
3
QMS
A
B
C
D
GXP Behaviors
X
Y
Z
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 71
Culture of Quality
Normal
Rewarding
Easy
QMS
System
Knowledge
Variation
Behavior
Behavior -GXPs
Fear Removed
Mastery
Awareness
EnvironmentLeadership Emphasis
Message Credibility
Peer Involvement
Employee Empowerment
Connect to CoQ
Connect to GXPs
A Framework and a Tool (for gap analysis)
3122015 Ajaz S Hussain PhD 49
Guidance for Industry Testing of
Glycerin for Diethylene Glycol
CDER May 2007 Compliance
1 Manufacturers did not perform full
identity testing on the glycerin raw
material including tests to quantify
the amount of DEG
2 Relied on the certificate of analysis
(COA)
3 The origin of the glycerin was not
easily apparent from the COA
4 The COA was often a copy of a COA
on the letterhead of the distributor
5 The chain of custody or distribution
history of the glycerin was also not
readily known
USP Glycerin Monograph
Type of Posting Revision Bulletin
Posting Date 04ndashFebndash2009
Official Date 01ndashMayndash2009
Because of the serious hazards
associated withhellip and in response to
recommendations set forth in the
FDA Guidance for Industry Testing
of Glycerin for Diethylene Glycol
published in May 2007 USP has
revised the USP Glycerin monograph
Because diethylene glycol and
ethylene glycol are considered
unacceptable toxic substances the
testing of USP Glycerin should
demonstrate the absence of these
substances
April 2007 FDA request to
USP to revise the Glycerin
monographrsquos
IDENTIFICATION section
Revision includes adding ndash
Identification test B LIMIT OF
DIETHYLENE GLYCOL AND
ETHYLENE GLYCOL to detect
and quantify DEGEG in Glycerin
minus Is no longer part of the impurity
testing
ldquoLimit of DEG and Related
Compoundsrdquo minus Introduces a
capillary gas-chromatographic
(GC) method with flame ionization
detection (FID) minus Limit of NMT
010 each for diethylene glycol
and ethylene glycol is found
70+ years to get here how difficult will it be to change habits such as lsquoblind reliance of COArsquo
3122015 Ajaz S Hussain PhD 50
Personality and Habitual Frame Biases
Myers Brigs ENTJ (first tested at FDA)
S
TF
Expanded frame
future
possibilities
objective lsquocause
and effectrsquo
Expanded frame
future
possibilities
people and
relationships
Narrow frame
the present
individuals and
relationships
Narrow frame
the present
objective
cause and
effect
N
Based on Stanford Webinar - How to Overcome the Top 3 MegaBiases in Decision-Making
Stanford Universityrsquos Strategic Decision and Risk Management certificate program
From Mapping a Managers Brain on Incentives
Social
influences
Relative
thinking
UncertaintyComplexity
By Design Intention to act consciously
bull In the interest of patients and to continually improve this ability bull To provide a healing touch ndash one life at a time in what we do and how we
do it
1292014 Ajazajazhussaincom 51
Consciously
Scientific methodology
Engineering Design
Plan-Do-Check-Act
Subconsciously
Habits (work to get rid of bad ones)
Habits (work to cultivate good one)
Keystone habits (Safety Alcoa ALCOA of data integrity)
The Power of Habit Why We Do What We Do in Life and Business Charles Duhigg (2012)
httpwwwslideshareneta2zpharmscipharmaceutical-culture-of-quality
What does it take to come out of the cGMP crisis
Persuasive demonstration of
(1) Ability to face facts
(2) Legal amp regulatory requirements
3) Systems approach to quality
4) Changing behavior amp culture
What is often missed or is unconvincing is how you will strengthen culture of quality
ldquoLet one who wants to move and convince others first be convinced and moved themselvesrdquo Thomas Carlyle
Signals that question the competence motivation andor integrity of company personnel
Do not defend the plainly indefensible it adds further serious credibility costs
3142015 Ajazajazhussaincom 52
Quality is everyones responsibility
Lack of knowledge that is
the problem
If you do not know how to ask the
right question you discover nothing
If you cant describe what you
are doing as a process you dont know what youre
doing
Rational behavior requires theory
Reactive behavior requires only reflex
action
Whenever there is fear you will get wrong figures
3142015 Ajazajazhussaincom 53
Selected quotes W Edwards Deming
3142015 Ajazajazhussaincom 54
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
ldquoWE CANNOT CHANGE THE HUMAN CONDITION BUThellipWE CAN CHANGE THE CONDITIONS UNDER WHICH HUMANS WORKrdquo JAMES REASON
Disregard to Malice
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 55
ldquohelliprecords not completed
contemporaneouslyrdquo
ldquohellipobserved analyst back-date logbooksrdquo
ldquohelliptrial injectionshelliprdquo
ldquohellipresults failing specifications are
retested until acceptable results are obtainedhelliprdquo
ldquohellipover-writing electronic raw datahelliprdquo
ldquohellipOOS not investigates per XYZ SOPrdquo
ldquohellipappropriate controls not establishedhelliprdquo
Each additional observation adds
reasons to confirm that this is very likely a system
with intentional lsquoholesrsquo in its
defenses
Preconditions
Rationalization amp Attitude
Pressure amp Incentive
Opportunity ndashlsquoholes in the QMSrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 56
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 57
Attitude towards the behavior
Subjective norm
Perceived behavioral
control
IntentionFuture
Behavior
usually found to predict behavioral intentions with a high degree of accuracy
intentions in combination with perceived behavioral control can account for a considerable proportion of variance in behavior
PastBehavior
Ajen I The theory of planned behavior ORGANIZATIONAL BEHAVIOR AND HUMAN DECISION PROCESSES 50 179-211 (1991)
Heparin tragedy 2007 and 2008
FDA reports 149 deaths with allergic or hypersensitivity symptoms during that period
bull Contaminated heparin from China
QC Testing
bull Initial testing failed to detect the contaminant
Pharmacovigilence
bull Signals in the pharmacovigilence systems responded slowly and
Eventually the severity of reactions associated made it likely that the contamination would be detected
bull too late for those who died or were injured
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 58
Congressman Shimkus When the drug safety system fails people get sick Some die
bull Some of these people are already very vulnerable and proving the cause of harm from impurities adulteration and counterfeits can be elusive
It is hard to detect harm
bull Certainly the companies are obligated to ensure a culture of quality and maintain vigilance as well This reflects a systems approach to safety
FDA inspectors look for a culture of quality at
manufacturing facilities
bull FDA policies led to the failure to inspect the Chinese plantThis system approach wasnt at
play here
bull While it doesnt deny the counterfeit source tries to say that counterfeits didnt cause the reaction as if the adulteration itself was no big deal Is this an acceptable mindset helliphelliphellip
This brings me to China and its quality culture or lack thereof
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 59
ONE HUNDRED TENTH CONGRESS SECOND SESSION APRIL 29 2008 Serial No 110-109
21 CFR PART 211 SUBPARTS -Deviations signal gaps in CoQ
bullGENERAL PROVISIONSA
bullORGANIZATION AND PERSONNELB
bullBUILDINGS AND FACILITIESC
bullEQUIPMENTD
bullCONTROL OF COMPONENTS AND DRUG PRODUCT CONTAINERS AND CLOSURESE
bullPRODUCTION AND PROCESS CONTROLSF
bullPACKAGING AND LABELING CONTROLG
bullHOLDING AND DISTRIBUTIONH
bullLABORATORY CONTROLSI
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 60
For example the combinationhellip
The Power of Habit Why We Do What We Do in Life and Business Charles Duhigg (2012)
bull Scientific methodology
bull Engineering Design
bull Plan-Do-Check-ActConsciously
bull Habits (work to get rid of bad ones)
bull Habits (work to cultivate good one)
bull Keystone habits (Safety Alcoa ALCOA of data integrity)
Subconsciously
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 61
CoQ How
bull What are the predictors of CoQCoQ Manifests by Design -
lsquoquality by designrsquo the foundation
bull 1 2 3When do people change their behaviors
bull A B C D (any body can dance)What makes a QMS effective
bull X Y ZWhen proactive compliance occurs
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 62
Going beyond rules pays
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 63
Human behavior Connecting the Dots With the Right Connectors
GXPs ndash rational behaviors
How proactive compliance is achieved X Y Z
Quality Management System
What makes a QMS reliable A B C D
Culture of Quality
Why people change their behavior 1 2 3
Human Behaviors Beyond GXPs
Predictors of Culture of Quality
Why What and How of Culture of Quality
9192014 copy Ajaz S Hussain | INSIGHT ADVICE amp SOLUTIONS LLC 64
Predictors of CoQ Act consciously in the interest of patients ndash when no one is looking
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 65
Only four attributes
actually predict a culture of
quality
Leadership Emphasis
Message Credibility
Peer Involvement
Employee Empower-ment
People will change their
behavior if they see the new behavior as
Normal
(1)
Rewarding
(2)
Easy
(3)
Dr W Edwards Demingrsquos - ldquoOut of the crisisrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 66
The journey requires leadership
with Profound Knowledge as a
guide
bull As leaders responsible for system change top management is most in need of profound knowledge
bull Quality is often determined in the boardroom
bull Problems arise when management reacts to common cause or chance variation as if it were special cause variation
bull Prediction based in theory provides a foundation for planning a course of action Plan ndash Do ndash Check ndash Act
bull The leader serves the people with clear vision and guidance to empower them To be empowered is to share ownership in the identity
bull Giving people a certain degree of control over their work fulfills the need for freedom and provides opportunity for taking joy in work
Profound Knowledge as a guide
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 67
Appreciation for a System
Theory of Knowledge
Knowledge about
Variation
Human Behavior -Psychology of Change
A
B
C
D+
Systems Approach for ErrorDeviation Management
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 68
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
Human error models and management J Reason BMJ 320 768ndash770 (2000)
D+
Culture of Error Management परबधनbull Error strain
bull Covering upFear of Errors
bull Anticipation
bull Risk takingAwareness
bull Development QbDRFT
bull Error detection Communication
bull Analyzing errors Correction
Mastery orientation
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 69
Dots amp Connections
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 70
CoQ
1
2
3
QMS
A
B
C
D
GXP Behaviors
X
Y
Z
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 71
Culture of Quality
Normal
Rewarding
Easy
QMS
System
Knowledge
Variation
Behavior
Behavior -GXPs
Fear Removed
Mastery
Awareness
EnvironmentLeadership Emphasis
Message Credibility
Peer Involvement
Employee Empowerment
Connect to CoQ
Connect to GXPs
A Framework and a Tool (for gap analysis)
3122015 Ajaz S Hussain PhD 50
Personality and Habitual Frame Biases
Myers Brigs ENTJ (first tested at FDA)
S
TF
Expanded frame
future
possibilities
objective lsquocause
and effectrsquo
Expanded frame
future
possibilities
people and
relationships
Narrow frame
the present
individuals and
relationships
Narrow frame
the present
objective
cause and
effect
N
Based on Stanford Webinar - How to Overcome the Top 3 MegaBiases in Decision-Making
Stanford Universityrsquos Strategic Decision and Risk Management certificate program
From Mapping a Managers Brain on Incentives
Social
influences
Relative
thinking
UncertaintyComplexity
By Design Intention to act consciously
bull In the interest of patients and to continually improve this ability bull To provide a healing touch ndash one life at a time in what we do and how we
do it
1292014 Ajazajazhussaincom 51
Consciously
Scientific methodology
Engineering Design
Plan-Do-Check-Act
Subconsciously
Habits (work to get rid of bad ones)
Habits (work to cultivate good one)
Keystone habits (Safety Alcoa ALCOA of data integrity)
The Power of Habit Why We Do What We Do in Life and Business Charles Duhigg (2012)
httpwwwslideshareneta2zpharmscipharmaceutical-culture-of-quality
What does it take to come out of the cGMP crisis
Persuasive demonstration of
(1) Ability to face facts
(2) Legal amp regulatory requirements
3) Systems approach to quality
4) Changing behavior amp culture
What is often missed or is unconvincing is how you will strengthen culture of quality
ldquoLet one who wants to move and convince others first be convinced and moved themselvesrdquo Thomas Carlyle
Signals that question the competence motivation andor integrity of company personnel
Do not defend the plainly indefensible it adds further serious credibility costs
3142015 Ajazajazhussaincom 52
Quality is everyones responsibility
Lack of knowledge that is
the problem
If you do not know how to ask the
right question you discover nothing
If you cant describe what you
are doing as a process you dont know what youre
doing
Rational behavior requires theory
Reactive behavior requires only reflex
action
Whenever there is fear you will get wrong figures
3142015 Ajazajazhussaincom 53
Selected quotes W Edwards Deming
3142015 Ajazajazhussaincom 54
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
ldquoWE CANNOT CHANGE THE HUMAN CONDITION BUThellipWE CAN CHANGE THE CONDITIONS UNDER WHICH HUMANS WORKrdquo JAMES REASON
Disregard to Malice
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 55
ldquohelliprecords not completed
contemporaneouslyrdquo
ldquohellipobserved analyst back-date logbooksrdquo
ldquohelliptrial injectionshelliprdquo
ldquohellipresults failing specifications are
retested until acceptable results are obtainedhelliprdquo
ldquohellipover-writing electronic raw datahelliprdquo
ldquohellipOOS not investigates per XYZ SOPrdquo
ldquohellipappropriate controls not establishedhelliprdquo
Each additional observation adds
reasons to confirm that this is very likely a system
with intentional lsquoholesrsquo in its
defenses
Preconditions
Rationalization amp Attitude
Pressure amp Incentive
Opportunity ndashlsquoholes in the QMSrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 56
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 57
Attitude towards the behavior
Subjective norm
Perceived behavioral
control
IntentionFuture
Behavior
usually found to predict behavioral intentions with a high degree of accuracy
intentions in combination with perceived behavioral control can account for a considerable proportion of variance in behavior
PastBehavior
Ajen I The theory of planned behavior ORGANIZATIONAL BEHAVIOR AND HUMAN DECISION PROCESSES 50 179-211 (1991)
Heparin tragedy 2007 and 2008
FDA reports 149 deaths with allergic or hypersensitivity symptoms during that period
bull Contaminated heparin from China
QC Testing
bull Initial testing failed to detect the contaminant
Pharmacovigilence
bull Signals in the pharmacovigilence systems responded slowly and
Eventually the severity of reactions associated made it likely that the contamination would be detected
bull too late for those who died or were injured
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 58
Congressman Shimkus When the drug safety system fails people get sick Some die
bull Some of these people are already very vulnerable and proving the cause of harm from impurities adulteration and counterfeits can be elusive
It is hard to detect harm
bull Certainly the companies are obligated to ensure a culture of quality and maintain vigilance as well This reflects a systems approach to safety
FDA inspectors look for a culture of quality at
manufacturing facilities
bull FDA policies led to the failure to inspect the Chinese plantThis system approach wasnt at
play here
bull While it doesnt deny the counterfeit source tries to say that counterfeits didnt cause the reaction as if the adulteration itself was no big deal Is this an acceptable mindset helliphelliphellip
This brings me to China and its quality culture or lack thereof
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 59
ONE HUNDRED TENTH CONGRESS SECOND SESSION APRIL 29 2008 Serial No 110-109
21 CFR PART 211 SUBPARTS -Deviations signal gaps in CoQ
bullGENERAL PROVISIONSA
bullORGANIZATION AND PERSONNELB
bullBUILDINGS AND FACILITIESC
bullEQUIPMENTD
bullCONTROL OF COMPONENTS AND DRUG PRODUCT CONTAINERS AND CLOSURESE
bullPRODUCTION AND PROCESS CONTROLSF
bullPACKAGING AND LABELING CONTROLG
bullHOLDING AND DISTRIBUTIONH
bullLABORATORY CONTROLSI
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 60
For example the combinationhellip
The Power of Habit Why We Do What We Do in Life and Business Charles Duhigg (2012)
bull Scientific methodology
bull Engineering Design
bull Plan-Do-Check-ActConsciously
bull Habits (work to get rid of bad ones)
bull Habits (work to cultivate good one)
bull Keystone habits (Safety Alcoa ALCOA of data integrity)
Subconsciously
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 61
CoQ How
bull What are the predictors of CoQCoQ Manifests by Design -
lsquoquality by designrsquo the foundation
bull 1 2 3When do people change their behaviors
bull A B C D (any body can dance)What makes a QMS effective
bull X Y ZWhen proactive compliance occurs
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 62
Going beyond rules pays
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 63
Human behavior Connecting the Dots With the Right Connectors
GXPs ndash rational behaviors
How proactive compliance is achieved X Y Z
Quality Management System
What makes a QMS reliable A B C D
Culture of Quality
Why people change their behavior 1 2 3
Human Behaviors Beyond GXPs
Predictors of Culture of Quality
Why What and How of Culture of Quality
9192014 copy Ajaz S Hussain | INSIGHT ADVICE amp SOLUTIONS LLC 64
Predictors of CoQ Act consciously in the interest of patients ndash when no one is looking
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 65
Only four attributes
actually predict a culture of
quality
Leadership Emphasis
Message Credibility
Peer Involvement
Employee Empower-ment
People will change their
behavior if they see the new behavior as
Normal
(1)
Rewarding
(2)
Easy
(3)
Dr W Edwards Demingrsquos - ldquoOut of the crisisrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 66
The journey requires leadership
with Profound Knowledge as a
guide
bull As leaders responsible for system change top management is most in need of profound knowledge
bull Quality is often determined in the boardroom
bull Problems arise when management reacts to common cause or chance variation as if it were special cause variation
bull Prediction based in theory provides a foundation for planning a course of action Plan ndash Do ndash Check ndash Act
bull The leader serves the people with clear vision and guidance to empower them To be empowered is to share ownership in the identity
bull Giving people a certain degree of control over their work fulfills the need for freedom and provides opportunity for taking joy in work
Profound Knowledge as a guide
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 67
Appreciation for a System
Theory of Knowledge
Knowledge about
Variation
Human Behavior -Psychology of Change
A
B
C
D+
Systems Approach for ErrorDeviation Management
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 68
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
Human error models and management J Reason BMJ 320 768ndash770 (2000)
D+
Culture of Error Management परबधनbull Error strain
bull Covering upFear of Errors
bull Anticipation
bull Risk takingAwareness
bull Development QbDRFT
bull Error detection Communication
bull Analyzing errors Correction
Mastery orientation
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 69
Dots amp Connections
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 70
CoQ
1
2
3
QMS
A
B
C
D
GXP Behaviors
X
Y
Z
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 71
Culture of Quality
Normal
Rewarding
Easy
QMS
System
Knowledge
Variation
Behavior
Behavior -GXPs
Fear Removed
Mastery
Awareness
EnvironmentLeadership Emphasis
Message Credibility
Peer Involvement
Employee Empowerment
Connect to CoQ
Connect to GXPs
A Framework and a Tool (for gap analysis)
By Design Intention to act consciously
bull In the interest of patients and to continually improve this ability bull To provide a healing touch ndash one life at a time in what we do and how we
do it
1292014 Ajazajazhussaincom 51
Consciously
Scientific methodology
Engineering Design
Plan-Do-Check-Act
Subconsciously
Habits (work to get rid of bad ones)
Habits (work to cultivate good one)
Keystone habits (Safety Alcoa ALCOA of data integrity)
The Power of Habit Why We Do What We Do in Life and Business Charles Duhigg (2012)
httpwwwslideshareneta2zpharmscipharmaceutical-culture-of-quality
What does it take to come out of the cGMP crisis
Persuasive demonstration of
(1) Ability to face facts
(2) Legal amp regulatory requirements
3) Systems approach to quality
4) Changing behavior amp culture
What is often missed or is unconvincing is how you will strengthen culture of quality
ldquoLet one who wants to move and convince others first be convinced and moved themselvesrdquo Thomas Carlyle
Signals that question the competence motivation andor integrity of company personnel
Do not defend the plainly indefensible it adds further serious credibility costs
3142015 Ajazajazhussaincom 52
Quality is everyones responsibility
Lack of knowledge that is
the problem
If you do not know how to ask the
right question you discover nothing
If you cant describe what you
are doing as a process you dont know what youre
doing
Rational behavior requires theory
Reactive behavior requires only reflex
action
Whenever there is fear you will get wrong figures
3142015 Ajazajazhussaincom 53
Selected quotes W Edwards Deming
3142015 Ajazajazhussaincom 54
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
ldquoWE CANNOT CHANGE THE HUMAN CONDITION BUThellipWE CAN CHANGE THE CONDITIONS UNDER WHICH HUMANS WORKrdquo JAMES REASON
Disregard to Malice
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 55
ldquohelliprecords not completed
contemporaneouslyrdquo
ldquohellipobserved analyst back-date logbooksrdquo
ldquohelliptrial injectionshelliprdquo
ldquohellipresults failing specifications are
retested until acceptable results are obtainedhelliprdquo
ldquohellipover-writing electronic raw datahelliprdquo
ldquohellipOOS not investigates per XYZ SOPrdquo
ldquohellipappropriate controls not establishedhelliprdquo
Each additional observation adds
reasons to confirm that this is very likely a system
with intentional lsquoholesrsquo in its
defenses
Preconditions
Rationalization amp Attitude
Pressure amp Incentive
Opportunity ndashlsquoholes in the QMSrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 56
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 57
Attitude towards the behavior
Subjective norm
Perceived behavioral
control
IntentionFuture
Behavior
usually found to predict behavioral intentions with a high degree of accuracy
intentions in combination with perceived behavioral control can account for a considerable proportion of variance in behavior
PastBehavior
Ajen I The theory of planned behavior ORGANIZATIONAL BEHAVIOR AND HUMAN DECISION PROCESSES 50 179-211 (1991)
Heparin tragedy 2007 and 2008
FDA reports 149 deaths with allergic or hypersensitivity symptoms during that period
bull Contaminated heparin from China
QC Testing
bull Initial testing failed to detect the contaminant
Pharmacovigilence
bull Signals in the pharmacovigilence systems responded slowly and
Eventually the severity of reactions associated made it likely that the contamination would be detected
bull too late for those who died or were injured
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 58
Congressman Shimkus When the drug safety system fails people get sick Some die
bull Some of these people are already very vulnerable and proving the cause of harm from impurities adulteration and counterfeits can be elusive
It is hard to detect harm
bull Certainly the companies are obligated to ensure a culture of quality and maintain vigilance as well This reflects a systems approach to safety
FDA inspectors look for a culture of quality at
manufacturing facilities
bull FDA policies led to the failure to inspect the Chinese plantThis system approach wasnt at
play here
bull While it doesnt deny the counterfeit source tries to say that counterfeits didnt cause the reaction as if the adulteration itself was no big deal Is this an acceptable mindset helliphelliphellip
This brings me to China and its quality culture or lack thereof
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 59
ONE HUNDRED TENTH CONGRESS SECOND SESSION APRIL 29 2008 Serial No 110-109
21 CFR PART 211 SUBPARTS -Deviations signal gaps in CoQ
bullGENERAL PROVISIONSA
bullORGANIZATION AND PERSONNELB
bullBUILDINGS AND FACILITIESC
bullEQUIPMENTD
bullCONTROL OF COMPONENTS AND DRUG PRODUCT CONTAINERS AND CLOSURESE
bullPRODUCTION AND PROCESS CONTROLSF
bullPACKAGING AND LABELING CONTROLG
bullHOLDING AND DISTRIBUTIONH
bullLABORATORY CONTROLSI
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 60
For example the combinationhellip
The Power of Habit Why We Do What We Do in Life and Business Charles Duhigg (2012)
bull Scientific methodology
bull Engineering Design
bull Plan-Do-Check-ActConsciously
bull Habits (work to get rid of bad ones)
bull Habits (work to cultivate good one)
bull Keystone habits (Safety Alcoa ALCOA of data integrity)
Subconsciously
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 61
CoQ How
bull What are the predictors of CoQCoQ Manifests by Design -
lsquoquality by designrsquo the foundation
bull 1 2 3When do people change their behaviors
bull A B C D (any body can dance)What makes a QMS effective
bull X Y ZWhen proactive compliance occurs
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 62
Going beyond rules pays
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 63
Human behavior Connecting the Dots With the Right Connectors
GXPs ndash rational behaviors
How proactive compliance is achieved X Y Z
Quality Management System
What makes a QMS reliable A B C D
Culture of Quality
Why people change their behavior 1 2 3
Human Behaviors Beyond GXPs
Predictors of Culture of Quality
Why What and How of Culture of Quality
9192014 copy Ajaz S Hussain | INSIGHT ADVICE amp SOLUTIONS LLC 64
Predictors of CoQ Act consciously in the interest of patients ndash when no one is looking
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 65
Only four attributes
actually predict a culture of
quality
Leadership Emphasis
Message Credibility
Peer Involvement
Employee Empower-ment
People will change their
behavior if they see the new behavior as
Normal
(1)
Rewarding
(2)
Easy
(3)
Dr W Edwards Demingrsquos - ldquoOut of the crisisrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 66
The journey requires leadership
with Profound Knowledge as a
guide
bull As leaders responsible for system change top management is most in need of profound knowledge
bull Quality is often determined in the boardroom
bull Problems arise when management reacts to common cause or chance variation as if it were special cause variation
bull Prediction based in theory provides a foundation for planning a course of action Plan ndash Do ndash Check ndash Act
bull The leader serves the people with clear vision and guidance to empower them To be empowered is to share ownership in the identity
bull Giving people a certain degree of control over their work fulfills the need for freedom and provides opportunity for taking joy in work
Profound Knowledge as a guide
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 67
Appreciation for a System
Theory of Knowledge
Knowledge about
Variation
Human Behavior -Psychology of Change
A
B
C
D+
Systems Approach for ErrorDeviation Management
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 68
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
Human error models and management J Reason BMJ 320 768ndash770 (2000)
D+
Culture of Error Management परबधनbull Error strain
bull Covering upFear of Errors
bull Anticipation
bull Risk takingAwareness
bull Development QbDRFT
bull Error detection Communication
bull Analyzing errors Correction
Mastery orientation
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 69
Dots amp Connections
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 70
CoQ
1
2
3
QMS
A
B
C
D
GXP Behaviors
X
Y
Z
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 71
Culture of Quality
Normal
Rewarding
Easy
QMS
System
Knowledge
Variation
Behavior
Behavior -GXPs
Fear Removed
Mastery
Awareness
EnvironmentLeadership Emphasis
Message Credibility
Peer Involvement
Employee Empowerment
Connect to CoQ
Connect to GXPs
A Framework and a Tool (for gap analysis)
What does it take to come out of the cGMP crisis
Persuasive demonstration of
(1) Ability to face facts
(2) Legal amp regulatory requirements
3) Systems approach to quality
4) Changing behavior amp culture
What is often missed or is unconvincing is how you will strengthen culture of quality
ldquoLet one who wants to move and convince others first be convinced and moved themselvesrdquo Thomas Carlyle
Signals that question the competence motivation andor integrity of company personnel
Do not defend the plainly indefensible it adds further serious credibility costs
3142015 Ajazajazhussaincom 52
Quality is everyones responsibility
Lack of knowledge that is
the problem
If you do not know how to ask the
right question you discover nothing
If you cant describe what you
are doing as a process you dont know what youre
doing
Rational behavior requires theory
Reactive behavior requires only reflex
action
Whenever there is fear you will get wrong figures
3142015 Ajazajazhussaincom 53
Selected quotes W Edwards Deming
3142015 Ajazajazhussaincom 54
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
ldquoWE CANNOT CHANGE THE HUMAN CONDITION BUThellipWE CAN CHANGE THE CONDITIONS UNDER WHICH HUMANS WORKrdquo JAMES REASON
Disregard to Malice
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 55
ldquohelliprecords not completed
contemporaneouslyrdquo
ldquohellipobserved analyst back-date logbooksrdquo
ldquohelliptrial injectionshelliprdquo
ldquohellipresults failing specifications are
retested until acceptable results are obtainedhelliprdquo
ldquohellipover-writing electronic raw datahelliprdquo
ldquohellipOOS not investigates per XYZ SOPrdquo
ldquohellipappropriate controls not establishedhelliprdquo
Each additional observation adds
reasons to confirm that this is very likely a system
with intentional lsquoholesrsquo in its
defenses
Preconditions
Rationalization amp Attitude
Pressure amp Incentive
Opportunity ndashlsquoholes in the QMSrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 56
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 57
Attitude towards the behavior
Subjective norm
Perceived behavioral
control
IntentionFuture
Behavior
usually found to predict behavioral intentions with a high degree of accuracy
intentions in combination with perceived behavioral control can account for a considerable proportion of variance in behavior
PastBehavior
Ajen I The theory of planned behavior ORGANIZATIONAL BEHAVIOR AND HUMAN DECISION PROCESSES 50 179-211 (1991)
Heparin tragedy 2007 and 2008
FDA reports 149 deaths with allergic or hypersensitivity symptoms during that period
bull Contaminated heparin from China
QC Testing
bull Initial testing failed to detect the contaminant
Pharmacovigilence
bull Signals in the pharmacovigilence systems responded slowly and
Eventually the severity of reactions associated made it likely that the contamination would be detected
bull too late for those who died or were injured
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 58
Congressman Shimkus When the drug safety system fails people get sick Some die
bull Some of these people are already very vulnerable and proving the cause of harm from impurities adulteration and counterfeits can be elusive
It is hard to detect harm
bull Certainly the companies are obligated to ensure a culture of quality and maintain vigilance as well This reflects a systems approach to safety
FDA inspectors look for a culture of quality at
manufacturing facilities
bull FDA policies led to the failure to inspect the Chinese plantThis system approach wasnt at
play here
bull While it doesnt deny the counterfeit source tries to say that counterfeits didnt cause the reaction as if the adulteration itself was no big deal Is this an acceptable mindset helliphelliphellip
This brings me to China and its quality culture or lack thereof
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 59
ONE HUNDRED TENTH CONGRESS SECOND SESSION APRIL 29 2008 Serial No 110-109
21 CFR PART 211 SUBPARTS -Deviations signal gaps in CoQ
bullGENERAL PROVISIONSA
bullORGANIZATION AND PERSONNELB
bullBUILDINGS AND FACILITIESC
bullEQUIPMENTD
bullCONTROL OF COMPONENTS AND DRUG PRODUCT CONTAINERS AND CLOSURESE
bullPRODUCTION AND PROCESS CONTROLSF
bullPACKAGING AND LABELING CONTROLG
bullHOLDING AND DISTRIBUTIONH
bullLABORATORY CONTROLSI
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 60
For example the combinationhellip
The Power of Habit Why We Do What We Do in Life and Business Charles Duhigg (2012)
bull Scientific methodology
bull Engineering Design
bull Plan-Do-Check-ActConsciously
bull Habits (work to get rid of bad ones)
bull Habits (work to cultivate good one)
bull Keystone habits (Safety Alcoa ALCOA of data integrity)
Subconsciously
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 61
CoQ How
bull What are the predictors of CoQCoQ Manifests by Design -
lsquoquality by designrsquo the foundation
bull 1 2 3When do people change their behaviors
bull A B C D (any body can dance)What makes a QMS effective
bull X Y ZWhen proactive compliance occurs
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 62
Going beyond rules pays
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 63
Human behavior Connecting the Dots With the Right Connectors
GXPs ndash rational behaviors
How proactive compliance is achieved X Y Z
Quality Management System
What makes a QMS reliable A B C D
Culture of Quality
Why people change their behavior 1 2 3
Human Behaviors Beyond GXPs
Predictors of Culture of Quality
Why What and How of Culture of Quality
9192014 copy Ajaz S Hussain | INSIGHT ADVICE amp SOLUTIONS LLC 64
Predictors of CoQ Act consciously in the interest of patients ndash when no one is looking
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 65
Only four attributes
actually predict a culture of
quality
Leadership Emphasis
Message Credibility
Peer Involvement
Employee Empower-ment
People will change their
behavior if they see the new behavior as
Normal
(1)
Rewarding
(2)
Easy
(3)
Dr W Edwards Demingrsquos - ldquoOut of the crisisrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 66
The journey requires leadership
with Profound Knowledge as a
guide
bull As leaders responsible for system change top management is most in need of profound knowledge
bull Quality is often determined in the boardroom
bull Problems arise when management reacts to common cause or chance variation as if it were special cause variation
bull Prediction based in theory provides a foundation for planning a course of action Plan ndash Do ndash Check ndash Act
bull The leader serves the people with clear vision and guidance to empower them To be empowered is to share ownership in the identity
bull Giving people a certain degree of control over their work fulfills the need for freedom and provides opportunity for taking joy in work
Profound Knowledge as a guide
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 67
Appreciation for a System
Theory of Knowledge
Knowledge about
Variation
Human Behavior -Psychology of Change
A
B
C
D+
Systems Approach for ErrorDeviation Management
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 68
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
Human error models and management J Reason BMJ 320 768ndash770 (2000)
D+
Culture of Error Management परबधनbull Error strain
bull Covering upFear of Errors
bull Anticipation
bull Risk takingAwareness
bull Development QbDRFT
bull Error detection Communication
bull Analyzing errors Correction
Mastery orientation
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 69
Dots amp Connections
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 70
CoQ
1
2
3
QMS
A
B
C
D
GXP Behaviors
X
Y
Z
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 71
Culture of Quality
Normal
Rewarding
Easy
QMS
System
Knowledge
Variation
Behavior
Behavior -GXPs
Fear Removed
Mastery
Awareness
EnvironmentLeadership Emphasis
Message Credibility
Peer Involvement
Employee Empowerment
Connect to CoQ
Connect to GXPs
A Framework and a Tool (for gap analysis)
Quality is everyones responsibility
Lack of knowledge that is
the problem
If you do not know how to ask the
right question you discover nothing
If you cant describe what you
are doing as a process you dont know what youre
doing
Rational behavior requires theory
Reactive behavior requires only reflex
action
Whenever there is fear you will get wrong figures
3142015 Ajazajazhussaincom 53
Selected quotes W Edwards Deming
3142015 Ajazajazhussaincom 54
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
ldquoWE CANNOT CHANGE THE HUMAN CONDITION BUThellipWE CAN CHANGE THE CONDITIONS UNDER WHICH HUMANS WORKrdquo JAMES REASON
Disregard to Malice
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 55
ldquohelliprecords not completed
contemporaneouslyrdquo
ldquohellipobserved analyst back-date logbooksrdquo
ldquohelliptrial injectionshelliprdquo
ldquohellipresults failing specifications are
retested until acceptable results are obtainedhelliprdquo
ldquohellipover-writing electronic raw datahelliprdquo
ldquohellipOOS not investigates per XYZ SOPrdquo
ldquohellipappropriate controls not establishedhelliprdquo
Each additional observation adds
reasons to confirm that this is very likely a system
with intentional lsquoholesrsquo in its
defenses
Preconditions
Rationalization amp Attitude
Pressure amp Incentive
Opportunity ndashlsquoholes in the QMSrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 56
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 57
Attitude towards the behavior
Subjective norm
Perceived behavioral
control
IntentionFuture
Behavior
usually found to predict behavioral intentions with a high degree of accuracy
intentions in combination with perceived behavioral control can account for a considerable proportion of variance in behavior
PastBehavior
Ajen I The theory of planned behavior ORGANIZATIONAL BEHAVIOR AND HUMAN DECISION PROCESSES 50 179-211 (1991)
Heparin tragedy 2007 and 2008
FDA reports 149 deaths with allergic or hypersensitivity symptoms during that period
bull Contaminated heparin from China
QC Testing
bull Initial testing failed to detect the contaminant
Pharmacovigilence
bull Signals in the pharmacovigilence systems responded slowly and
Eventually the severity of reactions associated made it likely that the contamination would be detected
bull too late for those who died or were injured
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 58
Congressman Shimkus When the drug safety system fails people get sick Some die
bull Some of these people are already very vulnerable and proving the cause of harm from impurities adulteration and counterfeits can be elusive
It is hard to detect harm
bull Certainly the companies are obligated to ensure a culture of quality and maintain vigilance as well This reflects a systems approach to safety
FDA inspectors look for a culture of quality at
manufacturing facilities
bull FDA policies led to the failure to inspect the Chinese plantThis system approach wasnt at
play here
bull While it doesnt deny the counterfeit source tries to say that counterfeits didnt cause the reaction as if the adulteration itself was no big deal Is this an acceptable mindset helliphelliphellip
This brings me to China and its quality culture or lack thereof
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 59
ONE HUNDRED TENTH CONGRESS SECOND SESSION APRIL 29 2008 Serial No 110-109
21 CFR PART 211 SUBPARTS -Deviations signal gaps in CoQ
bullGENERAL PROVISIONSA
bullORGANIZATION AND PERSONNELB
bullBUILDINGS AND FACILITIESC
bullEQUIPMENTD
bullCONTROL OF COMPONENTS AND DRUG PRODUCT CONTAINERS AND CLOSURESE
bullPRODUCTION AND PROCESS CONTROLSF
bullPACKAGING AND LABELING CONTROLG
bullHOLDING AND DISTRIBUTIONH
bullLABORATORY CONTROLSI
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 60
For example the combinationhellip
The Power of Habit Why We Do What We Do in Life and Business Charles Duhigg (2012)
bull Scientific methodology
bull Engineering Design
bull Plan-Do-Check-ActConsciously
bull Habits (work to get rid of bad ones)
bull Habits (work to cultivate good one)
bull Keystone habits (Safety Alcoa ALCOA of data integrity)
Subconsciously
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 61
CoQ How
bull What are the predictors of CoQCoQ Manifests by Design -
lsquoquality by designrsquo the foundation
bull 1 2 3When do people change their behaviors
bull A B C D (any body can dance)What makes a QMS effective
bull X Y ZWhen proactive compliance occurs
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 62
Going beyond rules pays
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 63
Human behavior Connecting the Dots With the Right Connectors
GXPs ndash rational behaviors
How proactive compliance is achieved X Y Z
Quality Management System
What makes a QMS reliable A B C D
Culture of Quality
Why people change their behavior 1 2 3
Human Behaviors Beyond GXPs
Predictors of Culture of Quality
Why What and How of Culture of Quality
9192014 copy Ajaz S Hussain | INSIGHT ADVICE amp SOLUTIONS LLC 64
Predictors of CoQ Act consciously in the interest of patients ndash when no one is looking
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 65
Only four attributes
actually predict a culture of
quality
Leadership Emphasis
Message Credibility
Peer Involvement
Employee Empower-ment
People will change their
behavior if they see the new behavior as
Normal
(1)
Rewarding
(2)
Easy
(3)
Dr W Edwards Demingrsquos - ldquoOut of the crisisrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 66
The journey requires leadership
with Profound Knowledge as a
guide
bull As leaders responsible for system change top management is most in need of profound knowledge
bull Quality is often determined in the boardroom
bull Problems arise when management reacts to common cause or chance variation as if it were special cause variation
bull Prediction based in theory provides a foundation for planning a course of action Plan ndash Do ndash Check ndash Act
bull The leader serves the people with clear vision and guidance to empower them To be empowered is to share ownership in the identity
bull Giving people a certain degree of control over their work fulfills the need for freedom and provides opportunity for taking joy in work
Profound Knowledge as a guide
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 67
Appreciation for a System
Theory of Knowledge
Knowledge about
Variation
Human Behavior -Psychology of Change
A
B
C
D+
Systems Approach for ErrorDeviation Management
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 68
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
Human error models and management J Reason BMJ 320 768ndash770 (2000)
D+
Culture of Error Management परबधनbull Error strain
bull Covering upFear of Errors
bull Anticipation
bull Risk takingAwareness
bull Development QbDRFT
bull Error detection Communication
bull Analyzing errors Correction
Mastery orientation
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 69
Dots amp Connections
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 70
CoQ
1
2
3
QMS
A
B
C
D
GXP Behaviors
X
Y
Z
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 71
Culture of Quality
Normal
Rewarding
Easy
QMS
System
Knowledge
Variation
Behavior
Behavior -GXPs
Fear Removed
Mastery
Awareness
EnvironmentLeadership Emphasis
Message Credibility
Peer Involvement
Employee Empowerment
Connect to CoQ
Connect to GXPs
A Framework and a Tool (for gap analysis)
3142015 Ajazajazhussaincom 54
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
ldquoWE CANNOT CHANGE THE HUMAN CONDITION BUThellipWE CAN CHANGE THE CONDITIONS UNDER WHICH HUMANS WORKrdquo JAMES REASON
Disregard to Malice
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 55
ldquohelliprecords not completed
contemporaneouslyrdquo
ldquohellipobserved analyst back-date logbooksrdquo
ldquohelliptrial injectionshelliprdquo
ldquohellipresults failing specifications are
retested until acceptable results are obtainedhelliprdquo
ldquohellipover-writing electronic raw datahelliprdquo
ldquohellipOOS not investigates per XYZ SOPrdquo
ldquohellipappropriate controls not establishedhelliprdquo
Each additional observation adds
reasons to confirm that this is very likely a system
with intentional lsquoholesrsquo in its
defenses
Preconditions
Rationalization amp Attitude
Pressure amp Incentive
Opportunity ndashlsquoholes in the QMSrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 56
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 57
Attitude towards the behavior
Subjective norm
Perceived behavioral
control
IntentionFuture
Behavior
usually found to predict behavioral intentions with a high degree of accuracy
intentions in combination with perceived behavioral control can account for a considerable proportion of variance in behavior
PastBehavior
Ajen I The theory of planned behavior ORGANIZATIONAL BEHAVIOR AND HUMAN DECISION PROCESSES 50 179-211 (1991)
Heparin tragedy 2007 and 2008
FDA reports 149 deaths with allergic or hypersensitivity symptoms during that period
bull Contaminated heparin from China
QC Testing
bull Initial testing failed to detect the contaminant
Pharmacovigilence
bull Signals in the pharmacovigilence systems responded slowly and
Eventually the severity of reactions associated made it likely that the contamination would be detected
bull too late for those who died or were injured
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 58
Congressman Shimkus When the drug safety system fails people get sick Some die
bull Some of these people are already very vulnerable and proving the cause of harm from impurities adulteration and counterfeits can be elusive
It is hard to detect harm
bull Certainly the companies are obligated to ensure a culture of quality and maintain vigilance as well This reflects a systems approach to safety
FDA inspectors look for a culture of quality at
manufacturing facilities
bull FDA policies led to the failure to inspect the Chinese plantThis system approach wasnt at
play here
bull While it doesnt deny the counterfeit source tries to say that counterfeits didnt cause the reaction as if the adulteration itself was no big deal Is this an acceptable mindset helliphelliphellip
This brings me to China and its quality culture or lack thereof
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 59
ONE HUNDRED TENTH CONGRESS SECOND SESSION APRIL 29 2008 Serial No 110-109
21 CFR PART 211 SUBPARTS -Deviations signal gaps in CoQ
bullGENERAL PROVISIONSA
bullORGANIZATION AND PERSONNELB
bullBUILDINGS AND FACILITIESC
bullEQUIPMENTD
bullCONTROL OF COMPONENTS AND DRUG PRODUCT CONTAINERS AND CLOSURESE
bullPRODUCTION AND PROCESS CONTROLSF
bullPACKAGING AND LABELING CONTROLG
bullHOLDING AND DISTRIBUTIONH
bullLABORATORY CONTROLSI
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 60
For example the combinationhellip
The Power of Habit Why We Do What We Do in Life and Business Charles Duhigg (2012)
bull Scientific methodology
bull Engineering Design
bull Plan-Do-Check-ActConsciously
bull Habits (work to get rid of bad ones)
bull Habits (work to cultivate good one)
bull Keystone habits (Safety Alcoa ALCOA of data integrity)
Subconsciously
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 61
CoQ How
bull What are the predictors of CoQCoQ Manifests by Design -
lsquoquality by designrsquo the foundation
bull 1 2 3When do people change their behaviors
bull A B C D (any body can dance)What makes a QMS effective
bull X Y ZWhen proactive compliance occurs
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 62
Going beyond rules pays
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 63
Human behavior Connecting the Dots With the Right Connectors
GXPs ndash rational behaviors
How proactive compliance is achieved X Y Z
Quality Management System
What makes a QMS reliable A B C D
Culture of Quality
Why people change their behavior 1 2 3
Human Behaviors Beyond GXPs
Predictors of Culture of Quality
Why What and How of Culture of Quality
9192014 copy Ajaz S Hussain | INSIGHT ADVICE amp SOLUTIONS LLC 64
Predictors of CoQ Act consciously in the interest of patients ndash when no one is looking
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 65
Only four attributes
actually predict a culture of
quality
Leadership Emphasis
Message Credibility
Peer Involvement
Employee Empower-ment
People will change their
behavior if they see the new behavior as
Normal
(1)
Rewarding
(2)
Easy
(3)
Dr W Edwards Demingrsquos - ldquoOut of the crisisrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 66
The journey requires leadership
with Profound Knowledge as a
guide
bull As leaders responsible for system change top management is most in need of profound knowledge
bull Quality is often determined in the boardroom
bull Problems arise when management reacts to common cause or chance variation as if it were special cause variation
bull Prediction based in theory provides a foundation for planning a course of action Plan ndash Do ndash Check ndash Act
bull The leader serves the people with clear vision and guidance to empower them To be empowered is to share ownership in the identity
bull Giving people a certain degree of control over their work fulfills the need for freedom and provides opportunity for taking joy in work
Profound Knowledge as a guide
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 67
Appreciation for a System
Theory of Knowledge
Knowledge about
Variation
Human Behavior -Psychology of Change
A
B
C
D+
Systems Approach for ErrorDeviation Management
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 68
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
Human error models and management J Reason BMJ 320 768ndash770 (2000)
D+
Culture of Error Management परबधनbull Error strain
bull Covering upFear of Errors
bull Anticipation
bull Risk takingAwareness
bull Development QbDRFT
bull Error detection Communication
bull Analyzing errors Correction
Mastery orientation
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 69
Dots amp Connections
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 70
CoQ
1
2
3
QMS
A
B
C
D
GXP Behaviors
X
Y
Z
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 71
Culture of Quality
Normal
Rewarding
Easy
QMS
System
Knowledge
Variation
Behavior
Behavior -GXPs
Fear Removed
Mastery
Awareness
EnvironmentLeadership Emphasis
Message Credibility
Peer Involvement
Employee Empowerment
Connect to CoQ
Connect to GXPs
A Framework and a Tool (for gap analysis)
Disregard to Malice
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 55
ldquohelliprecords not completed
contemporaneouslyrdquo
ldquohellipobserved analyst back-date logbooksrdquo
ldquohelliptrial injectionshelliprdquo
ldquohellipresults failing specifications are
retested until acceptable results are obtainedhelliprdquo
ldquohellipover-writing electronic raw datahelliprdquo
ldquohellipOOS not investigates per XYZ SOPrdquo
ldquohellipappropriate controls not establishedhelliprdquo
Each additional observation adds
reasons to confirm that this is very likely a system
with intentional lsquoholesrsquo in its
defenses
Preconditions
Rationalization amp Attitude
Pressure amp Incentive
Opportunity ndashlsquoholes in the QMSrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 56
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 57
Attitude towards the behavior
Subjective norm
Perceived behavioral
control
IntentionFuture
Behavior
usually found to predict behavioral intentions with a high degree of accuracy
intentions in combination with perceived behavioral control can account for a considerable proportion of variance in behavior
PastBehavior
Ajen I The theory of planned behavior ORGANIZATIONAL BEHAVIOR AND HUMAN DECISION PROCESSES 50 179-211 (1991)
Heparin tragedy 2007 and 2008
FDA reports 149 deaths with allergic or hypersensitivity symptoms during that period
bull Contaminated heparin from China
QC Testing
bull Initial testing failed to detect the contaminant
Pharmacovigilence
bull Signals in the pharmacovigilence systems responded slowly and
Eventually the severity of reactions associated made it likely that the contamination would be detected
bull too late for those who died or were injured
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 58
Congressman Shimkus When the drug safety system fails people get sick Some die
bull Some of these people are already very vulnerable and proving the cause of harm from impurities adulteration and counterfeits can be elusive
It is hard to detect harm
bull Certainly the companies are obligated to ensure a culture of quality and maintain vigilance as well This reflects a systems approach to safety
FDA inspectors look for a culture of quality at
manufacturing facilities
bull FDA policies led to the failure to inspect the Chinese plantThis system approach wasnt at
play here
bull While it doesnt deny the counterfeit source tries to say that counterfeits didnt cause the reaction as if the adulteration itself was no big deal Is this an acceptable mindset helliphelliphellip
This brings me to China and its quality culture or lack thereof
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 59
ONE HUNDRED TENTH CONGRESS SECOND SESSION APRIL 29 2008 Serial No 110-109
21 CFR PART 211 SUBPARTS -Deviations signal gaps in CoQ
bullGENERAL PROVISIONSA
bullORGANIZATION AND PERSONNELB
bullBUILDINGS AND FACILITIESC
bullEQUIPMENTD
bullCONTROL OF COMPONENTS AND DRUG PRODUCT CONTAINERS AND CLOSURESE
bullPRODUCTION AND PROCESS CONTROLSF
bullPACKAGING AND LABELING CONTROLG
bullHOLDING AND DISTRIBUTIONH
bullLABORATORY CONTROLSI
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 60
For example the combinationhellip
The Power of Habit Why We Do What We Do in Life and Business Charles Duhigg (2012)
bull Scientific methodology
bull Engineering Design
bull Plan-Do-Check-ActConsciously
bull Habits (work to get rid of bad ones)
bull Habits (work to cultivate good one)
bull Keystone habits (Safety Alcoa ALCOA of data integrity)
Subconsciously
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 61
CoQ How
bull What are the predictors of CoQCoQ Manifests by Design -
lsquoquality by designrsquo the foundation
bull 1 2 3When do people change their behaviors
bull A B C D (any body can dance)What makes a QMS effective
bull X Y ZWhen proactive compliance occurs
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 62
Going beyond rules pays
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 63
Human behavior Connecting the Dots With the Right Connectors
GXPs ndash rational behaviors
How proactive compliance is achieved X Y Z
Quality Management System
What makes a QMS reliable A B C D
Culture of Quality
Why people change their behavior 1 2 3
Human Behaviors Beyond GXPs
Predictors of Culture of Quality
Why What and How of Culture of Quality
9192014 copy Ajaz S Hussain | INSIGHT ADVICE amp SOLUTIONS LLC 64
Predictors of CoQ Act consciously in the interest of patients ndash when no one is looking
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 65
Only four attributes
actually predict a culture of
quality
Leadership Emphasis
Message Credibility
Peer Involvement
Employee Empower-ment
People will change their
behavior if they see the new behavior as
Normal
(1)
Rewarding
(2)
Easy
(3)
Dr W Edwards Demingrsquos - ldquoOut of the crisisrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 66
The journey requires leadership
with Profound Knowledge as a
guide
bull As leaders responsible for system change top management is most in need of profound knowledge
bull Quality is often determined in the boardroom
bull Problems arise when management reacts to common cause or chance variation as if it were special cause variation
bull Prediction based in theory provides a foundation for planning a course of action Plan ndash Do ndash Check ndash Act
bull The leader serves the people with clear vision and guidance to empower them To be empowered is to share ownership in the identity
bull Giving people a certain degree of control over their work fulfills the need for freedom and provides opportunity for taking joy in work
Profound Knowledge as a guide
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 67
Appreciation for a System
Theory of Knowledge
Knowledge about
Variation
Human Behavior -Psychology of Change
A
B
C
D+
Systems Approach for ErrorDeviation Management
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 68
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
Human error models and management J Reason BMJ 320 768ndash770 (2000)
D+
Culture of Error Management परबधनbull Error strain
bull Covering upFear of Errors
bull Anticipation
bull Risk takingAwareness
bull Development QbDRFT
bull Error detection Communication
bull Analyzing errors Correction
Mastery orientation
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 69
Dots amp Connections
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 70
CoQ
1
2
3
QMS
A
B
C
D
GXP Behaviors
X
Y
Z
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 71
Culture of Quality
Normal
Rewarding
Easy
QMS
System
Knowledge
Variation
Behavior
Behavior -GXPs
Fear Removed
Mastery
Awareness
EnvironmentLeadership Emphasis
Message Credibility
Peer Involvement
Employee Empowerment
Connect to CoQ
Connect to GXPs
A Framework and a Tool (for gap analysis)
Preconditions
Rationalization amp Attitude
Pressure amp Incentive
Opportunity ndashlsquoholes in the QMSrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 56
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 57
Attitude towards the behavior
Subjective norm
Perceived behavioral
control
IntentionFuture
Behavior
usually found to predict behavioral intentions with a high degree of accuracy
intentions in combination with perceived behavioral control can account for a considerable proportion of variance in behavior
PastBehavior
Ajen I The theory of planned behavior ORGANIZATIONAL BEHAVIOR AND HUMAN DECISION PROCESSES 50 179-211 (1991)
Heparin tragedy 2007 and 2008
FDA reports 149 deaths with allergic or hypersensitivity symptoms during that period
bull Contaminated heparin from China
QC Testing
bull Initial testing failed to detect the contaminant
Pharmacovigilence
bull Signals in the pharmacovigilence systems responded slowly and
Eventually the severity of reactions associated made it likely that the contamination would be detected
bull too late for those who died or were injured
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 58
Congressman Shimkus When the drug safety system fails people get sick Some die
bull Some of these people are already very vulnerable and proving the cause of harm from impurities adulteration and counterfeits can be elusive
It is hard to detect harm
bull Certainly the companies are obligated to ensure a culture of quality and maintain vigilance as well This reflects a systems approach to safety
FDA inspectors look for a culture of quality at
manufacturing facilities
bull FDA policies led to the failure to inspect the Chinese plantThis system approach wasnt at
play here
bull While it doesnt deny the counterfeit source tries to say that counterfeits didnt cause the reaction as if the adulteration itself was no big deal Is this an acceptable mindset helliphelliphellip
This brings me to China and its quality culture or lack thereof
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 59
ONE HUNDRED TENTH CONGRESS SECOND SESSION APRIL 29 2008 Serial No 110-109
21 CFR PART 211 SUBPARTS -Deviations signal gaps in CoQ
bullGENERAL PROVISIONSA
bullORGANIZATION AND PERSONNELB
bullBUILDINGS AND FACILITIESC
bullEQUIPMENTD
bullCONTROL OF COMPONENTS AND DRUG PRODUCT CONTAINERS AND CLOSURESE
bullPRODUCTION AND PROCESS CONTROLSF
bullPACKAGING AND LABELING CONTROLG
bullHOLDING AND DISTRIBUTIONH
bullLABORATORY CONTROLSI
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 60
For example the combinationhellip
The Power of Habit Why We Do What We Do in Life and Business Charles Duhigg (2012)
bull Scientific methodology
bull Engineering Design
bull Plan-Do-Check-ActConsciously
bull Habits (work to get rid of bad ones)
bull Habits (work to cultivate good one)
bull Keystone habits (Safety Alcoa ALCOA of data integrity)
Subconsciously
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 61
CoQ How
bull What are the predictors of CoQCoQ Manifests by Design -
lsquoquality by designrsquo the foundation
bull 1 2 3When do people change their behaviors
bull A B C D (any body can dance)What makes a QMS effective
bull X Y ZWhen proactive compliance occurs
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 62
Going beyond rules pays
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 63
Human behavior Connecting the Dots With the Right Connectors
GXPs ndash rational behaviors
How proactive compliance is achieved X Y Z
Quality Management System
What makes a QMS reliable A B C D
Culture of Quality
Why people change their behavior 1 2 3
Human Behaviors Beyond GXPs
Predictors of Culture of Quality
Why What and How of Culture of Quality
9192014 copy Ajaz S Hussain | INSIGHT ADVICE amp SOLUTIONS LLC 64
Predictors of CoQ Act consciously in the interest of patients ndash when no one is looking
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 65
Only four attributes
actually predict a culture of
quality
Leadership Emphasis
Message Credibility
Peer Involvement
Employee Empower-ment
People will change their
behavior if they see the new behavior as
Normal
(1)
Rewarding
(2)
Easy
(3)
Dr W Edwards Demingrsquos - ldquoOut of the crisisrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 66
The journey requires leadership
with Profound Knowledge as a
guide
bull As leaders responsible for system change top management is most in need of profound knowledge
bull Quality is often determined in the boardroom
bull Problems arise when management reacts to common cause or chance variation as if it were special cause variation
bull Prediction based in theory provides a foundation for planning a course of action Plan ndash Do ndash Check ndash Act
bull The leader serves the people with clear vision and guidance to empower them To be empowered is to share ownership in the identity
bull Giving people a certain degree of control over their work fulfills the need for freedom and provides opportunity for taking joy in work
Profound Knowledge as a guide
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 67
Appreciation for a System
Theory of Knowledge
Knowledge about
Variation
Human Behavior -Psychology of Change
A
B
C
D+
Systems Approach for ErrorDeviation Management
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 68
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
Human error models and management J Reason BMJ 320 768ndash770 (2000)
D+
Culture of Error Management परबधनbull Error strain
bull Covering upFear of Errors
bull Anticipation
bull Risk takingAwareness
bull Development QbDRFT
bull Error detection Communication
bull Analyzing errors Correction
Mastery orientation
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 69
Dots amp Connections
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 70
CoQ
1
2
3
QMS
A
B
C
D
GXP Behaviors
X
Y
Z
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 71
Culture of Quality
Normal
Rewarding
Easy
QMS
System
Knowledge
Variation
Behavior
Behavior -GXPs
Fear Removed
Mastery
Awareness
EnvironmentLeadership Emphasis
Message Credibility
Peer Involvement
Employee Empowerment
Connect to CoQ
Connect to GXPs
A Framework and a Tool (for gap analysis)
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 57
Attitude towards the behavior
Subjective norm
Perceived behavioral
control
IntentionFuture
Behavior
usually found to predict behavioral intentions with a high degree of accuracy
intentions in combination with perceived behavioral control can account for a considerable proportion of variance in behavior
PastBehavior
Ajen I The theory of planned behavior ORGANIZATIONAL BEHAVIOR AND HUMAN DECISION PROCESSES 50 179-211 (1991)
Heparin tragedy 2007 and 2008
FDA reports 149 deaths with allergic or hypersensitivity symptoms during that period
bull Contaminated heparin from China
QC Testing
bull Initial testing failed to detect the contaminant
Pharmacovigilence
bull Signals in the pharmacovigilence systems responded slowly and
Eventually the severity of reactions associated made it likely that the contamination would be detected
bull too late for those who died or were injured
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 58
Congressman Shimkus When the drug safety system fails people get sick Some die
bull Some of these people are already very vulnerable and proving the cause of harm from impurities adulteration and counterfeits can be elusive
It is hard to detect harm
bull Certainly the companies are obligated to ensure a culture of quality and maintain vigilance as well This reflects a systems approach to safety
FDA inspectors look for a culture of quality at
manufacturing facilities
bull FDA policies led to the failure to inspect the Chinese plantThis system approach wasnt at
play here
bull While it doesnt deny the counterfeit source tries to say that counterfeits didnt cause the reaction as if the adulteration itself was no big deal Is this an acceptable mindset helliphelliphellip
This brings me to China and its quality culture or lack thereof
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 59
ONE HUNDRED TENTH CONGRESS SECOND SESSION APRIL 29 2008 Serial No 110-109
21 CFR PART 211 SUBPARTS -Deviations signal gaps in CoQ
bullGENERAL PROVISIONSA
bullORGANIZATION AND PERSONNELB
bullBUILDINGS AND FACILITIESC
bullEQUIPMENTD
bullCONTROL OF COMPONENTS AND DRUG PRODUCT CONTAINERS AND CLOSURESE
bullPRODUCTION AND PROCESS CONTROLSF
bullPACKAGING AND LABELING CONTROLG
bullHOLDING AND DISTRIBUTIONH
bullLABORATORY CONTROLSI
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 60
For example the combinationhellip
The Power of Habit Why We Do What We Do in Life and Business Charles Duhigg (2012)
bull Scientific methodology
bull Engineering Design
bull Plan-Do-Check-ActConsciously
bull Habits (work to get rid of bad ones)
bull Habits (work to cultivate good one)
bull Keystone habits (Safety Alcoa ALCOA of data integrity)
Subconsciously
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 61
CoQ How
bull What are the predictors of CoQCoQ Manifests by Design -
lsquoquality by designrsquo the foundation
bull 1 2 3When do people change their behaviors
bull A B C D (any body can dance)What makes a QMS effective
bull X Y ZWhen proactive compliance occurs
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 62
Going beyond rules pays
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 63
Human behavior Connecting the Dots With the Right Connectors
GXPs ndash rational behaviors
How proactive compliance is achieved X Y Z
Quality Management System
What makes a QMS reliable A B C D
Culture of Quality
Why people change their behavior 1 2 3
Human Behaviors Beyond GXPs
Predictors of Culture of Quality
Why What and How of Culture of Quality
9192014 copy Ajaz S Hussain | INSIGHT ADVICE amp SOLUTIONS LLC 64
Predictors of CoQ Act consciously in the interest of patients ndash when no one is looking
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 65
Only four attributes
actually predict a culture of
quality
Leadership Emphasis
Message Credibility
Peer Involvement
Employee Empower-ment
People will change their
behavior if they see the new behavior as
Normal
(1)
Rewarding
(2)
Easy
(3)
Dr W Edwards Demingrsquos - ldquoOut of the crisisrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 66
The journey requires leadership
with Profound Knowledge as a
guide
bull As leaders responsible for system change top management is most in need of profound knowledge
bull Quality is often determined in the boardroom
bull Problems arise when management reacts to common cause or chance variation as if it were special cause variation
bull Prediction based in theory provides a foundation for planning a course of action Plan ndash Do ndash Check ndash Act
bull The leader serves the people with clear vision and guidance to empower them To be empowered is to share ownership in the identity
bull Giving people a certain degree of control over their work fulfills the need for freedom and provides opportunity for taking joy in work
Profound Knowledge as a guide
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 67
Appreciation for a System
Theory of Knowledge
Knowledge about
Variation
Human Behavior -Psychology of Change
A
B
C
D+
Systems Approach for ErrorDeviation Management
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 68
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
Human error models and management J Reason BMJ 320 768ndash770 (2000)
D+
Culture of Error Management परबधनbull Error strain
bull Covering upFear of Errors
bull Anticipation
bull Risk takingAwareness
bull Development QbDRFT
bull Error detection Communication
bull Analyzing errors Correction
Mastery orientation
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 69
Dots amp Connections
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 70
CoQ
1
2
3
QMS
A
B
C
D
GXP Behaviors
X
Y
Z
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 71
Culture of Quality
Normal
Rewarding
Easy
QMS
System
Knowledge
Variation
Behavior
Behavior -GXPs
Fear Removed
Mastery
Awareness
EnvironmentLeadership Emphasis
Message Credibility
Peer Involvement
Employee Empowerment
Connect to CoQ
Connect to GXPs
A Framework and a Tool (for gap analysis)
Heparin tragedy 2007 and 2008
FDA reports 149 deaths with allergic or hypersensitivity symptoms during that period
bull Contaminated heparin from China
QC Testing
bull Initial testing failed to detect the contaminant
Pharmacovigilence
bull Signals in the pharmacovigilence systems responded slowly and
Eventually the severity of reactions associated made it likely that the contamination would be detected
bull too late for those who died or were injured
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 58
Congressman Shimkus When the drug safety system fails people get sick Some die
bull Some of these people are already very vulnerable and proving the cause of harm from impurities adulteration and counterfeits can be elusive
It is hard to detect harm
bull Certainly the companies are obligated to ensure a culture of quality and maintain vigilance as well This reflects a systems approach to safety
FDA inspectors look for a culture of quality at
manufacturing facilities
bull FDA policies led to the failure to inspect the Chinese plantThis system approach wasnt at
play here
bull While it doesnt deny the counterfeit source tries to say that counterfeits didnt cause the reaction as if the adulteration itself was no big deal Is this an acceptable mindset helliphelliphellip
This brings me to China and its quality culture or lack thereof
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 59
ONE HUNDRED TENTH CONGRESS SECOND SESSION APRIL 29 2008 Serial No 110-109
21 CFR PART 211 SUBPARTS -Deviations signal gaps in CoQ
bullGENERAL PROVISIONSA
bullORGANIZATION AND PERSONNELB
bullBUILDINGS AND FACILITIESC
bullEQUIPMENTD
bullCONTROL OF COMPONENTS AND DRUG PRODUCT CONTAINERS AND CLOSURESE
bullPRODUCTION AND PROCESS CONTROLSF
bullPACKAGING AND LABELING CONTROLG
bullHOLDING AND DISTRIBUTIONH
bullLABORATORY CONTROLSI
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 60
For example the combinationhellip
The Power of Habit Why We Do What We Do in Life and Business Charles Duhigg (2012)
bull Scientific methodology
bull Engineering Design
bull Plan-Do-Check-ActConsciously
bull Habits (work to get rid of bad ones)
bull Habits (work to cultivate good one)
bull Keystone habits (Safety Alcoa ALCOA of data integrity)
Subconsciously
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 61
CoQ How
bull What are the predictors of CoQCoQ Manifests by Design -
lsquoquality by designrsquo the foundation
bull 1 2 3When do people change their behaviors
bull A B C D (any body can dance)What makes a QMS effective
bull X Y ZWhen proactive compliance occurs
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 62
Going beyond rules pays
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 63
Human behavior Connecting the Dots With the Right Connectors
GXPs ndash rational behaviors
How proactive compliance is achieved X Y Z
Quality Management System
What makes a QMS reliable A B C D
Culture of Quality
Why people change their behavior 1 2 3
Human Behaviors Beyond GXPs
Predictors of Culture of Quality
Why What and How of Culture of Quality
9192014 copy Ajaz S Hussain | INSIGHT ADVICE amp SOLUTIONS LLC 64
Predictors of CoQ Act consciously in the interest of patients ndash when no one is looking
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 65
Only four attributes
actually predict a culture of
quality
Leadership Emphasis
Message Credibility
Peer Involvement
Employee Empower-ment
People will change their
behavior if they see the new behavior as
Normal
(1)
Rewarding
(2)
Easy
(3)
Dr W Edwards Demingrsquos - ldquoOut of the crisisrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 66
The journey requires leadership
with Profound Knowledge as a
guide
bull As leaders responsible for system change top management is most in need of profound knowledge
bull Quality is often determined in the boardroom
bull Problems arise when management reacts to common cause or chance variation as if it were special cause variation
bull Prediction based in theory provides a foundation for planning a course of action Plan ndash Do ndash Check ndash Act
bull The leader serves the people with clear vision and guidance to empower them To be empowered is to share ownership in the identity
bull Giving people a certain degree of control over their work fulfills the need for freedom and provides opportunity for taking joy in work
Profound Knowledge as a guide
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 67
Appreciation for a System
Theory of Knowledge
Knowledge about
Variation
Human Behavior -Psychology of Change
A
B
C
D+
Systems Approach for ErrorDeviation Management
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 68
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
Human error models and management J Reason BMJ 320 768ndash770 (2000)
D+
Culture of Error Management परबधनbull Error strain
bull Covering upFear of Errors
bull Anticipation
bull Risk takingAwareness
bull Development QbDRFT
bull Error detection Communication
bull Analyzing errors Correction
Mastery orientation
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 69
Dots amp Connections
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 70
CoQ
1
2
3
QMS
A
B
C
D
GXP Behaviors
X
Y
Z
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 71
Culture of Quality
Normal
Rewarding
Easy
QMS
System
Knowledge
Variation
Behavior
Behavior -GXPs
Fear Removed
Mastery
Awareness
EnvironmentLeadership Emphasis
Message Credibility
Peer Involvement
Employee Empowerment
Connect to CoQ
Connect to GXPs
A Framework and a Tool (for gap analysis)
Congressman Shimkus When the drug safety system fails people get sick Some die
bull Some of these people are already very vulnerable and proving the cause of harm from impurities adulteration and counterfeits can be elusive
It is hard to detect harm
bull Certainly the companies are obligated to ensure a culture of quality and maintain vigilance as well This reflects a systems approach to safety
FDA inspectors look for a culture of quality at
manufacturing facilities
bull FDA policies led to the failure to inspect the Chinese plantThis system approach wasnt at
play here
bull While it doesnt deny the counterfeit source tries to say that counterfeits didnt cause the reaction as if the adulteration itself was no big deal Is this an acceptable mindset helliphelliphellip
This brings me to China and its quality culture or lack thereof
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 59
ONE HUNDRED TENTH CONGRESS SECOND SESSION APRIL 29 2008 Serial No 110-109
21 CFR PART 211 SUBPARTS -Deviations signal gaps in CoQ
bullGENERAL PROVISIONSA
bullORGANIZATION AND PERSONNELB
bullBUILDINGS AND FACILITIESC
bullEQUIPMENTD
bullCONTROL OF COMPONENTS AND DRUG PRODUCT CONTAINERS AND CLOSURESE
bullPRODUCTION AND PROCESS CONTROLSF
bullPACKAGING AND LABELING CONTROLG
bullHOLDING AND DISTRIBUTIONH
bullLABORATORY CONTROLSI
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 60
For example the combinationhellip
The Power of Habit Why We Do What We Do in Life and Business Charles Duhigg (2012)
bull Scientific methodology
bull Engineering Design
bull Plan-Do-Check-ActConsciously
bull Habits (work to get rid of bad ones)
bull Habits (work to cultivate good one)
bull Keystone habits (Safety Alcoa ALCOA of data integrity)
Subconsciously
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 61
CoQ How
bull What are the predictors of CoQCoQ Manifests by Design -
lsquoquality by designrsquo the foundation
bull 1 2 3When do people change their behaviors
bull A B C D (any body can dance)What makes a QMS effective
bull X Y ZWhen proactive compliance occurs
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 62
Going beyond rules pays
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 63
Human behavior Connecting the Dots With the Right Connectors
GXPs ndash rational behaviors
How proactive compliance is achieved X Y Z
Quality Management System
What makes a QMS reliable A B C D
Culture of Quality
Why people change their behavior 1 2 3
Human Behaviors Beyond GXPs
Predictors of Culture of Quality
Why What and How of Culture of Quality
9192014 copy Ajaz S Hussain | INSIGHT ADVICE amp SOLUTIONS LLC 64
Predictors of CoQ Act consciously in the interest of patients ndash when no one is looking
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 65
Only four attributes
actually predict a culture of
quality
Leadership Emphasis
Message Credibility
Peer Involvement
Employee Empower-ment
People will change their
behavior if they see the new behavior as
Normal
(1)
Rewarding
(2)
Easy
(3)
Dr W Edwards Demingrsquos - ldquoOut of the crisisrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 66
The journey requires leadership
with Profound Knowledge as a
guide
bull As leaders responsible for system change top management is most in need of profound knowledge
bull Quality is often determined in the boardroom
bull Problems arise when management reacts to common cause or chance variation as if it were special cause variation
bull Prediction based in theory provides a foundation for planning a course of action Plan ndash Do ndash Check ndash Act
bull The leader serves the people with clear vision and guidance to empower them To be empowered is to share ownership in the identity
bull Giving people a certain degree of control over their work fulfills the need for freedom and provides opportunity for taking joy in work
Profound Knowledge as a guide
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 67
Appreciation for a System
Theory of Knowledge
Knowledge about
Variation
Human Behavior -Psychology of Change
A
B
C
D+
Systems Approach for ErrorDeviation Management
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 68
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
Human error models and management J Reason BMJ 320 768ndash770 (2000)
D+
Culture of Error Management परबधनbull Error strain
bull Covering upFear of Errors
bull Anticipation
bull Risk takingAwareness
bull Development QbDRFT
bull Error detection Communication
bull Analyzing errors Correction
Mastery orientation
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 69
Dots amp Connections
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 70
CoQ
1
2
3
QMS
A
B
C
D
GXP Behaviors
X
Y
Z
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 71
Culture of Quality
Normal
Rewarding
Easy
QMS
System
Knowledge
Variation
Behavior
Behavior -GXPs
Fear Removed
Mastery
Awareness
EnvironmentLeadership Emphasis
Message Credibility
Peer Involvement
Employee Empowerment
Connect to CoQ
Connect to GXPs
A Framework and a Tool (for gap analysis)
21 CFR PART 211 SUBPARTS -Deviations signal gaps in CoQ
bullGENERAL PROVISIONSA
bullORGANIZATION AND PERSONNELB
bullBUILDINGS AND FACILITIESC
bullEQUIPMENTD
bullCONTROL OF COMPONENTS AND DRUG PRODUCT CONTAINERS AND CLOSURESE
bullPRODUCTION AND PROCESS CONTROLSF
bullPACKAGING AND LABELING CONTROLG
bullHOLDING AND DISTRIBUTIONH
bullLABORATORY CONTROLSI
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 60
For example the combinationhellip
The Power of Habit Why We Do What We Do in Life and Business Charles Duhigg (2012)
bull Scientific methodology
bull Engineering Design
bull Plan-Do-Check-ActConsciously
bull Habits (work to get rid of bad ones)
bull Habits (work to cultivate good one)
bull Keystone habits (Safety Alcoa ALCOA of data integrity)
Subconsciously
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 61
CoQ How
bull What are the predictors of CoQCoQ Manifests by Design -
lsquoquality by designrsquo the foundation
bull 1 2 3When do people change their behaviors
bull A B C D (any body can dance)What makes a QMS effective
bull X Y ZWhen proactive compliance occurs
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 62
Going beyond rules pays
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 63
Human behavior Connecting the Dots With the Right Connectors
GXPs ndash rational behaviors
How proactive compliance is achieved X Y Z
Quality Management System
What makes a QMS reliable A B C D
Culture of Quality
Why people change their behavior 1 2 3
Human Behaviors Beyond GXPs
Predictors of Culture of Quality
Why What and How of Culture of Quality
9192014 copy Ajaz S Hussain | INSIGHT ADVICE amp SOLUTIONS LLC 64
Predictors of CoQ Act consciously in the interest of patients ndash when no one is looking
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 65
Only four attributes
actually predict a culture of
quality
Leadership Emphasis
Message Credibility
Peer Involvement
Employee Empower-ment
People will change their
behavior if they see the new behavior as
Normal
(1)
Rewarding
(2)
Easy
(3)
Dr W Edwards Demingrsquos - ldquoOut of the crisisrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 66
The journey requires leadership
with Profound Knowledge as a
guide
bull As leaders responsible for system change top management is most in need of profound knowledge
bull Quality is often determined in the boardroom
bull Problems arise when management reacts to common cause or chance variation as if it were special cause variation
bull Prediction based in theory provides a foundation for planning a course of action Plan ndash Do ndash Check ndash Act
bull The leader serves the people with clear vision and guidance to empower them To be empowered is to share ownership in the identity
bull Giving people a certain degree of control over their work fulfills the need for freedom and provides opportunity for taking joy in work
Profound Knowledge as a guide
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 67
Appreciation for a System
Theory of Knowledge
Knowledge about
Variation
Human Behavior -Psychology of Change
A
B
C
D+
Systems Approach for ErrorDeviation Management
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 68
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
Human error models and management J Reason BMJ 320 768ndash770 (2000)
D+
Culture of Error Management परबधनbull Error strain
bull Covering upFear of Errors
bull Anticipation
bull Risk takingAwareness
bull Development QbDRFT
bull Error detection Communication
bull Analyzing errors Correction
Mastery orientation
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 69
Dots amp Connections
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 70
CoQ
1
2
3
QMS
A
B
C
D
GXP Behaviors
X
Y
Z
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 71
Culture of Quality
Normal
Rewarding
Easy
QMS
System
Knowledge
Variation
Behavior
Behavior -GXPs
Fear Removed
Mastery
Awareness
EnvironmentLeadership Emphasis
Message Credibility
Peer Involvement
Employee Empowerment
Connect to CoQ
Connect to GXPs
A Framework and a Tool (for gap analysis)
The Power of Habit Why We Do What We Do in Life and Business Charles Duhigg (2012)
bull Scientific methodology
bull Engineering Design
bull Plan-Do-Check-ActConsciously
bull Habits (work to get rid of bad ones)
bull Habits (work to cultivate good one)
bull Keystone habits (Safety Alcoa ALCOA of data integrity)
Subconsciously
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 61
CoQ How
bull What are the predictors of CoQCoQ Manifests by Design -
lsquoquality by designrsquo the foundation
bull 1 2 3When do people change their behaviors
bull A B C D (any body can dance)What makes a QMS effective
bull X Y ZWhen proactive compliance occurs
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 62
Going beyond rules pays
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 63
Human behavior Connecting the Dots With the Right Connectors
GXPs ndash rational behaviors
How proactive compliance is achieved X Y Z
Quality Management System
What makes a QMS reliable A B C D
Culture of Quality
Why people change their behavior 1 2 3
Human Behaviors Beyond GXPs
Predictors of Culture of Quality
Why What and How of Culture of Quality
9192014 copy Ajaz S Hussain | INSIGHT ADVICE amp SOLUTIONS LLC 64
Predictors of CoQ Act consciously in the interest of patients ndash when no one is looking
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 65
Only four attributes
actually predict a culture of
quality
Leadership Emphasis
Message Credibility
Peer Involvement
Employee Empower-ment
People will change their
behavior if they see the new behavior as
Normal
(1)
Rewarding
(2)
Easy
(3)
Dr W Edwards Demingrsquos - ldquoOut of the crisisrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 66
The journey requires leadership
with Profound Knowledge as a
guide
bull As leaders responsible for system change top management is most in need of profound knowledge
bull Quality is often determined in the boardroom
bull Problems arise when management reacts to common cause or chance variation as if it were special cause variation
bull Prediction based in theory provides a foundation for planning a course of action Plan ndash Do ndash Check ndash Act
bull The leader serves the people with clear vision and guidance to empower them To be empowered is to share ownership in the identity
bull Giving people a certain degree of control over their work fulfills the need for freedom and provides opportunity for taking joy in work
Profound Knowledge as a guide
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 67
Appreciation for a System
Theory of Knowledge
Knowledge about
Variation
Human Behavior -Psychology of Change
A
B
C
D+
Systems Approach for ErrorDeviation Management
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 68
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
Human error models and management J Reason BMJ 320 768ndash770 (2000)
D+
Culture of Error Management परबधनbull Error strain
bull Covering upFear of Errors
bull Anticipation
bull Risk takingAwareness
bull Development QbDRFT
bull Error detection Communication
bull Analyzing errors Correction
Mastery orientation
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 69
Dots amp Connections
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 70
CoQ
1
2
3
QMS
A
B
C
D
GXP Behaviors
X
Y
Z
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 71
Culture of Quality
Normal
Rewarding
Easy
QMS
System
Knowledge
Variation
Behavior
Behavior -GXPs
Fear Removed
Mastery
Awareness
EnvironmentLeadership Emphasis
Message Credibility
Peer Involvement
Employee Empowerment
Connect to CoQ
Connect to GXPs
A Framework and a Tool (for gap analysis)
CoQ How
bull What are the predictors of CoQCoQ Manifests by Design -
lsquoquality by designrsquo the foundation
bull 1 2 3When do people change their behaviors
bull A B C D (any body can dance)What makes a QMS effective
bull X Y ZWhen proactive compliance occurs
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 62
Going beyond rules pays
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 63
Human behavior Connecting the Dots With the Right Connectors
GXPs ndash rational behaviors
How proactive compliance is achieved X Y Z
Quality Management System
What makes a QMS reliable A B C D
Culture of Quality
Why people change their behavior 1 2 3
Human Behaviors Beyond GXPs
Predictors of Culture of Quality
Why What and How of Culture of Quality
9192014 copy Ajaz S Hussain | INSIGHT ADVICE amp SOLUTIONS LLC 64
Predictors of CoQ Act consciously in the interest of patients ndash when no one is looking
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 65
Only four attributes
actually predict a culture of
quality
Leadership Emphasis
Message Credibility
Peer Involvement
Employee Empower-ment
People will change their
behavior if they see the new behavior as
Normal
(1)
Rewarding
(2)
Easy
(3)
Dr W Edwards Demingrsquos - ldquoOut of the crisisrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 66
The journey requires leadership
with Profound Knowledge as a
guide
bull As leaders responsible for system change top management is most in need of profound knowledge
bull Quality is often determined in the boardroom
bull Problems arise when management reacts to common cause or chance variation as if it were special cause variation
bull Prediction based in theory provides a foundation for planning a course of action Plan ndash Do ndash Check ndash Act
bull The leader serves the people with clear vision and guidance to empower them To be empowered is to share ownership in the identity
bull Giving people a certain degree of control over their work fulfills the need for freedom and provides opportunity for taking joy in work
Profound Knowledge as a guide
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 67
Appreciation for a System
Theory of Knowledge
Knowledge about
Variation
Human Behavior -Psychology of Change
A
B
C
D+
Systems Approach for ErrorDeviation Management
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 68
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
Human error models and management J Reason BMJ 320 768ndash770 (2000)
D+
Culture of Error Management परबधनbull Error strain
bull Covering upFear of Errors
bull Anticipation
bull Risk takingAwareness
bull Development QbDRFT
bull Error detection Communication
bull Analyzing errors Correction
Mastery orientation
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 69
Dots amp Connections
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 70
CoQ
1
2
3
QMS
A
B
C
D
GXP Behaviors
X
Y
Z
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 71
Culture of Quality
Normal
Rewarding
Easy
QMS
System
Knowledge
Variation
Behavior
Behavior -GXPs
Fear Removed
Mastery
Awareness
EnvironmentLeadership Emphasis
Message Credibility
Peer Involvement
Employee Empowerment
Connect to CoQ
Connect to GXPs
A Framework and a Tool (for gap analysis)
Going beyond rules pays
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 63
Human behavior Connecting the Dots With the Right Connectors
GXPs ndash rational behaviors
How proactive compliance is achieved X Y Z
Quality Management System
What makes a QMS reliable A B C D
Culture of Quality
Why people change their behavior 1 2 3
Human Behaviors Beyond GXPs
Predictors of Culture of Quality
Why What and How of Culture of Quality
9192014 copy Ajaz S Hussain | INSIGHT ADVICE amp SOLUTIONS LLC 64
Predictors of CoQ Act consciously in the interest of patients ndash when no one is looking
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 65
Only four attributes
actually predict a culture of
quality
Leadership Emphasis
Message Credibility
Peer Involvement
Employee Empower-ment
People will change their
behavior if they see the new behavior as
Normal
(1)
Rewarding
(2)
Easy
(3)
Dr W Edwards Demingrsquos - ldquoOut of the crisisrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 66
The journey requires leadership
with Profound Knowledge as a
guide
bull As leaders responsible for system change top management is most in need of profound knowledge
bull Quality is often determined in the boardroom
bull Problems arise when management reacts to common cause or chance variation as if it were special cause variation
bull Prediction based in theory provides a foundation for planning a course of action Plan ndash Do ndash Check ndash Act
bull The leader serves the people with clear vision and guidance to empower them To be empowered is to share ownership in the identity
bull Giving people a certain degree of control over their work fulfills the need for freedom and provides opportunity for taking joy in work
Profound Knowledge as a guide
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 67
Appreciation for a System
Theory of Knowledge
Knowledge about
Variation
Human Behavior -Psychology of Change
A
B
C
D+
Systems Approach for ErrorDeviation Management
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 68
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
Human error models and management J Reason BMJ 320 768ndash770 (2000)
D+
Culture of Error Management परबधनbull Error strain
bull Covering upFear of Errors
bull Anticipation
bull Risk takingAwareness
bull Development QbDRFT
bull Error detection Communication
bull Analyzing errors Correction
Mastery orientation
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 69
Dots amp Connections
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 70
CoQ
1
2
3
QMS
A
B
C
D
GXP Behaviors
X
Y
Z
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 71
Culture of Quality
Normal
Rewarding
Easy
QMS
System
Knowledge
Variation
Behavior
Behavior -GXPs
Fear Removed
Mastery
Awareness
EnvironmentLeadership Emphasis
Message Credibility
Peer Involvement
Employee Empowerment
Connect to CoQ
Connect to GXPs
A Framework and a Tool (for gap analysis)
Human behavior Connecting the Dots With the Right Connectors
GXPs ndash rational behaviors
How proactive compliance is achieved X Y Z
Quality Management System
What makes a QMS reliable A B C D
Culture of Quality
Why people change their behavior 1 2 3
Human Behaviors Beyond GXPs
Predictors of Culture of Quality
Why What and How of Culture of Quality
9192014 copy Ajaz S Hussain | INSIGHT ADVICE amp SOLUTIONS LLC 64
Predictors of CoQ Act consciously in the interest of patients ndash when no one is looking
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 65
Only four attributes
actually predict a culture of
quality
Leadership Emphasis
Message Credibility
Peer Involvement
Employee Empower-ment
People will change their
behavior if they see the new behavior as
Normal
(1)
Rewarding
(2)
Easy
(3)
Dr W Edwards Demingrsquos - ldquoOut of the crisisrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 66
The journey requires leadership
with Profound Knowledge as a
guide
bull As leaders responsible for system change top management is most in need of profound knowledge
bull Quality is often determined in the boardroom
bull Problems arise when management reacts to common cause or chance variation as if it were special cause variation
bull Prediction based in theory provides a foundation for planning a course of action Plan ndash Do ndash Check ndash Act
bull The leader serves the people with clear vision and guidance to empower them To be empowered is to share ownership in the identity
bull Giving people a certain degree of control over their work fulfills the need for freedom and provides opportunity for taking joy in work
Profound Knowledge as a guide
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 67
Appreciation for a System
Theory of Knowledge
Knowledge about
Variation
Human Behavior -Psychology of Change
A
B
C
D+
Systems Approach for ErrorDeviation Management
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 68
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
Human error models and management J Reason BMJ 320 768ndash770 (2000)
D+
Culture of Error Management परबधनbull Error strain
bull Covering upFear of Errors
bull Anticipation
bull Risk takingAwareness
bull Development QbDRFT
bull Error detection Communication
bull Analyzing errors Correction
Mastery orientation
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 69
Dots amp Connections
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 70
CoQ
1
2
3
QMS
A
B
C
D
GXP Behaviors
X
Y
Z
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 71
Culture of Quality
Normal
Rewarding
Easy
QMS
System
Knowledge
Variation
Behavior
Behavior -GXPs
Fear Removed
Mastery
Awareness
EnvironmentLeadership Emphasis
Message Credibility
Peer Involvement
Employee Empowerment
Connect to CoQ
Connect to GXPs
A Framework and a Tool (for gap analysis)
Predictors of CoQ Act consciously in the interest of patients ndash when no one is looking
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 65
Only four attributes
actually predict a culture of
quality
Leadership Emphasis
Message Credibility
Peer Involvement
Employee Empower-ment
People will change their
behavior if they see the new behavior as
Normal
(1)
Rewarding
(2)
Easy
(3)
Dr W Edwards Demingrsquos - ldquoOut of the crisisrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 66
The journey requires leadership
with Profound Knowledge as a
guide
bull As leaders responsible for system change top management is most in need of profound knowledge
bull Quality is often determined in the boardroom
bull Problems arise when management reacts to common cause or chance variation as if it were special cause variation
bull Prediction based in theory provides a foundation for planning a course of action Plan ndash Do ndash Check ndash Act
bull The leader serves the people with clear vision and guidance to empower them To be empowered is to share ownership in the identity
bull Giving people a certain degree of control over their work fulfills the need for freedom and provides opportunity for taking joy in work
Profound Knowledge as a guide
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 67
Appreciation for a System
Theory of Knowledge
Knowledge about
Variation
Human Behavior -Psychology of Change
A
B
C
D+
Systems Approach for ErrorDeviation Management
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 68
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
Human error models and management J Reason BMJ 320 768ndash770 (2000)
D+
Culture of Error Management परबधनbull Error strain
bull Covering upFear of Errors
bull Anticipation
bull Risk takingAwareness
bull Development QbDRFT
bull Error detection Communication
bull Analyzing errors Correction
Mastery orientation
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 69
Dots amp Connections
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 70
CoQ
1
2
3
QMS
A
B
C
D
GXP Behaviors
X
Y
Z
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 71
Culture of Quality
Normal
Rewarding
Easy
QMS
System
Knowledge
Variation
Behavior
Behavior -GXPs
Fear Removed
Mastery
Awareness
EnvironmentLeadership Emphasis
Message Credibility
Peer Involvement
Employee Empowerment
Connect to CoQ
Connect to GXPs
A Framework and a Tool (for gap analysis)
Dr W Edwards Demingrsquos - ldquoOut of the crisisrdquo
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 66
The journey requires leadership
with Profound Knowledge as a
guide
bull As leaders responsible for system change top management is most in need of profound knowledge
bull Quality is often determined in the boardroom
bull Problems arise when management reacts to common cause or chance variation as if it were special cause variation
bull Prediction based in theory provides a foundation for planning a course of action Plan ndash Do ndash Check ndash Act
bull The leader serves the people with clear vision and guidance to empower them To be empowered is to share ownership in the identity
bull Giving people a certain degree of control over their work fulfills the need for freedom and provides opportunity for taking joy in work
Profound Knowledge as a guide
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 67
Appreciation for a System
Theory of Knowledge
Knowledge about
Variation
Human Behavior -Psychology of Change
A
B
C
D+
Systems Approach for ErrorDeviation Management
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 68
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
Human error models and management J Reason BMJ 320 768ndash770 (2000)
D+
Culture of Error Management परबधनbull Error strain
bull Covering upFear of Errors
bull Anticipation
bull Risk takingAwareness
bull Development QbDRFT
bull Error detection Communication
bull Analyzing errors Correction
Mastery orientation
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 69
Dots amp Connections
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 70
CoQ
1
2
3
QMS
A
B
C
D
GXP Behaviors
X
Y
Z
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 71
Culture of Quality
Normal
Rewarding
Easy
QMS
System
Knowledge
Variation
Behavior
Behavior -GXPs
Fear Removed
Mastery
Awareness
EnvironmentLeadership Emphasis
Message Credibility
Peer Involvement
Employee Empowerment
Connect to CoQ
Connect to GXPs
A Framework and a Tool (for gap analysis)
Profound Knowledge as a guide
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 67
Appreciation for a System
Theory of Knowledge
Knowledge about
Variation
Human Behavior -Psychology of Change
A
B
C
D+
Systems Approach for ErrorDeviation Management
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 68
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
Human error models and management J Reason BMJ 320 768ndash770 (2000)
D+
Culture of Error Management परबधनbull Error strain
bull Covering upFear of Errors
bull Anticipation
bull Risk takingAwareness
bull Development QbDRFT
bull Error detection Communication
bull Analyzing errors Correction
Mastery orientation
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 69
Dots amp Connections
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 70
CoQ
1
2
3
QMS
A
B
C
D
GXP Behaviors
X
Y
Z
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 71
Culture of Quality
Normal
Rewarding
Easy
QMS
System
Knowledge
Variation
Behavior
Behavior -GXPs
Fear Removed
Mastery
Awareness
EnvironmentLeadership Emphasis
Message Credibility
Peer Involvement
Employee Empowerment
Connect to CoQ
Connect to GXPs
A Framework and a Tool (for gap analysis)
Systems Approach for ErrorDeviation Management
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 68
Organization (Policies amp Sr Mgmt)
Technology(Constraints amp Controls)
Individual (Training amp Certification)
Team amp Supervisor (Soft Defenses)
Defenses(Quality Management System)
Error
Latent अपरकट conditions Goal conflicts amp mixed messages
Design flaws
Production pressures
Fear of error
Human error models and management J Reason BMJ 320 768ndash770 (2000)
D+
Culture of Error Management परबधनbull Error strain
bull Covering upFear of Errors
bull Anticipation
bull Risk takingAwareness
bull Development QbDRFT
bull Error detection Communication
bull Analyzing errors Correction
Mastery orientation
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 69
Dots amp Connections
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 70
CoQ
1
2
3
QMS
A
B
C
D
GXP Behaviors
X
Y
Z
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 71
Culture of Quality
Normal
Rewarding
Easy
QMS
System
Knowledge
Variation
Behavior
Behavior -GXPs
Fear Removed
Mastery
Awareness
EnvironmentLeadership Emphasis
Message Credibility
Peer Involvement
Employee Empowerment
Connect to CoQ
Connect to GXPs
A Framework and a Tool (for gap analysis)
Culture of Error Management परबधनbull Error strain
bull Covering upFear of Errors
bull Anticipation
bull Risk takingAwareness
bull Development QbDRFT
bull Error detection Communication
bull Analyzing errors Correction
Mastery orientation
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 69
Dots amp Connections
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 70
CoQ
1
2
3
QMS
A
B
C
D
GXP Behaviors
X
Y
Z
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 71
Culture of Quality
Normal
Rewarding
Easy
QMS
System
Knowledge
Variation
Behavior
Behavior -GXPs
Fear Removed
Mastery
Awareness
EnvironmentLeadership Emphasis
Message Credibility
Peer Involvement
Employee Empowerment
Connect to CoQ
Connect to GXPs
A Framework and a Tool (for gap analysis)
Dots amp Connections
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 70
CoQ
1
2
3
QMS
A
B
C
D
GXP Behaviors
X
Y
Z
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 71
Culture of Quality
Normal
Rewarding
Easy
QMS
System
Knowledge
Variation
Behavior
Behavior -GXPs
Fear Removed
Mastery
Awareness
EnvironmentLeadership Emphasis
Message Credibility
Peer Involvement
Employee Empowerment
Connect to CoQ
Connect to GXPs
A Framework and a Tool (for gap analysis)
3142015 copy Ajaz S Hussain | Insight Advice amp Solutions LLC 71
Culture of Quality
Normal
Rewarding
Easy
QMS
System
Knowledge
Variation
Behavior
Behavior -GXPs
Fear Removed
Mastery
Awareness
EnvironmentLeadership Emphasis
Message Credibility
Peer Involvement
Employee Empowerment
Connect to CoQ
Connect to GXPs
A Framework and a Tool (for gap analysis)