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The roots of this book extend back to the experiences
and on-the-job training I had in the corporate Quality Assurance
Division at Eli Lilly and Company. There, I had the opportunity of
learning good manufacturing practice and quality auditing techniques
from experienced colleagues. In the U.S., and overseas, I was able
to apply these skills as we audited manufacturing and support sites.
The more recent catalyst for this book was being
asked to create a workshop to teach auditing skills to pharmaceutical
industry personnel. In designing the workshop, I talked with experienced
auditors as well as auditees. I tried to understand the thought process
used by auditors-something expert auditors do not consciously ponder;
they simply audit.
Nobody is born an auditor -- it requires
basic knowledge and several different skill sets. To be a successful
auditor, you need to:
-
Have technical and regulatory knowledge and
be able to apply it in various situations;
-
Organize your thoughts and actions, following
a defined process;
-
Communicate effectively orally and in writing;
and
-
Work well with people.
This book is written for someone who is new to
GMP auditing; it covers topics related to these four competencies,
which will help make you successful. You will find the rationale
for why auditing is an important quality tool, along with the audit
cycle broken into five distinct phases. The basic framework for auditing
(the phases of preparation, conducting the audit, reporting, following-up)
can be found in almost any book on the ISO 9000 quality system; in
this book an additional phase, on analysis, is included.
Two other pieces that have been added are the Types
of Audit and Audit Approaches. These are meant to give more structure
to the questions, "What is the purpose of this audit?" and "What
should I be looking for?" The categories and items presented in the
Type of Audits and Audit Approaches are not meant to be definitive.
They are guides that should be expanded upon as needed and kept current.
In Appendix 2, in the back of the book, are responses
to a questionnaire from experienced auditors. Their personal insights
are valuable for new auditors and will trigger memories for those
who have been auditing for many years.
While this book is aimed at personnel new to GMP
auditing, many of the concepts can be used in other areas. For example,
currently, as I create GMP training programs and courses for clients,
I do not formally audit firms. Instead, other training professionals
and I conduct a needs analysis to define desired performance; examine
actual performance; and identify the knowledge, skills, and performance
tools/support that people need to do their jobs. This process has
many elements in common with auditing; a background in GMP auditing
has made this immensely easier for me.
To be successful at auditing you need more than
this book-you need to audit. Working with other experienced auditors
will help you apply the information from this book and allow you
to develop the skills and instincts you need. Do not be alarmed if
the seasoned auditor you work with doesn't have a detailed audit
plan written up or a loose-leaf binder filled with checklists. When
you have done dozens of audits every year for a decade, you may not
need them either. Early in your career as an auditor, however, plans
and checklists are tools you need to use and continually refine.
You will find that the tools will not only help you audit, but will
increase your professionalism and credibility with the audit sponsor
and the auditee.
GMP auditing is a tremendous way to learn more
about the drug and medical device industry. It also is important
from the consumer/patient side. Every time you audit, you help assure
that the products our families might use are safe, properly identified,
pure, and of the highest possible quality. Please do a good job.
We're depending on you.
Jim Vesper
May 1997
| viii |
|
Dedication |
| ix |
|
Preface |
| xiii |
|
Acknowledgments |
| 1 |
|
1. What Is a GMP or Quality Audit? |
| 1 |
|
Goals |
| 6 |
|
Why Conduct GMP Audits? |
| 8 |
|
Terms Related to GMP Audits |
| 10 |
|
What an Audit Is Not |
| 11 |
|
Conclusion |
| 13 |
|
2. The Big Picture |
| 13 |
|
Goals |
| 13 |
|
The Audit as a Quality
System Component |
| 14 |
|
Five Phases of the Audit
Process |
| 17 |
|
Management Support |
| 17 |
|
Monitoring Improvement |
| 17 |
|
Outcomes of the Audit |
| 18 |
|
Conclusion |
| 19 |
|
3. Regulatory Requirements and Expectations
for GMP Audits |
| 19 |
|
Goals |
| 20 |
|
Requirements vs. Expectations |
| 30 |
|
Conclusion |
| 31 |
|
4. Your Auditing Policy and SOP |
| 31 |
|
Goals |
| 32 |
|
Policies and Procedures |
| 33 |
|
Regulatory Inspection
of GMP Auditing Policies and SOPs |
| 35 |
|
Certification of an Audit |
| 36 |
|
Regulatory Inspection
of Vendor Audits |
| 38 |
|
Conclusion |
| 39 |
|
5. Types of Audits |
| 39 |
|
Goals |
| 39 |
|
Types of Audits |
| 40 |
|
Making Use of Various
Types of Audits |
| 47 |
|
Conclusion |
| 49 |
|
6. Audit Approaches |
| 49 |
|
Goals |
| 49 |
|
What Is an Audit Approach? |
| 52 |
|
Audit Approaches: Quality
System |
| 54 |
|
Audit Approaches: Documentation
System |
| 56 |
|
Audit Approaches: Deviations |
| 57 |
|
Audit Approaches: Validation
and Change Control |
| 60 |
|
Audit Approaches: Stability
Testing and Monitoring |
| 61 |
|
Audit Approaches: Complaints
(Product) |
| 62 |
|
Audit Approaches: Data
Quality and Integrity |
| 63 |
|
Audit Approaches: Laboratories
(Microbiological, Analytical, and Development) |
| 64 |
|
Audit Approaches: Vendor
(Supplier) Requirements |
| 67 |
|
Audit Approaches: Facilities
and Equipment |
| 69 |
|
Audit Approaches: Computer
Systems |
| 70 |
|
Audit Approaches: Commercialized
Product |
| 71 |
|
Audit Approaches: Investigational
Product |
| 72 |
|
Audit Approaches: General
GMP Operations |
| 76 |
|
Conclusion |
| 77 |
|
7. Auditor Qualifications and Skills |
| 77 |
|
Goals |
| 78 |
|
What Is Required of a
GMP Auditor? |
| 80 |
|
Three Areas of Competence
for Auditors |
| 84 |
|
Ethics and Integrity |
| 85 |
|
Becoming a Qualified Auditor |
| 85 |
|
What to Expect as an Auditor |
| 87 |
|
Conclusion |
| 89 |
|
8. Phase I: Preparation |
| 89 |
|
Goals |
| 90 |
|
Who Is Involved |
| 90 |
|
When It Is Done |
| 90 |
|
Key Tasks |
| 91 |
|
The Audit Plan |
| 107 |
|
Milestones for Phase I:
Preparation |
| 109 |
|
9. Phase II: Conduct the Audit |
| 109 |
|
Goals |
| 110 |
|
Who Is Involved |
| 110 |
|
When It Is Done |
| 110 |
|
The Evaluation Process |
| 111 |
|
The Desk Audit |
| 112 |
|
The Site Audit |
| 112 |
|
Site Audit Agenda |
| 124 |
|
Milestones for Phase II:
Conduct the Audit |
| 125 |
|
10. Interviewing Auditees |
| 125 |
|
Goals |
| 126 |
|
What Is an Interview? |
| 127 |
|
Interview Success |
| 127 |
|
The First Critical Seconds
of the Interview |
| 128 |
|
Spoken Communication |
| 129 |
|
Other Visual Cues |
| 132 |
|
Conclusion |
| 133 |
|
11. Phase III: Analyzing Audit Data |
| 133 |
|
Goals |
| 134 |
|
Who Is Involved |
| 134 |
|
When It Is Done |
| 135 |
|
Analysis While Collecting
Data |
| 137 |
|
Isolated vs. Systemic
Deficiencies |
| 140 |
|
Other Analytical Tools |
| 141 |
|
Self-Analysis by Team
Members |
| 141 |
|
Milestones for Phase III:
Analysis |
| 143 |
|
12. Phase IV: The Audit Report |
| 143 |
|
Goals |
| 143 |
|
Who Is Involved |
| 144 |
|
When It Is Done |
| 145 |
|
Standard Formats |
| 158 |
|
The Standard Audit Report |
| 160 |
|
Working Papers |
| 160 |
|
As You Write the Report
... |
| 161 |
|
Proprietary and Confidential
Nature of the Information |
| 162 |
|
Milestones for Phase IV:
Report |
| 163 |
|
13. Phase V: Follow-up and Closure |
| 163 |
|
Goals |
| 164 |
|
Who Is Involved |
| 164 |
|
When It Is Done |
| 165 |
|
What to Expect From the
Auditee |
| 166 |
|
Evaluating Auditee Responses |
| 166 |
|
When Differences Arise
... |
| 168 |
|
Tracking Corrective Actions |
| 168 |
|
Verifying Corrective Actions |
| 170 |
|
Closure |
| 170 |
|
Archiving Working Papers |
| 170 |
|
Milestones for Phase V:
Follow-up and Closure |
| 173 |
|
14. Auditing Vendors and Contractors |
| 173 |
|
Goals |
| 175 |
|
Special Preparation for
Vendor Audits |
| 181 |
|
Conclusion |
| 183 |
|
15. Being Audited |
| 183 |
|
Goals |
| 184 |
|
Phase I: Preparation |
| 191 |
|
Phase II: The Audit |
| 194 |
|
Phase III: Analysis |
| 194 |
|
Phase IV: Report |
| 196 |
|
Phase V: Following up |
| 196 |
|
Conclusion |
| 197 |
|
References and Readings |
| 199 |
|
Appendix 1-American Society for Quality Control
Code of Ethics |
| 203 |
|
Appendix 2-In Their Own Words: GMP and Quality
Auditors Talk About Auditing |
| 215 |
|
Appendix 3-Resources |
| 219 |
|
James L. Vesper |
| 221 |
|
Index |
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