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Books by LearningPlus founder James L. Vesper

Quality and GMP Auditing Clear and Simple

This book provides you with both a deep understanding of the principles of GMP auditing and the techniques to apply them to your organization in ways that will allow you to meet and exceed GMP requirements.

An experienced trainer, Jim Vesper uses a building block approach to cover topics related to the four key competencies essential for successful GMP audits and to break down the audit cycle into five distinct phases. Using proven techniques, he then offers you a dozen audit approaches that you can adapt to your specific requirements.

Written for QA/QC professionals and others interested in audit basics, this book is a hands-on learning tool that will enhance your audit techniques and provide you with a deeper understanding of ways to meet the demands of the regulated environment.

 

Preface

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

Table of Contents

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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