Web Document Management and a CGMP-Compliant Quality System - Management Responsibilities

The underlying foundation of any quality system is itsmay include the following:
associated documentation. Quality system- "The scope of the quality system, including any
documentation includes policies, procedures and writtenoutsourcing (see IV.B.4.)"
processes (e.g., quality assurance documentation,- "The quality standard that will be followed"
SOPs, etc.) and provides the proof that it does or- "The manufacturer's policies to implement the quality
does not meet documented expectations.systems criteria and the supporting objectives (see
Because documentation is the foundation andIV.A.4.)"
assurance of an accurately applied system it is- "The procedures needed to establish and maintain
probably safe to assume that those companies thatthe quality system"3
manage and manipulate their documentation fasterWhen these and other forms of documentation need
and more effectively at the enterprise level have anto be created and presented, management is called to
increased ability to more effectively manage theirtask. To create these documents in a manner efficient
overall quality.enough for even the busiest of executives, a web
Enterprise Level Web Document Managementdocument management solution should be
Depending on the industry in question, this kind ofimplemented so that document collaboration can take
system will generally require a variety of documentedplace and so that documents can be automatically
policies and procedures that must be approved, stored,routed to users of all departments for collaboration and
and/or presented to remain in a state of compliance.review. Audit trails will also make it easy to see when,
The life science industries, for example--especially thewhere and by whom a document has been modified.
pharmaceutical industry--are very highly regulated (bySystem Review
the FDA and other regulatory agencies or standardsAnother "must" for management is to review the
organizations) and require the strict management ofcompany system on a regular basis. According to the
quality documentation, product life cycle documentationguidance, Quality Systems Approach to
and those documented forms required for formalPharmaceutical cGMP Regulations, "Under this
submissions (these can equal hundreds of thousandsapproach, a review should consider at least the
or millions of documents in the pharma industry).following:"
Modern Quality System Elements- "The appropriateness of the quality policy and
The FDA's guidance for the pharmaceutical industry,objectives"
Quality Systems Approach to Pharmaceutical cGMP- "The results of audits and other assessments"
Regulations1 presents the necessary elements of a- "Customer feedback, including complaints"
modern quality system (includes harmonized- "The analysis of data trending results"
international standards, ISO 9000 elements, etc.) and- "The status of actions to prevent a potential problem
connects those elements with cGMP standardsor a recurrence"
required since the 70s by the FDA. The guidance- "Any follow-up actions from previous management
provides a modern model2 that includes the followingreviews"
categories:- "Any changes in business practices or environment
- Management Responsibilitiesthat may affect the quality system (such as the
- Resourcesvolume or type of operations)"
- Manufacturing Operations- "Product characteristics meeting the customer's
- Evaluation Activitiesneeds"
Each of these systems categories can be managedAll of these requirements can be conducted with
and controlled more effectively with the use of anelectronic web-based process management software
enterprise-level web document management system.and with the following capabilities:
This article, however, will focus primarily on- Document Collaboration
management responsibilities and how web document- Audit Management Software
management software can greatly amplify and- Customer Complaints Management Software
executive's ability to keep a quality software in check.- Nonconformance, Deviations and other Trend
Management ResponsibilitiesSolutions
According to the FDA's guidance, Quality Systems- CAPA Software
Approach to Pharmaceutical cGMP Regulations, a- Change Control Software
"Modern robust quality systems models call for- Easy Search and Retrieval Capabilities for all
management to play a key role in the design,Documentation and Forms
implementation, and management of the qualityThe Trick
system."The trick for managing all of these requirements
Even from the initial stages of creation, management iselectronically is to find the software provider that can
presented with the required responsibility ofprovide all of the solutions mentioned above on one
participating in the design of a company's qualityweb-based platform.
system. This documentation, according to the guidance