Strategic Issues
  • Regulatory Exposure / Risk
  • Regulatory compliance
  • Too many errors, incidents, discrepancies, or deviations requiring investigation, resolution and corrective action
  • High number of changes and revisions and excessive time required for approvals
  • Extended cycle times
  • Excessive in-process inventories
  • Higher product cost
  • Excessive documentation
  • Plans to implement an Electronic Document Management System, Product Data Management System, Device History Record and/or Manufacturing Execution System
  • Harmonization of documentation within a site or across sites
  • ISO Certification
  • 21CFR part 11 compliance issues
  • Lean initiatives
Critical Success Factors
  • A Quality System in place to comply with the Regulations
  • A Design History File (DHF) that describes the design history of a finished device.
  • Device Master Record (DMR) containing the procedures and specifications for a finished device.
  • Device History Records (DHRs) that meet requirements for Production & Process control
  • An effective Change Control Process with few and infrequent changes required
  • Clear ‘Ownership’ of Records
  • Documentation that is
    • Streamlined
    • Simplified
    • Uniform and Standardized
    • Easy to maintain and administer
    • Designed to minimize errors and omissions
  • Minimal Training time is required
  • Fast Product release times
  • Process reliability
Brighton - Tool Kit
  • Documentation Assessment
  • ‘As Is’ Process Maps & Models
  • Use & User Review
  • Review of Interfaces with other Systems (EDMS/MRP/LIMS)
  • Analysis and Challenges of current Documentation
  • “Proof-of-Concept” Device History Record redesign
  • Definition of Benefits and ROI
  • Documentation Redesign
  • Identify GMP & process control requirements
  • Compare what's in place to requirements
  • Recommend appropriate use of technology
  • Simplify documentation content and interfaces
  • Develop model and format for uniform and standardized DHRs
  • Use Connect-The-Docs® for DHR redesign and to issue lot specific DHRs
  • Program Management
  • Time Compression
  • Implementation
Results
  • Enhanced Regulatory Compliance
  • Pages reduced 30 - 50%
  • Document entries reduced 30 - 60%
  • Documentation / procedural errors reduced 50 - 80%
  • Review cycle time reduced 40 - 70%
  • Product release cycle time reduced 30 - 60%
  • Manufacturing cycle time reduced 15 - 20%
  • Time spent on investigations reduced 20 - 30%
  • Document creation/revision time reduced 25 - 40%
  • Framework for all processes and products
  • Standardized work instructions
  • First step when converting to an electronic DHR system
  • Back-up system for an electronic DHR system
  • Simplifies implementation of an electronic DHR