1-2 introduction to quality risk management (qrm)

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    1-2 Introduction to Quality Risk Management (QRM)

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    Table of Contents1 Quality Risk Management (QRM) ............................................................. 3

    1.1 Introduction to Risk Management ...................................................... 3

    1.2 Successfully Managing Risk .............................................................. 7

    1.3 Risk Assessment Plan ....................................................................... 8

    1.4 Opportunity for Improvement ........................................................... 10

    1.5 Risk Management Case Study Example ......................................... 12

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    1 Quality Risk Management (QRM)

    1.1 Introd uct io n to Risk Management

    Worst case scenarios

    When designing any equipment system we need to consider an appropriate

    response to any upset condition. Focus particularly on likely worst case

    scenarios, with initially a high probability for failure.

    Primary worst case scenarios are typically in the context of:

    1. Product effectiveness and quality

    2. Personnel safety both operator and customer.

    At the outset we try to identify what could go wrong and what to expect in that

    event.

    Planning for worst case scenarios

    Then we need to consider our reactions to these upset conditions. What are

    we going to do, or what do we need to put in place, when these things do go

    wrong?

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    Remember, whatever solutions we put in place there will always be residual

    risk. There is rarely a perfect solution. Ac ceptance of residual risk will dictate

    a go/no-go scenario with the product.

    Causes of failures

    Now we need to figure out what could trigger the fault with a view to

    preventing it from occurring. Therefore, for each fault we try and identify

    causes. We could also further describe specific deviations and/or effects

    associated with each cause in the context of the overall fault.

    Fault prioritization

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    Next, prioritize each cause and deviation/effect combination typically rating

    against severity, and likelihood of occurrence (probability).

    Control strategies

    Based on priorities then choose which

    faults over others we must endeavor

    to control. The process predominately

    culminates in a suitable control

    strategy being decided upon and

    implemented.

    Remember there can be many solutions to choose from, but be sure they will

    all cost money! If a solution is too expensive to implement it can render the

    business initiative economically unviable, thus killing the project.

    Risk communication

    Communication to the

    operator/customer is hugely

    important particularly in the context

    of managing the residual risk.

    Residual risk is usually managed in

    combination with procedures, as

    opposed to being completely

    designed out.

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    Risk review

    Endeavour to track all post-

    implementation and post-production

    failures. Dont make the same

    mistake twice!

    Know what you dont know

    Knowledge based on experience

    is referred to as wisdom. But we

    dont alwa ys have the benefit of

    wisdom particularly when doing

    something for the first time where

    there is little or no precedence.

    Plan to accumulate wisdom in advance of experience, using risk-managementin combination with well designed simulation and prototyping studies.

    Find ways to unlock -wisdom not yet experienced.

    Simulations

    Gain experience with prototypes through well designed simulations and feed

    back newly identified risks back into the evolving design

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    1.2 Success ful ly Managing RiskRisk is an opportunity to incur a loss or an injury. To successfully manage risk

    you must identify the processes, participants, and interactions between them.

    Who is at risk of what? Who is liable for what? What is the potential for loss or

    injury? What can be done to prevent or control those potential losses or

    injuries?

    Risk analysis

    Intended use/intendedpurpose identification

    Hazard identification Risk estimation

    Risk evaluation

    Risk acceptability decisions

    Risk control

    Option analysis Implementation Residual risk evaluation Overall risk acceptance

    Post-production information

    Post-production experience Review of risk

    management experience

    R i s k a s s e s s m e n

    t

    R i s k m a n a e m

    e n

    t

    Schematic representation of the risk management process (adapted from ISO 14971 Application of Risk Management to Medical Devices)

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    1.3 Risk Ass essment Plan A risk assessment plan is an important design tool in the development of a

    medicinal product. It is used to ensure that the products are designed safe

    and effective. Unlike other processes however, the hazard evaluation is one

    that never dies. In fact the risk plan should evolve especially as other risks are

    identified such as when a problem occurs out in the field or when a

    customer complaint is issued.

    unacceptable

    InitiateQuality Risk Management Process

    Risk Identification

    Risk Analysis

    Risk Evaluation

    Risk Assessment

    Risk Reduction

    Risk Acce tance

    Risk Control

    Output / Result of theQuality Risk Management Process

    Risk Events

    Risk Review

    RiskManagement Tools

    R i s k C o m m u n

    i c a t i o

    n m

    ICH-Q9 Overview of a typical risk management process

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    The level of effort needed for actual management of risk, however, depends

    on the product and its application. Risk management is, in reality, easier for

    tongue depressors than it is for pacemakers.

    Risk management requires clear executive policy, useful guidance, and

    resource support in the form of human resources and training. You will need

    effective assessment methodologies appropriate to the product or service,

    and continual monitoring, assessment and improvement of the risk

    management process. Risk management can be used to connect design

    control, quality planning, process control, measurements control and core

    problem solving processes. When this connection is made the interplay

    between them becomes clear and potential problems can be prioritized and

    addressed in the most effective way at the lowest possible cost.

    Risk management process should to be used as part of a quality companys

    management system and specify a procedure for the manufacturer of a

    medicinal product to incorporate the following:

    Identify hazards associated with the medicinal product device and its

    accessories

    Estimate and evaluate the risk associated with those hazards

    Control those risks

    Monitor the effectiveness of that control

    To get started first determine what quality risk scenarios can occur, what is

    the likelihood and the consequences given they occur. Second, estimate the

    parameters used to determine the frequencies and probabilities of the various

    events. The level of detail and quantification needed helps to determine the

    tool to use:

    Methodology: e.g . formal or informal risk management process

    System risks: e.g . risk ranking and filtering, FMEA

    Process risks: e.g . FMEA, HACCP, process mapping, flow charts

    Product risks: e.g . flow charts, decision trees, tables, check sheets

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    1.4 Oppo rtuni ty for Imp rovem entIn general, the risk management process can be applied to any problem /opportunity for improvement, as follows:

    unacceptable

    Problem statement: identification ofopportunities for improvement

    Use and/or adapt risk assessment tool(s) toindividually scrutinise and analyse eachreason/cause that lead to the problem

    Evaluate and prioritise reasons/causes todetermine extent of mitigation required basedon risk to product quality, and currentresource loadings

    Risk Assessment

    Based on the mitigation strategies to beused, develop a project plan and a scheduleof activities for completion. Accept andimplement the plan.

    Risk Control

    Quality improvements: superior systemperformance, enhanced and betterunderstanding of the process, improvedcapability to react to system upsets, andincreased opportunity for continuous

    improvements.

    Periodic reapplication of (adapted) riskassessment tool(s) to problem statementfollowing implementation of risk controlstrategies. Confirm actual improvements toquality. Determine if there is additional roomfor further improvements.

    Risk Review

    RiskManagem

    ent Tools

    R i s k C o m m u n

    i c a

    t i o n

    Typical site application of risk management process toidentification of opportunities for improvement

    Use and/or adapt risk assessment tool(s) toidentify reasons/causes for current poorperformance

    Set up a dedicated project team. Take aproblem-solving approach and decide onoptimum mitigation strategies.

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    The following is the hypothetical application of the risk management processto identify a suitable formulation strategy for a new drug substance:

    Hypothetical application of risk management process during

    pharmaceutical development to identify a suitable formulation

    unacceptable

    Problem statement: identify suitableformulation for a new drug substance.

    Use and/or adapt risk assessment tool(s) torobustly scrutinise and analyse eachidentified formulation risk(s) that could leadto the patient harm.

    Evaluate and prioritise formulation risk(s) todecide on a suitable manufacturing conceptbased on risk to patient health, and businessrequirements. Choose the formulation andidentify the critical process parameters.

    Risk Assessment

    Determine the product release concept forthe chosen formulation.

    Risk Control

    The output is robust pharmaceuticaldevelopment study that demonstrates to theregulatory authorities an advancedunderstanding of the process, an opportunityfor continuous improvements, and a firmbasis for process validation studies.

    Periodic reapplication of (adapted) riskassessment tool(s) to problem statementfollowing formulation choice. As the processdesign evolves determine if there isadditional room for further improvements tothe chosen formulation approach.

    Risk Review

    RiskManagement Tools

    R i s k C

    o m m u n

    i c a

    t i o n m

    Use and/or adapt risk assessment tool(s) toidentify risks to patient health based on arange of proposed formulations.

    With the critical process parametersidentified, determine the process controlconcept for the chosen formulation.

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    1.5 Risk Management Case Study Example

    Know what you dont know

    Knowledge based on experience is referred to as wisdom. But we dont

    always have the benefit of wisdom particularly when doing something for the

    first time where there is little or no precedence. Plan to accumulate wisdom in

    advance of experience, using risk-management in combination with well

    designed simulation and prototyping studies. Find ways to unlock -wisdom

    not yet experienced. Gain experience with prototypes through well designed

    simulations and feed back newly identified risks back into the evolving design

    we should have caught it.

    The Apollo 1 crew, from left to right,Roger Chaffee, Ed White and GusGrissom

    .. Somewhere, somehow, we

    screwed up. It could have been in

    design, build, or test. Whatever it

    was, we should have caught it. We

    were too gung ho about the

    schedule and we locked out all of

    the problems we saw each day in

    our work. .

    [Gene Kranz ]

    Command module (CM-012)destroyed by fire during a test andtraining exercise on 27 January

    1967 killing all three Apollo 1 crew.

    Eugene Francis "Gene" Kranz athis console in the MissionOperations Control Room, MissionControl Center, Houston

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    How should we have caught it?

    How can you predict problems?

    Its got to be a bit like predicting the future

    Nobody has ever done this before, so we have no benchmark orprecedent to compare against.

    The only guarantee is that well never think of everything - never ever

    How do you predict the future?

    The consequences of our actions are

    so complicated, so diverse, that

    predicting the future is a very difficultbusiness indeed. [ J. K. Rowling ,

    Harry Potter and the Prisoner of

    Azkaban ]

    Uncertainty based on fear is the beginning of knowledge

    It is the unknown we fear [ J. K. Rowling , Harry Potter and the Half

    Blood Prince ]

    We all fear the future to some extent. We learn from looking back, but we

    achieve when we look forward. With risk management positively harness our

    fear of the future by looking forward in apprehension when things wont go

    correctly.

    What to do when things go wrong How do you plan to react when things do go wrong.

    What could go wrong, where and when.

    How do I find out what things could go wrong?

    Nobody ever expects everything will go right all the time, especially the first

    time; the big test is what will you do when things go wrong.

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    1st: Develop the concept

    Describe desired processes and outcomes

    2nd: Identify possible deviations

    This is the trickiest part identify potential problems. A team of backroom

    scientists and engineers, often with great amusement, would develop various

    likely and unlikely scenarios. They would then feed a sequence of code into

    the computer to simulate the problem, and monitor the reaction of the crewand mission control.

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    3rd: Run failure simulations

    IBM 7090 computer

    Through simulation techniques in the

    early 1960s, NASA's Saturn moon

    flight rocket was "flown" thousands oftimes within the IBM 7090 computer

    before real flight. The fully

    transistorized 7090 could perform

    229,000 calculations a second.

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    4th: Monitor reactions

    Monitor reaction of crew and mission control to upset conditions. If observedreactions are undesirable, then proceed to mitigate and control. Either design-

    out (preferable) or procedurilize-out (last resort) the problem. Remember,

    there are many options available to mitigate and control faults.

    5th: Communicate the action

    Ensure only does that need to know

    are updated with the communication.

    Dont waste the time of those who

    dont really need to know

    Apollo Operations Handbook

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    6th: Review the action

    Buzz Aldrin walks on the surface

    of the Moon 20 July 1969

    Apollo 11 astronauts in New

    York

    Mistakes will be made

    Innovation and creativity are experimental processes where there are always

    unknowns. Everything cannot be predicted where there is no precedent.

    Mistakes are a necessary part of creative experimentation and will be made.

    Dont make the same mistake twice!