To harmonize procedures that satisfy GLP, GMP, and ISO 9001 standards, organizations should implement a structured document architecture, utilize a compliance applicability matrix, and standardize processes and training to ensure alignment across all frameworks.
Why it matters
- Regulatory Compliance: Ensures adherence to diverse regulatory requirements, reducing the risk of non-compliance penalties.
- Operational Efficiency: Streamlines processes, minimizing redundancy and improving resource allocation.
- Quality Assurance: Enhances product quality and reliability by integrating best practices from multiple standards.
- Risk Management: Identifies and mitigates risks associated with non-conformance across different regulatory frameworks.
- Continuous Improvement: Facilitates a culture of ongoing enhancement through unified reviews and audits.
How to apply
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Establish Document Architecture:
- Create a hierarchical structure: Quality Manual → Process Maps → SOPs → Work Instructions/Forms.
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Develop Compliance Applicability Matrix:
- Within each SOP, specify applicable clauses from GLP, GMP, and ISO 9001.
- Identify and document any delta controls needed for compliance.
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Create a Crosswalk:
- Map regulatory requirements to control statements and evidence artifacts (e.g., records, logs).
- Ensure that each control is linked to the relevant compliance framework.
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Standardize Templates:
- Develop consistent templates for documents to ensure uniform terminology and approval workflows across all standards.
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Implement Risk-Based Validation:
- For computerized systems, apply validation and data integrity controls that meet Part 11, GLP, and GMP expectations.
- Reference these controls in multiple SOPs to avoid duplication.
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Train Staff by Role:
- Use the compliance applicability matrix to guide training, ensuring staff understand their specific obligations based on their roles (e.g., nonclinical vs. manufacturing).
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Conduct Unified Reviews:
- Schedule management reviews (ISO 9001) and quality reviews (GLP/GMP) in a single meeting to discuss CAPA and continual improvement actions based on data.
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Perform Periodic Internal Audits:
- Utilize the crosswalk to verify that controls meet multiple frameworks without gaps or conflicts.
Metrics to track
- Compliance Rate: Percentage of processes that meet GLP, GMP, and ISO 9001 requirements.
- Audit Findings: Number and severity of findings from internal audits related to compliance.
- Training Completion: Percentage of staff trained on relevant SOPs and compliance obligations.
- CAPA Effectiveness: Time taken to resolve corrective and preventive actions identified during reviews.
- Process Improvement Metrics: Number of improvements implemented as a result of unified reviews.
Pitfalls
- Inconsistent Terminology: Failure to standardize language across documents can lead to confusion and misinterpretation.
- Overlapping Controls: Implementing redundant controls can waste resources and create unnecessary complexity.
- Inadequate Training: Insufficient training on compliance obligations can lead to non-compliance and operational errors.
- Neglecting Stakeholder Input: Not involving key stakeholders in the harmonization process may result in overlooked requirements or resistance to change.
- Ignoring Continuous Improvement: Failing to regularly review and update procedures can lead to outdated practices that do not meet current standards.
Key takeaway: Build one control set with a requirements crosswalk; reuse validated controls and unify reviews to satisfy multiple standards efficiently.