When juggling priorities, early-stage life sciences companies often find themselves between a rock and a hard place. Intent on winning FDA approval and bringing new, high-value products to market faster than the competition, small, cash-strapped companies often choose to funnel their limited financial and manpower resources into furthering their research, development and commercial production goals.
However, regulatory compliance—and the development of a robust quality system to handle compliance-related considerations—must also be at the top of the corporate agenda. Smart executives find that they can mitigate risks and avoid unforeseen expenses, product or production delays, or other go-to-market setbacks if they address compliance and quality system effectiveness early in their business planning process.
The mere mention of compliance, however, makes many drug manufacturers apprehensive. Historically, companies of all types and sizes have had a tough time tracking, understanding, and adhering to constantly changing FDA and other agency regulations and quality requirements. Larger firms have tried to manage these complexities by assigning teams of employees to the task or by investing in sophisticated IT systems; even these manufacturers often find themselves struggling to meet regulatory expectations.
Smaller companies, lacking the deep pockets of the bigger players, tend to postpone quality system development until their organizations are better established, have reached critical milestones, or can expand their available resources. This tactic can, and often does, backfire as soon as compliance issues or quality gaps arise.
Although there is no blueprint for quality system development, there are a number of things executives can do to achieve near-term and future business objectives while supporting a compliance-centric environment. This article looks at some of these best practices, from clearly defining the organization’s quality vision to building a pragmatic quality system that can grow over time.
Defining the Quality System Vision
As with most strategic initiatives, devising and implementing a robust and effective quality system depends on the corporate vision behind it, and the commitment senior leaders make to realize that vision. While executives may initially be preoccupied with short-term deliverables and directives during their company’s start-up phase, as the organization gets closer to the launch they’ll want to pay attention to serious compliance risks and quality system gaps that could threaten continued development and commercialization.
The sooner C-level managers can get their heads around big-picture compliance issues, and visualize what’s at stake should the company fail to address them, the more adept the company will be at putting corrective and preventative actions in place and beginning to build a reliable quality system.
This first step need not require major effort and resources. More than anything, it requires forethought among senior managers, who will want to consider the following:
• Is there a better way to operate?
• What can we do to simultaneously achieve speed, efficiency, and compliance?
• How can we develop a scalable, fit-for-purpose quality system that supports our business structure, operations, and targets?
• How can compliance and quality be integrated into our everyday decision-making process?
• How can an effective quality system reduce time to market or improve the organization’s value?
• How can the system add measurable value beyond delivering a level of assurance that regulatory expectations are met?
Once the answers become clear, the senior leadership team must drive the design and implementation of an effective quality system. How well they articulate their vision, align business processes to it, and get the rest of the organization on board will determine the acceptance and success of the proposed quality system.
Creating the Quality System
With the vision defined, companies must create a quality system architecture that will benefit them immediately and yet be flexible enough to adapt to growth and change over the long haul. At its core, an effective quality system establishes what a company says it will do, tracks how well it has done so, and documents the entire process. It’s also a tool that can be used for planning corrective and preventative actions, managing change, and keeping tabs on contract research and manufacturing organizations.
Developing and implementing the system across the enterprise can be inherently frustrating and create a sense of anxiety, but putting an effective quality system in place doesn’t have to be as hard as it sounds. Nor does it have to be burdensome, time consuming, or costly. Organizations can start small and set up an uncomplicated, but comprehensive, base that can be built upon incrementally.
In our experience, there are five rules of thumb that management must follow in the successful implementation of a quality system:
Understand the role of culture. A company’s culture greatly impacts tactical and strategic projects and often determines whether needed changes will become permanent. Executives grappling with quality system design will benefit from accepting this simple truth: the organizational mindset around quality and compliance will determine the kind of system that’s created and adopted.
Culture varies widely from company to company, and past experience can sway senior staff’s natural inclination to either embrace or resist compliance and quality system initiatives. To a large extent, though, executives will be responsible for instilling a compliance- and quality-focused culture.
Discipline is needed. For a compliance culture to thrive, the quality system must be integrated across functional areas, encompassing everything from authoring regulatory documentation to tracking near-term quality targets to long-term planning.