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The quality manual should be almost an outline format and should not contain details of the procedures or processes. Flowcharts, tables, and other visual representations of the information are helpful and appropriate for the manual. The manual should also identify the hierarchy of quality documents. For example:
3.Quality objectives
These objectives are designed to encourage organizations to define strategic goals and a purpose for the QMS. Objectives translate an organization’s vision into practice by creating a link between customer requirements and specific, measurable, and attainable goals. Well-written objectives lend purpose to a quality management system initiative and establish a customer-centric culture in an organization. They also serve as guideposts to tell the organization what is working well and what areas may need more attention.
Quality objectives should be realistic; don’t aim for the stars if you haven’t even made it to the moon yet. For example, if non-conformances have been an issue that you are now working on through quality objectives, don’t aim for perfection right out of the gate. Quality objectives should be revisited and revised periodically, so it’s okay to be realistic and then challenge yourself once things are more in control. Some example quality objectives include:
Quality objectives should provide a clear vision for every member of the organization to understand the company's purpose and the value of a QMS. The objectives should provide a clear metric for measuring progress against strategic goals, including the timeline for achievement and a measurable parameter of improvement.
4.Organizational structure and responsibilities
The top level documents provide a basic framework and starting point for the QMS, but they do not contain enough detail to ensure quality. A QMS needs various policies, procedures, processes, documents, and records to maintain consistent quality and document evidence of that quality.
A QMS should include a clear and current model of the organization's structure and the responsibilities of all individuals within the organization. This is typically accomplished with an organizational chart, which visually shows the roles and the flow of responsibility. This can be embedded in the quality manual, but is typically managed as a stand alone document and referenced within the quality manual. For ISO 13485, this document should identify who is serving as a Management Representative (usually the Quality Manager).
5. Document and records control and management
In a QMS, all documents must be controlled and all records must be retained. Think of documents as procedures, form templates, the quality manual, work instructions, approved supplier lists, and other documents that contribute to making the product in any small way. Document control means that these documents must be revision controlled so that any changes to the documents are correctly approved and evaluated for any potential effect on production or product risk. Further, these document changes must be communicated to all necessary personnel and any copies that have been distributed must be replaced with the new revision. All of these processes must be documented.
Further, an organization must have processes in place for records control and retention. Records can be thought of more like the evidence of work. So if a document is put through the revision process, all of the evidence that it was properly approved and communicated would be considered records. Key examples of records include: training records, manufacturing batch records, complaint records, nonconformance records, etc.
Effective record-keeping is crucial to the success of the QMS, the ability to obtain certification with QMS standards, and regulatory compliance. During QMS design, organizations should create specific definitions of records within the organization and policies for document creation, retention, and editing. Document and records control is commonly managed through an electronic QMS to ensure access is limited and to automate the document control process where possible.
6. Processes and procedures
The entire QMS approach to quality control is to establish standardized, replicable processes throughout the organization. This means processes out on the production floor just as much as the document control process taking place in the corporate offices. Standards for quality management require organizations to identify and define all organizational processes which use any resource to transform inputs into outputs. Virtually every responsibility in the organization can be tied to a process, including purchasing.
Initial efforts to define processes should create a high-level picture of how processes serve the organization and intersect with resources such as employees, machines, or technology. After identifying processes, organizations can begin to define standards and success metrics:
It may be helpful to develop a process map that identifies how all of the processes are interconnected. This is useful not only for identifying potential bottlenecks that will have significant ripple effects, but also to help personnel see how their role and responsibilities has an effect on everything else in the company. Helping personnel see that their role is important to the bigger picture is helpful in building a culture of quality and personnel that know they are valued members of the team.
7. Data management and analysis
Having access to data to make data-driven decisions will allow the QMS framework to drive continuous improvement and preventative quality control activities. Data analysis should be used to identify processes or systems that are out of control as early as possible instead of waiting until major nonconformance occurs. The organization must have plans in place for collecting this data and performing statistical analysis on the data. This data may then be used to assess if the quality objectives are being met and/or other metrics that the organization has established. It is common to compile this data to create a quality dashboard to give upper management a snapshot view of how the QMS is performing.
The types of data required to demonstrate effective QMS performance can vary significantly between organizations. However, at a minimum, it should include the following sources:
These data points will also feed into an organization’s risk analysis process for products as well as for risk-based decision making pertaining to the QMS. For example, high rates of nonconformance with a specific component from a supplier may necessitate updating the risk analysis documents for any products that use that component to account for the possibility of the nonconformance making it through to finished product. Additionally, that data should be reviewed as part of the supplier review process to determine if another supplier should be sourced or if changes to the supplier evaluation process are required.
8. Continuous improvement
A QMS is most valuable to an organization when the tools and processes built into the QMS are being used for continuous improvement. This shift to innovation and improvement instead of putting out fires as they come up is where a QMS can make a huge difference in the overall trajectory of a company. Maintaining quality and process performance at consistent levels is the most basic goal of any QMS, but when fully implemented and mature, that QMS should allow for improvement of quality and processes.
For example, continuous improvement can use kanban or similar methods to analyze a process and find ways to streamline it. This may mean reorganizing a packaging area so that production personnel can complete tasks more quickly, while also minimizing the risk for mixups on the line.
Auditors like to see corrective and preventive actions (CAPA) that are opened for continuous improvement projects. It signals to them that the systems are in control enough that there are resources being devoted to improvement, but also shows a commitment to quality and improvement.
9. Quality instruments
The control and calibration of tools used to measure quality are integral to the success of a QMS. If machines or equipment are used to validate products or processes, this equipment must be carefully controlled and calibrated according to industry standards. Depending on the instrument, this could involve periodic calibrations or calibration before every measurement.
The QMS system design within an organization should dictate a clear policy for the maintenance of quality instruments based on nationally or internationally recognized standards for each piece of quality equipment. This documentation should address:
In addition to these requirements, the QMS should address effective documentation of calibration results, including procedures for maintaining complete records of activities and calibration results.
Implementing a QMS
Quality management systems are not designed to provide a prescriptive checklist for total quality management. Instead, a QMS is intended to serve as a framework that guides the organization in achieving quality objectives, continuous improvement, and customer satisfaction. Use your QMS to keep your life sciences company’s policies and procedures aligned with launching and scaling life-saving products.
The most successful QMS implementations balance simplicity and customization. There can't be a one size fits all QMS, since each organization is unique. A QMS needs to be purpose-built to fit an organization's objectives, industry, and compliance requirements to have a meaningful impact on culture. The right QMS design is a mixture of flexibility and standardization. Organizations need enough standardization to produce consistent results and enough flexibility for continuous improvement to create a quality-driven culture.
It's important to note that having procedures written does not amount to implementation of the QMS and does not ensure compliance. A binder full of excellent and compliant procedures means nothing if there isn’t evidence to show that they are being used. Make sure that systems are setup to support the procedures and processes, training is provided, and the culture is there to ensure that personnel stick to the procedures. Even better, build a culture where employees feel comfortable suggesting improvements where processes aren’t working.
QMS certifications
Once the QMS is implemented the organization may want to become ISO certified in ISO 9001 and/or other industry specific QMS standards such as ISO 13485.
The first step towards certification is identifying and qualifying a registrar. A registrar is an organization that certifies compliance with the ISO standard. The certification process can take awhile, so look into various registrars at least 6 months in advance to figure out any special requirements they may have and what their process is for certification. For an initial certification there will be a one or more day on-site audit that will look at your entire QMS and ensure that it is compliant with the standard(s). Once certified you will be subject to periodic recertification audits. The frequency and recertification requirements vary by registrar.
Choosing QMS Software or electronic QMS (eQMS)
There are specific rules regarding electronic records as part of FDA 21 CFR Part 11 that can make maintaining a QMS electronically a little tricky. These regulations ensure that records and signatures are strictly controlled and cannot be edited. One of the easiest ways to ensure compliance and keep your QMS in the 21st century instead of on paper is to use QMS software.
There are many options out there for QMS software. In most, organizations are able to purchase access to just select modules or areas that they want, or they can purchase the full suite that includes most if not all areas of the QMS. Larger organizations should definitely have an electronic QMS to assist with the burden of trying to keep track of all of the documents and records. Now that remote or hybrid work is more common, having an QMS system that can be accessed from anywhere is critical for keeping the work flowing and happier employees with greater work-life balance.
For smaller organizations the need for QMS software isn’t always as obvious, but it can definitely benefit the company. In smaller organizations personnel often wear many hats and the QMS can help streamline things so that personnel are spending less time dealing with document and records management. Training and vendor records can be maintained through the software, making it easy to know when suppliers are due for re-evaluation and easy to show that all training records are in order when an auditor comes in. Over time, the system should pay for itself with time savings if it is a clean, easy to use system.
When choosing an electronic QMS be sure to look for validations, 21 CFR Part 11 compliance, and modules and workflows that make sense for your organization. The initial setup of a new QMS can be onerous, so consider any setup support that the company provides. If you are just dipping your toe into the QMS software, document control and training records are typically good choices for starting out. These are manual, labor intensive processes that need input from multiple users, so they are well suited to being managed in an electronic QMS environment.
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