Best practice means finding and using the best ways of working to achieve strategic and operational goals. This is an important
concept for biopharmaceutical manufacturing as much as it is for other industries. Notably, biopharmaceutical businesses work
within a regulatory framework that requires good practices (GxP) to be defined and consistently executed. So, are good practices the same as best practices?
Demonstrating good manufacturing practice (GMP) represents a minimum requirement to run biopharmaceutical operations. Failure
to comply with GMP, on the other hand, can lead to external intervention and remedial actions, at high cost and risk to reputation.
But good practice is not necessarily the same as best practice and regulations do not cover the whole gamut of business processes
and systems that affect performance. Much of the good practices used can be described as being "acceptable" to external inspectors,
but in most cases, there are better ways of working that still earn regulatory approval.
Is the industry doing enough to proactively search out, internalize, and establish better practices? Or do we mostly allow
good or acceptable practice to stay unchallenged and unimproved? In today's tough environment, biopharmaceutical manufacturers
cannot afford to ignore the fact that better ways of working might be possible.
People engaged in biopharmaceutical operations, whether it is production, quality, development, or engineering have a great
appetite for learning and sharing their approaches. Such sharing can be achieved in many ways: reading technical journals,
attending conferences, networking with peers, and participating in structured knowledge sharing and Operational Excellence
programs. Senior management must encourage these initiatives.
Concerns about sharing information with competitors has be put in perspective, however. When companies collaborate, the industry
is strengthened and competition is increased. Most importantly, collaboration supports increased quality and patient safety.
These benefits easily outweigh the potential loss of advantage where some companies incur higher costs from using poorer practices.
There is no real competitive advantage here. Sharing best practice does not mean sharing IP, cost, or commercial information.
These are no-go areas.
In a sharing-based environment, most information can be gleaned from other parts of the business or from other companies in
the industry. Less common practice is to seek out other industries to learn about their best practices or benchmark their
performance levels. And here's the problem: if most of our best-practice sharing is within our company or within similar companies,
then we miss out on learning where significant gains can be made. As one senior executive put it to me, "If I'm a C-grade
student, I don't just want to learn from a C+ grade friend. I also want to learn from the A-grade student who is going to
help me leap forward."
Sharing best practice between players in the industry means improvement comes more quickly. However, if the best practice
doesn't exist in the industry how can it be shared and copied? Taking best practice from other industries can bring a step-change
in perspective and in performance.
A great example spreading across our industry at the moment are practices associated with people making mistakes in their
work and how the resulting problems are dealt with. When mistakes lead to product quality risks, then there is a duty on the
part of the manufacturer to identify, correct, and prevent the mistakes from reoccurring. Until recently, the common practice
for responding to human error was to retrain the person making the mistake. If this is done correctly and documented, then
it is acceptable from a GMP perspective. Good practice? Yes, but is it best practice?
The nature of bioprocessing necessitates a significant amount of manual intervention and the amount of reported human errors
in GMP investigations is high. These errors are costly to the industry not only in terms of rework, lost product, and lead
time but also in terms of the number of errors that implicate training, supervision, verification, and attention to detail.
In such instances, the ability of the industry to identify and address true root causes is questioned. As a result, regulatory
concerns have been heightened, and agencies are pushing for a more formal approach to Human Error Reduction (HER).
The shifting environment suggests that past good practice may not be future acceptable practice. So how can better practices
associated with human error be found and used?
One only has to look at nuclear or aerospace businesses to realize there are better ways. The worst-case impact of human error
in these industries doesn't need to be detailed here, but it is worth mentioning that millions of hours of operation are routinely
recorded without accident. Best practices found in nuclear and aerospace operations include the following:
- Near misses are recorded and investigated as learning opportunities.
- Management encourages the highlighting of errors to facilitate improvement rather than punish the guilty.
- Systemic issues are reviewed for root cause analysis and true preventive measures adopted.
- Environmental, behavioral, and psychological factors are assessed in a structured way.
These practices have been largely absent in pharmaceuticals. However, there is now a rapid uptake in these ways of working
and implementation is active in many biopharmaceutical businesses.
At the end of this month, February 2012, 12 top biopharmaceutical businesses will meet in London to compare and contrast HER
approaches. The aim is to create a common level of awareness of how the industry is effectively addressing human errors, accelerating
the journey by learning from other regulated industries whose HER approaches are mature and to develop an industry vision
for best practice HER. This will be only be the start of an ongoing collaboration to make sure biopharmaceutical manufacturing
is as reliable as any other safety critical business across the world.
The demands on biopharmaceutical operations for better performance will not go away—in fact, they will increase. All means
must be explored to accelerate the improvement process, including shamelessly copying from the best and borrowing from (and
giving to) others. Best-practice sharing will itself become a best practice feature of the most successful organizations
involved in biopharmaceutical innovation and production.
Simon Chalk is director of the BioPhorum Operations Group, firstname.lastname@example.org