PHARMACEUTICAL INDUSTRY :
Compliance Remediation
  Client:   A major generic pharmaceutical company
     
  Problem:   The client was under intense regulatory scrutiny and had received a number of 483s over a 2 year span. The FDA identified the company's Standard Operating Procedures (SOPs) as needing improvement:
  • SOPs were not up-to-date and contained procedural inaccuracies
  • Multiple SOPs existed for the same activities, and duplicate SOPs sometimes differed in instructions
  • SOPs were not being consistently utilized by staff
  • Departments were not taking ownership of SOPs
  •      
      Approach:   A team of Tunnell Subject Matter Experts reviewed and revised the company's entire portfolio of SOPs. This team, consisting of experts in Manufacturing, Regulatory Affairs, Quality Assurance, Quality Control, R&D, Engineering, and Analytical Research, worked with the client's process owners and staff to:
  • Conduct a Gap Analysis vs. current procedures by observing execution of the SOP activities
  • Interview process stakeholders to identify potential improvements or undocumented practices
  • Incorporate industry best practices into processes
  • Revise SOPs and prepare required change management documentation.
  •      
      Results:   Once fully implemented the improvement program will result in:
  • Gaps in instructions eliminated. Increased detail and descriptions added to facilitate consistent execution of the instructions
  • Reduced Deviations and Investigations from improper execution of tasks
  • Better training and preparation of new and existing employees
  • SOPs created in collaboration with Supervisors and Operators to improve compliance and reinforce a sense of document ownership
    • SOPs converted to "Step Action" format for ease of use
    • Process Maps created and added to facilitate SOP use and understanding
    • Pictures added to identify key components and actions
    • Over 8500 SOPs reviewed and revised; approximately 125 SOPs eliminated or streamlined.
           
       
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