ife sciences organizations are under
L growing pressure to reduce risk to patient,
provide better quality products, squeeze time
to market and comply with regulations. Too
to quality and compliance. The need of the hour
is to adopt a holistic approach tocompliance that
is essential to achieve higher successful audits;
facilitate consistency in quality processes;
reduce costs associated with validation; and
enable reusability of content created. The
Higher regulatory compliance hurdles
are making it harder for companies to bring
new drugs to market. Safety issues are leading
to product withdrawals and of course, genomics
has also added to the deterrents of drug research
and manufacturing. Further, the industry isto ensure compliance. Also, in spite of spending
millions of dollars to achieve compliance,
companies are often faced with issues such as:
a Large amount of unstructured data
= Multiple conflicting Standard Operating
Procedures (SOP)
= Delayed decision making due to
inefficient underlying processes
= Lack of management oversight
= Operation overheads caused due to
multiple vendors supporting multiple
business processes
a Value chain complexity.
Companies often have procedural SOPs to
take care of the greater percentage of business
processes, but there is no system in place to
ensure people complying with processes defined
in those hundreds of SOPs. Today, companies‘QAnot involved at the beginning of | * Too many SOPs and no metric to
validation, measure its effectiveness
Violation of SOPs and deviation Roferences to nor-existent
process, documents
Inadequate training Unsigned critical deliverables
Lack of consistency across sites Inability to locate documentation
Inadequate training on good ‘Absence of log books for recording
document practices: Seviations
Inconsistent compliance
requirements for standard
components such as security and 21
CFRPart 11
Codes, test scripts and test
‘execution for standard requirements
are not reused
Testing standards are either non=
existent or no followed (risk and
criticality)
Table I: Issues Created due to lack of Automated Control — Source: Infosys Research
and Intervention
Life Sciences System Development Life Cycle
Table 3: Standards addressing Life Sciences System — Source: Infosys Research
Development Requirements
is an important issue. One survey estimates
that business-technology professionals in the
industry are spending up to 22 percent of
their work-week, complying with regulationsFurther, most of the documents created
for compliance are redundant in nature. More
than a third of compliance document content
is used repeatedly. Yet authors in most
organizations re-create it for every document.
When authors re-create content that already
exists, their unnecessary effort increases
labor costs and produces inconsistencies that
decrease accuracy and reader comprehension.
Unique
Close Variation
Exact Match
First Time Content
Figure 2: Analysis of GXP Document Compesition by
ParagraphCOMPLIANCE ARCHITECTURE
Using the sight compliance architecture,
companies should start thinking of optimal
business models that will enablea single platform
for managing regulatory compliance. This can be
achieved by automating compliance processes
and bringing in accountability of relevant people,
process and technology compliance to business
functions. Such a model will help life science
This architecture identifies a «
framework that includes:
m Process Architecture: Includes «
processes in the company and d
the respective scope, objective, a:
roles and responsibilities
= Repeatable Implementation Ay
Identify all the business proces
are implemented repeatedly thr
the company and come up wi
(templates, code repositories, au
scripts, etc) that can enable 1
usage of these processes in a qt
cost effective manner
= Knowledge Management: TheKnowledge Management: There is no
dearth of knowledge in any company.
The problem often arises when this
knowledge is segregated in different
wings of a company. Therefore, it is
essential to consolidate the knowledge
within a company by providing easily
accessible and appropriate repositories
for content sharing, SME analyses,
Frequently Asked Questions for
compliance projects, case histories, etc
all the business processes and compliance
regulations
IT System Inventory: A module that
will act as a repository for information
xelated to all the systems within a
company, including information related
to compliance regulations associated
swith the systems
Reusable Code: A module that will act
as a sepository for all the custom built
proprietary code within a company,
thereby providing means for reusing the
code for future projects
Reusable Scripts: A module that will
provide a xepository for all the test scxipts
utilized during compliance testing,
These test scripts may be converted
into templates for zeutilization in future
projects or may be simply used as
references for similar testing processes in
future.
Effective utilization of these businessPhysician Decides to
Prescnbe Medication
Logs Into a
Hand-held Device
Opens the Patient's
Electronic Record
Checks for Drug Reactions
or Patient Allergies
Checks Formulary Status
& Patient's Health Plan
Selects The Strength, Dosage,
& Number of Refills
Selects a Pharmacy from the
List and Presses Send
Pharmacy Receives the
Rx Via E-mail or Fax
Pharmacy Picks Up the Rx,
Keeps it Ready
Figure 1: Prescription Process Flow