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Our range of services
Like all businesses, many pharmaceutical
companies are planning to gain and maintain a competitive advantage
through information automation in research, manufacturing and
distribution. Pharmaceutical companies are however tightly regulated,
and are required to validate processes, which could have an impact
on product quality. Validation is defined by the Food and Drug
Administration (FDA) in the United States as:
"Establishing documented
evidence which provides a high degree of assurance that a specific
process will consistently produce a product meeting its pre-determined
specifications and quality attributes".
FDA Guidelines on General Principles
of Process Validation, May 1987.
These principles are also applied to computer systems meaning
that the importance of correctly documenting all aspects of a
computer system implementation cannot be overstressed. The
“documented evidence” as required by the FDA is normally
produced by performing rigorous tests of the proposed system which
will provide “the high level of assurance” required.
Historically, the FDA has been happy with the level of documentation
available to their inspectors indicating that processes were compliant
with all relevant guidelines. The whole purpose of automating
a process however, is to streamline operations and achieve improvements
which obviously lead to savings, and or competitive advantage.
In order to enable Pharmaceutical companies to take advantage
of new software packages and implement new processes which were
delivering significant productivity improvements to non regulated
manufacturing industries, the agency issued guidelines to it’s
inspectors in 1985, on how to inspect computerised systems, which
subsequently became known as the “Blue Book.” In order
to interpret these regulations, the agency also issued a number
of Compliance Policy Guidelines (CPGs), which helped industry
interpret the relevant regulatory requirements.
Some computer software and integrated systems suppliers have made
considerable progress in accommodating heavily regulated operations.
Available software technology is now applicable, stable, and trustworthy
enough to justify the investment required for its implementation
in the pharmaceutical industry.
The Food and Drug Administration announced in 1995, that it proposed
to issue regulations to regulate the utilisation of electronic
records and electronic signatures in Pharmaceutical and medical
Device Companies. This was to become 21 CFR Part11. When the agency
first announced it’s intentions, it began an advance notification
of proposed rule making or “ANPRM” process. This process
is designed to enable interested parties make submissions to the
agency prior to the regulation becoming law. Our technical director,
Jeff McBride made a number of submissions which the agency took
on board during this process. The rule became law in August 1997,
and since that date, the agency has accepted electronic records
and signatures as being the equivalent of manual documents. Because
of this, many of our customers have decided to implement new software
packages, including Enterprise Resource and Planning (ERP) systems,
Laboratory Information Management Systems, (LIMS) Electronic Document
Management Systems, (EDMS) and others. Because of KE Consulting
Groups’ experience in software validation since our foundation
in 1997, we have actively participated in many successful implementations
which have subsequently been audited by the FDA, and the IMB.
(Irish Medicines Board)
In 1994, the Pharmaceutical Industry in the UK came together under
the umbrella of the Pharmaceutical Industry Computer Systems Validation
Forum (PICSVF), and laid down guidelines for suppliers of computer
systems, as to what the Pharmaceutical Industry required of its’
vendors in order to take advantage of new technologies while at
the same time maintaining compliance. Diarmuid Cahalane and Jeff
McBride, who co-founded KE Consulting Group maintained contact
with a number of key members of this forum including David Selby
of Selby Hope International, Sion Wynn, then of Activa Systems,
and Annis Bratt of Smithkline Beecham. When the PICSVF subsequently
changed its name to the Good Automated Manufacturing Process (GAMP)
forum, the guidelines were re-issued as “The GAMP Guidelines.”
At the International Society of Pharmaceutical Engineering (ISPE)
Conference in Orlando Florida, in 1997, KE Consulting Group exhibited
it’s novel “Business Process” approach to validation
and regulatory consulting. At this same conference the GAMP guidelines
were commended to the FDA, and an embryonic “GAMP of The
Americas Forum” was born.
Because of our wide knowledge of the industry, and our unrivalled
experience with customers involved in large-scale implementation
projects, we believe that we can offer the skills necessary to
act as a bridge between regulators and industry during the implementation
of large-scale systems.
Our customers are the key to our ongoing success, and now include
the following major names:
- Pfizer
- Glaxo Smithkline
- Wyeth
- Schering Plough USA
(Global Professional Services Agreement)
- Helsinn
- Johnson & Johnson
- Genzyme
- Achileon
- Elan
- Merck USA
(Global Professional Services Agreement)
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