However, such a project will face some major barriers, such as lack of digital maturity, disparate legacy systems, lack of industry standards, lack of management supply, cost of installation, security concerns, and, finally, cultural hurdles ending in lack of collaboration, though none of these are unmanageable.
Pharma 4.0™ and Environmental Safety Governance
Joydeep Ganguly, SVP Corporate Operations, Gilead Sciences Inc., raised the question, “Is Pharma 4.0 the answer to bridging operational excellence and environmental safety governance (ESG) ambitions?” Ganguly considers Pharma 4.0™ principles as a catalyst for ESG.
Thousands or millions of queries and results between AI engine and data form biased decisions. Biased decisions and hundreds of thousands or millions of decisions make a large “splash.”
Use cases in the ESG area include reducing waste, utilizing resources, and ensuring supplier diversity.
Reducing waste
- Reducing energy leakage in energy-intensive fume hoods: analysis of face velocity, air flow, time, and sash positions creates an email alert to user when parameters met
- Reducing waste via prediction of root cause inefficiencies: using the power of predictive data science to find and root cause variances between actuals and forecast, down to equipment submeter
- Resource utilization identifying equipment performance issues: using the power of trend analysis to find and root cause equipment problem areas
- Resource utilization insights: using AI/ML powered optical sensors to identify utilization insights (ex, heat maps, trends, density averages and employee counts)
- Supplier diversity: worked with an emerging data analytics supplier to leverage AI/ML methods to help to create supplier options that are all “curated good choices.”
Digitization and Surveillance Expectations
Ronald Bauer, Head Institute, Surveillance, Agency for Health and Food Safety, Federal Office for Safety in Health Care, Vienna, Austria, addressed digitization and surveillance expectations. First, he considered EU GMP Annex 1: Manufacture of Sterile Medicinal Products and noted that risks should already be considered in the design of a manufacturing process. This includes:
- Monitoring systems (e.g., for processes through computerized systems or new forms of process control systems)
- Artificial intelligence (e.g., adaptive systems used in conjunction with computerized systems or process control systems), which evaluates generated data and makes decisions as part of these monitoring systems
- Robotics (e.g., automated docking of closures) to keep the human factor away from the product
Monitoring systems can be of varying complexity and may have varying levels of AI involvement. Simple systems can be automated decision trees (e.g., sensors) and complex systems can be learning neural networks (e.g., camera systems). A computerized system may control the sterilization process. For example, a control system can be automated in visual control, such as with optical inspection and particle detection. To ensure the AI is operating effectively, it’s critical that the data teaches the system to differentiate between cracks, fissure, fibers, parts of insects, etc.
Another area is represented by the revision of Annex 11, where digitalization will advance significantly in the future related to regulatory aspects in Annex 1. Surveillance authorities need to have regulatory approaches to evaluate new ways of digitalization.
The following are considerations when identifying the systems with more risk and the manufacturer’s integration approach:
- Do the risk assessment and a risk-based approach as the basis of qualification, validation, and operation reflect the continuous control strategy?
- Are GMP-critical elements of a system, that affect product quality and data integrity, adequately identified and emphasized in the validation approach?
- Is there a governance system for validation, data management, and data integrity?
The following are considerations for the manufacturer’s reliance on vendors:
- Are all GxP-relevant internal or external IT services assessed?
- Are hosted services as a black box not accepted?
- Is the vendors’ documentation complete in order to assess GxP risks and GxP compliance?
- Are the regulatory expectations of the “formal SLA” met (e.g., SaaS: the distribution and assessment of tasks demonstrated to inspectors)?
The following are considerations for producing and protecting electronic records:
- How well-defined is data management?
- Is the integrity of electronic data understood as a pivotal issue and underpinned by a holistic approach?
- Does the governance system of data integrity cover electronic data, paper-based data, and data migration?
- Is the governance system in line with continuous user management?
- Is the significance of networks and all relevant infrastructure considered?
- Does the interaction between the regulated user and the vendor ensure data integrity and is it sufficiently understood by both sides?
- Are all support processes regarding data identified and considered in validation (completeness of data sets in migration; backup, restore, archiving and the focus on the ability to restore for a given period)?
The following are considerations for artificial intelligence:
- The regulated user’s approach to development of the AI/ML
- Suitability of the model and model development (assessment of completeness and representativeness of training data, labeling of data with meta data, personnel qualification, documentation standard)
- Validation strategy as part of the risk-based integration into the process
- If relevant: adequate assessment of cloud solutions
- Verification of function during operation: does the model work, are malfunctions recognized, is the process under control?
Conclusion
The combined conference event brought discussion of these key Pharma 4.0™ and Annex 1 topics to the nearly 500 participants. The speakers delivered expert opinions, regulators views and use cases in the sessions that provided a wealth of information for an impactful event. There will be a follow up conference in December 2023 in Barcelona (Spain).