Unlocking Innovation: Embracing Validation 4.0 for a Digital Pharma Future

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October 2025

In this episode, Michelle Vuolo, Head of Quality at Tulip Interfaces and ISPE Good Practice Guide: Validation 4.0 co-lead, along with Guide team member, Victor de Oliveira Silva Ferreira, Project Manager at the Instituto De Tecnologia Em Imunobiológico/Fundação Oswaldo Cruz, join the podcast share their insights on how Validation 4.0 aims to leverage digital tools to transition from traditional validation methods to more dynamic, real-time processes. Explore how to utilize the principles of Quality by Design and Quality Risk Management to create dynamic, continuous validation practices, powered by digital innovations. Vuolo will present on this topic during a session titled “Transforming Pharma 4.0™: ISPE’s New Pharma 4.0™ Guides” at the upcoming 2025 ISPE Pharma 4.0™ Conference.

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  • Guests

    Michelle Vuolo
    Head of Quality
    Tulip Interfaces
    Victor De Oliveira Silva Ferreira
    Validation Division Manager
    Instituto De Tecnologia Em Imunobiológico/Fundação Oswaldo Cruz
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    Welcome to the ISPE podcast, Shaping the Future of Pharma,

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    where ISPE supports you on your journey,

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    fueling innovation, sharing insights, thought leadership,

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    and empowering a global community to reimagine what's possible.

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    Hello and welcome to the ISPE podcast, Shaping the Future of Pharma.

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    I'm Bob Chew, your host, and today we have another episode

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    where we'll be sharing the latest insights and thought leadership

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    on manufacturing, technology, supply chains,

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    and regulatory trends impacting the pharmaceutical industry.

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    You'll hear directly from the innovators, experts,

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    and professionals driving progress and shaping the future.

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    Thank you again for joining us, and now let's dive into this episode.

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    Our topic today is Unlocking Innovation,

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    Embracing Validation 4.0 for a Digital Pharma Future.

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    To share more about this topic, I would like to welcome Michelle Vuolo,

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    head of quality at Tulip Interfaces and co-lead of the Validation 4.0 guide team.

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    And fellow guide team member representing South America

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    is Victor de Oliveira Silva Ferreira,

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    Project Manager for PEQMS, Implementation of Electronic Systems

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    for the Quality Management System at the Instituto de Tecnologia

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    Em Imunobiológico Fundação Oswaldo Cruz.

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    Michelle and Victor, welcome to the podcast.

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    We're so glad to have you both with us.

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    Thanks. Thanks for having us.

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    I hope that's a thank you for invitation.

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    Well, first, before we jump into some of the questions about the guide,

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    I'm curious, how did you guys get involved in this guide?

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    What's your background? What's your passion? Why this one?

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    Michelle?

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    Sure. Yeah, I'll go ahead and start.

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    Yeah, I work at Tulip Interfaces,

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    which is a technology company providing software for manufacturing environments.

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    I've been here about five years, but before that,

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    I spent about 25 years in life sciences and doing all things quality

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    from lab to manufacturing operations quality to all the way to IT quality,

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    probably my natural progression and decided to get engaged

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    with the Pharma 4.0 community of practice.

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    And so I wanted to help modernize the way we look at quality and validation topics

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    and thought that it would best fit in the Pharma 4.0 community of practice.

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    So fast forward five years and lots of PE,

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    pharmaceutical engineering articles and conference speaking

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    and lots of really great active members in the ISPE community.

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    Later, we published the good practice.

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    And Victor?

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    I have to work with qualification and validation for entire of my career,

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    mainly with the development new strategies to release new products in my company.

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    For the last five years, I was dedicated to understand

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    how technology can enhance quality and validation strategies.

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    So I joined in validation 14 and have been working with Michelle for these years in GPD.

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    Well, great.

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    Well, let's start out with kind of the big picture.

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    What exactly is validation 4.0?

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    Yeah, I can start because I do recall when we first got our working group

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    now called subcommittee together.

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    That was the big question.

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    Like, what is it?

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    Because validation is such a broad topic covering so many aspects.

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    And it was very clear that it wasn't computerized system validation specifically,

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    because there's Gantt for that very well established group.

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    But that we wanted to look at how we could modernize validation

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    and look at how to become more efficient and effective with validation

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    in this digital world, right?

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    Like, it doesn't have to be digital, but what's happening

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    or what's driving the change to look at validation was the digital transition.

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    And I think bigger picture even on that is really trying to help enable

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    real-time validation, again, with the usage of digital technologies,

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    real-time validation, continuous validation, looking at upstream and downstream

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    sort of impacts on validation of what you're trying to validate.

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    So it's sort of the bigger picture.

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    It's rooted in the guideposts of the IEH guidelines,

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    in particular quality risk management and quality by design

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    to fundamental and foundational principles to enable validation.

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    Really, when you look at validation as just like going back and saying,

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    what is validation?

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    It's really the demonstration of control.

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    And so those are two fundamental principles and foundational aspects

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    that need to be understood to really do validation on any focused way.

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    Yeah.

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    I don't like I did that.

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    I see validation for is looking to data on the quality by design lens.

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    So you need to ensure that the probability data

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    is available for users during the entire life cycle.

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    So there is an operational approach that approach itself.

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    How do you need to do validation for?

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    But there is an aspect, the business aspect regarding

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    how you deal with validation quality as a business strategy,

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    because it was discussed in years.

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    Validation quality need to be work as business strategy

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    to enhance control around the product process.

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    So what triggered the creation of Validation 4.0?

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    Was it the Pharma 4.0 good practice guide,

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    or was it other factors in industry?

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    Yeah.

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    So, you know, we started working together as a group.

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    There's, you know, there's an ebb and flow of folks

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    that come and join on these groups,

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    which is understood because people are volunteering their time to do this

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    and have day jobs, so to speak.

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    But, you know, I think our group was doing a lot.

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    Like I said, we did a lot of

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    pharmaceutical engineering magazine articles.

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    We are trying to develop and define case studies.

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    Then we moved on.

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    We did a couple of presentations at most of the ISTE annual meetings,

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    both in the EU and in the US.

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    Also in the Eastern communities, too,

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    because the co-lead of the Validation 4.0 working group is out of Bangkok.

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    So we're able to do a lot of seminars and webinars out there in India as well.

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    I'm forgetting.

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    It's been five years.

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    But then we got involved in one of the chapters,

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    the quality chapter of the Pharma 4.0 baseline guide, right?

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    So there's baseline guides, which are sort of higher level overarching,

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    which is what GAMP is, for example.

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    I think a lot of people with ISPE are very familiar with GAMP.

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    And then under that umbrella,

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    there's lots of good practice guides that are on specific topics.

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    Like, for example, GAMP has an MES specific good practice guide.

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    So, yeah, the Pharma 4.0 baseline guide was published in December of 23, I think it was.

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    That's when we started saying,

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    what are good opportunities for documenting more information

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    on how to execute this Pharma 4.0 approach on particular topics?

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    And so Validation 4.0 is prime for that.

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    We've had our approach, our guideposts, our methodology defined.

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    We've had a few case studies.

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    So we started writing the good practice guide.

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    And, you know, with the intentions of really trying to demonstrate to the industry

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    how to do this more specifically than, you know, sort of this conceptual idea.

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    If I go back many decades, there was an FDA aseptic process validation guide,

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    if I recall correctly, talking about media fills or aseptic process simulation.

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    And it specified a minimum of three lots.

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    Now, in that case, one lot was at least 5,000 units.

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    So you really were looking at the aseptic contamination possibility

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    spread across 15,000 instances.

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    But those three lots then kind of morphed into validation, process validation.

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    And we need to do three lots.

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    Now, we all would agree that three lots is not statistically significant

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    and does not capture potential variability in raw materials and all this stuff.

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    Now, up front, you're supposed to have development work

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    that covers that base.

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    And then you do these three lots.

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    And then you do continuous process verification.

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    Tell me how this validation 4.0 changes that.

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    I can go first.

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    And, Victor, jump in for sure if you want to help support or add anything different.

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    But, yeah, so what we're trying to get away from in this validation paradigm

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    towards a new paradigm is, you know, I think traditionally the three,

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    you know, the tradition, the golden three-batch run,

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    like that's always sort of like people immediately think of that

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    when they think of, oh, how am I going to validate?

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    What we're trying to do is shift the thinking away from,

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    I have to do three runs of process validation

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    towards how have I demonstrated the controls in my process?

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    The only way to do that really is to understand your process requirements,

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    which in my opinion are around quality by design, right?

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    Quality by design, basically the fundamental of quality by design

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    is the more you know about your product and process,

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    the more you can control it, right?

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    So the idea through CPP, CQAs, these critical aspects to your process

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    are defined and identified as critical, right?

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    Using your quality risk management principles

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    and identifying the controls around each of those individually

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    and developing controls around them.

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    The validation of that is not just running through it three times.

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    The validation of that is really building an evidence story

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    around each of those controls and how you demonstrate them, really.

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    So the idea is like the culmination of all these controls,

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    the evidence of these controls really starts to become your validation package,

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    not whether you ran it three times.

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    You could have run it several times on, I don't know,

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    different parameters and different things on a particular control area

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    or a particular critical area of the process.

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    But you're building this evidence file on an ongoing basis.

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    If you can do this during product development, right?

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    These iterations of like through risk management though, right?

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    A controlled process of identify a risk and put a control in place,

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    determining if it's effective or not,

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    and iterating on that in this sort of continuous loop.

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    That's where we also want to get into this continuous validation

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    or the idea that we can, at any one point in time,

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    understand our state of control.

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    Yeah, we, using Go, said that we are going to move

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    from the stage of validation to stage of validation.

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    Because in the moment that we're starting,

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    Go have control about the data since the development.

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    You have confidence to scale up all validation activities

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    through their all study, clinical studies,

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    and to reach the commercial match understanding for the entire process.

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    This is what you should know about holistic control strategy,

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    is have all control for all strategies need to be implemented during the life cycle.

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    Okay, you mentioned quality risk management.

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    There's a lot of different views on that.

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    There's a lot of different practices on that.

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    I think those of us who have done it would agree that in most cases,

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    certainly many cases, it's subjective.

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    The probability, the effectiveness of the controls,

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    and the probability given those controls, et cetera.

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    How is validation 4.0 dealing with those,

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    that subjective nature of quality risk management?

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    And can technology turn subjectivity into objectivity?

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    Yeah, I can go first or Victor,

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    I want to give you the opportunity to go first if you want.

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    Okay, I think that we are thinking validation 4

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    in quality risk management.

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    We are not speaking about using spreadsheets,

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    but using digital tools to enhance the entire management.

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    So, this allows to have capability to integrate systems with MERS,

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    LIMS, and other kind of stuff to get data since the development,

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    going through this system, provide the control.

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    Obviously, there is some kind of complexity in doing this,

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    but in the moment that you take quality validation group and IT group,

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    look into the strategy of the whole process,

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    you can provide control for all decision

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    and activity that will occur in your manufacturing process.

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    I believe this is the main point that quality risk management

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    and validation can enhance.

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    The possibility to, since the first time they start a process or product,

    218
    00:14:22,000 --> 00:14:24,000
    you're working together to think,

    219
    00:14:24,000 --> 00:14:29,000
    okay, what can affect my process, my product?

    220
    00:14:29,000 --> 00:14:32,000
    How the sensor could be failed during my process

    221
    00:14:32,000 --> 00:14:37,000
    and how this information put through quality risk management digital

    222
    00:14:37,000 --> 00:14:43,000
    and send the trigger action that you can do in real time.

    223
    00:14:43,000 --> 00:14:49,000
    So, these are, as I see, validation for enhancing quality risk management.

    224
    00:14:49,000 --> 00:14:51,000
    Yeah, I think just to add to that too,

    225
    00:14:51,000 --> 00:14:52,000
    is like one of the things that we have,

    226
    00:14:53,000 --> 00:14:55,000
    like in all the presentations I've given on this,

    227
    00:14:55,000 --> 00:14:57,000
    like one of the things we do say is like

    228
    00:14:57,000 --> 00:15:01,000
    we are not prescribing a particular risk methodology at all.

    229
    00:15:01,000 --> 00:15:05,000
    Like we're not saying FMEA is great or not or whatever.

    230
    00:15:05,000 --> 00:15:07,000
    What we do, like what I do with myself

    231
    00:15:07,000 --> 00:15:11,000
    and what I do like about ICHQNAN is risk identification,

    232
    00:15:11,000 --> 00:15:14,000
    risk assessment, and risk control.

    233
    00:15:15,000 --> 00:15:18,000
    Just logically that process works really well.

    234
    00:15:18,000 --> 00:15:22,000
    And if you're doing a three-by-three matrix or a two-by-two matrix

    235
    00:15:22,000 --> 00:15:25,000
    or you're using detectability or frequency or likelihood,

    236
    00:15:25,000 --> 00:15:28,000
    we don't get into that level of detail.

    237
    00:15:28,000 --> 00:15:32,000
    But what we're saying is we need to identify and understand

    238
    00:15:32,000 --> 00:15:36,000
    the risk associated with certain data points, right,

    239
    00:15:36,000 --> 00:15:37,000
    associated with your process.

    240
    00:15:38,000 --> 00:15:42,000
    And so, and the idea is, again, as you are identifying the risk,

    241
    00:15:43,000 --> 00:15:45,000
    you're like a sterility assurance,

    242
    00:15:45,000 --> 00:15:48,000
    you identify the control, whichever it might be,

    243
    00:15:49,000 --> 00:15:53,000
    and then you ultimately then verify the effectiveness of that control

    244
    00:15:53,000 --> 00:15:56,000
    right away through several iterations or several runs.

    245
    00:15:57,000 --> 00:16:02,000
    But the idea is that as soon as you get an effective or ineffective data point,

    246
    00:16:02,000 --> 00:16:04,000
    that gets fed back into the risk,

    247
    00:16:05,000 --> 00:16:06,000
    identified if the risk changes,

    248
    00:16:06,000 --> 00:16:09,000
    which not often does the risk change itself,

    249
    00:16:09,000 --> 00:16:12,000
    but the risk control is either effective or ineffective.

    250
    00:16:12,000 --> 00:16:16,000
    And you determine if you need to adjust your risk control.

    251
    00:16:17,000 --> 00:16:20,000
    So again, it's not a three-by-three matrix.

    252
    00:16:20,000 --> 00:16:22,000
    It's not subjective or objective.

    253
    00:16:22,000 --> 00:16:27,000
    It's, you know, the basis is product quality, patient safety always.

    254
    00:16:28,000 --> 00:16:32,000
    So in those terms is where, again,

    255
    00:16:32,000 --> 00:16:34,000
    that continuous loop allows you to feedback

    256
    00:16:34,000 --> 00:16:36,000
    and adjust your controls as necessary.

    257
    00:16:37,000 --> 00:16:40,000
    But again, I just think of many examples

    258
    00:16:40,000 --> 00:16:43,000
    of having been in risk assessments in my previous life.

    259
    00:16:44,000 --> 00:16:46,000
    And there is not that continuous loop.

    260
    00:16:46,000 --> 00:16:48,000
    There's not that feedback loop.

    261
    00:16:48,000 --> 00:16:52,000
    You know, we spend hours and hours and hours in a meeting room

    262
    00:16:52,000 --> 00:16:54,000
    trying to determine the risk level of something

    263
    00:16:55,000 --> 00:16:59,000
    and not really following up or understanding

    264
    00:16:59,000 --> 00:17:00,000
    whatever control we put in place.

    265
    00:17:00,000 --> 00:17:01,000
    Was it effective?

    266
    00:17:01,000 --> 00:17:02,000
    Was it not?

    267
    00:17:02,000 --> 00:17:04,000
    Did it impact other things?

    268
    00:17:04,000 --> 00:17:05,000
    Like there's no assessment.

    269
    00:17:05,000 --> 00:17:07,000
    And that is ultimately the most important piece.

    270
    00:17:08,000 --> 00:17:12,000
    You know, coupling what Victor said is like in the digital world,

    271
    00:17:12,000 --> 00:17:16,000
    digital is enabling us to do that more immediate feedback loop, right?

    272
    00:17:16,000 --> 00:17:19,000
    And to look at things independently as well

    273
    00:17:19,000 --> 00:17:23,000
    or look at individual controls as well,

    274
    00:17:23,000 --> 00:17:25,000
    which I think is very important.

    275
    00:17:26,000 --> 00:17:28,000
    This is, in my opinion, has not necessarily

    276
    00:17:29,000 --> 00:17:31,000
    been done on a big scale until now.

    277
    00:17:32,000 --> 00:17:36,000
    So risk assessments, as we just talked about,

    278
    00:17:37,000 --> 00:17:39,000
    there's statistics behind them.

    279
    00:17:39,000 --> 00:17:43,000
    They're probabilistically determined, right?

    280
    00:17:45,000 --> 00:17:46,000
    It's a high probability.

    281
    00:17:46,000 --> 00:17:47,000
    It's a low probability.

    282
    00:17:47,000 --> 00:17:49,000
    There's a statistic to that.

    283
    00:17:51,000 --> 00:17:56,000
    The concept of a design space assumes

    284
    00:17:56,000 --> 00:18:01,000
    that you have some sort of statistical understanding

    285
    00:18:01,000 --> 00:18:04,000
    of the interrelationships between different variables.

    286
    00:18:04,000 --> 00:18:06,000
    Some of the relationships are strong,

    287
    00:18:06,000 --> 00:18:09,000
    i.e. a high correlation coefficient.

    288
    00:18:10,000 --> 00:18:13,000
    Some of them are weak, a low correlation coefficient,

    289
    00:18:13,000 --> 00:18:16,000
    but it's statistics, right?

    290
    00:18:17,000 --> 00:18:20,000
    Now, today we have AI,

    291
    00:18:20,000 --> 00:18:24,000
    we have digital twins, process and equipment,

    292
    00:18:25,000 --> 00:18:29,000
    and they're statistical tools, right?

    293
    00:18:30,000 --> 00:18:32,000
    That's all they are.

    294
    00:18:32,000 --> 00:18:35,000
    They're very sophisticated, but they're statistical tools.

    295
    00:18:36,000 --> 00:18:40,000
    So we have a need over here from a design space

    296
    00:18:40,000 --> 00:18:44,000
    and a risk assessment to have statistical analysis.

    297
    00:18:44,000 --> 00:18:46,000
    And now we've got all these really cool tools

    298
    00:18:47,000 --> 00:18:49,000
    that are statistical tools.

    299
    00:18:49,000 --> 00:18:51,000
    How do we bring them together?

    300
    00:18:51,000 --> 00:18:52,000
    Yeah, yeah.

    301
    00:18:53,000 --> 00:18:56,000
    Well, so it was easy.

    302
    00:18:56,000 --> 00:18:57,000
    Like one of my first things was like,

    303
    00:18:57,000 --> 00:19:00,000
    oh, we just need digital risk assessment tools.

    304
    00:19:00,000 --> 00:19:01,000
    And yes, that can help enable.

    305
    00:19:01,000 --> 00:19:04,000
    Like I ultimately would like to see

    306
    00:19:04,000 --> 00:19:06,000
    that some of these digital tools for risk management

    307
    00:19:06,000 --> 00:19:08,000
    become validation tools, right?

    308
    00:19:10,000 --> 00:19:11,000
    But even more importantly,

    309
    00:19:11,000 --> 00:19:13,000
    and we have a few cases,

    310
    00:19:13,000 --> 00:19:15,000
    I think we have two case studies in the guidance

    311
    00:19:15,000 --> 00:19:19,000
    on utilizing a digital quality by design tool.

    312
    00:19:20,000 --> 00:19:23,000
    What was really exciting about those case studies

    313
    00:19:23,000 --> 00:19:25,000
    is that it was demonstrating the ability

    314
    00:19:25,000 --> 00:19:30,000
    to use a digital quality by design tool to do that, right?

    315
    00:19:30,000 --> 00:19:33,000
    And it was providing you the correlations

    316
    00:19:33,000 --> 00:19:35,000
    between different control groups and different things.

    317
    00:19:35,000 --> 00:19:39,000
    And it gave you the visibility or in a visual way

    318
    00:19:40,000 --> 00:19:42,000
    about how like when you identify

    319
    00:19:42,000 --> 00:19:44,000
    through quality by design,

    320
    00:19:44,000 --> 00:19:45,000
    what's critical, what's not,

    321
    00:19:46,000 --> 00:19:48,000
    what controls you put in place,

    322
    00:19:48,000 --> 00:19:51,000
    and you can also link in what controls

    323
    00:19:51,000 --> 00:19:55,000
    are impacting other critical aspects as well.

    324
    00:19:55,000 --> 00:19:57,000
    But it provides you the ability

    325
    00:19:57,000 --> 00:19:59,000
    to do statistical analysis

    326
    00:19:59,000 --> 00:20:02,000
    on your control effectiveness as well,

    327
    00:20:02,000 --> 00:20:06,000
    as you can plug in the evidence data

    328
    00:20:06,000 --> 00:20:07,000
    after you execute this thing,

    329
    00:20:08,000 --> 00:20:10,000
    you can determine whether those controls

    330
    00:20:10,000 --> 00:20:11,000
    are effective or not,

    331
    00:20:11,000 --> 00:20:12,000
    they might impact other things.

    332
    00:20:13,000 --> 00:20:16,000
    So this is where we didn't wanna start

    333
    00:20:16,000 --> 00:20:18,000
    with digital tools, right?

    334
    00:20:18,000 --> 00:20:20,000
    Because we wanna get the fundamental aspects down,

    335
    00:20:21,000 --> 00:20:23,000
    but we have a whole section on the main part

    336
    00:20:23,000 --> 00:20:26,000
    of the document that's about enablers,

    337
    00:20:26,000 --> 00:20:27,000
    digital tools and key enablers,

    338
    00:20:27,000 --> 00:20:29,000
    which we feel like, yeah,

    339
    00:20:29,000 --> 00:20:31,000
    if you wanna get to the state where we're,

    340
    00:20:32,000 --> 00:20:34,000
    I don't wanna say promising,

    341
    00:20:34,000 --> 00:20:37,000
    but the nirvana of this would be to get to the state

    342
    00:20:37,000 --> 00:20:39,000
    of like just running continuously

    343
    00:20:39,000 --> 00:20:41,000
    and being able to do a snapshot validation

    344
    00:20:41,000 --> 00:20:42,000
    at any one point in time,

    345
    00:20:42,000 --> 00:20:44,000
    you need to do that through digital tools, right?

    346
    00:20:44,000 --> 00:20:46,000
    And I think the most effective ones

    347
    00:20:46,000 --> 00:20:47,000
    that I have seen to date are,

    348
    00:20:48,000 --> 00:20:51,000
    like I said, in the examples and the case studies

    349
    00:20:51,000 --> 00:20:54,000
    on the quality by design tool that we used

    350
    00:20:54,000 --> 00:20:55,000
    so that you could do that.

    351
    00:20:55,000 --> 00:20:57,000
    So you could do the statistics

    352
    00:20:57,000 --> 00:20:59,000
    so that you could see your effectiveness

    353
    00:20:59,000 --> 00:21:01,000
    of controls in real time.

    354
    00:21:03,000 --> 00:21:06,000
    So currently we've got three stages

    355
    00:21:06,000 --> 00:21:08,000
    of validation, right?

    356
    00:21:08,000 --> 00:21:11,000
    We've got what happens in development,

    357
    00:21:11,000 --> 00:21:14,000
    then we've got the demonstration lots,

    358
    00:21:14,000 --> 00:21:16,000
    and then we've got the ongoing.

    359
    00:21:17,000 --> 00:21:22,000
    How does validation 4.0 change any of that?

    360
    00:21:22,000 --> 00:21:24,000
    Or are they still those three phases?

    361
    00:21:25,000 --> 00:21:27,000
    And will they ever change?

    362
    00:21:29,000 --> 00:21:30,000
    My hope is yes.

    363
    00:21:30,000 --> 00:21:30,000
    Do you wanna go, Victor?

    364
    00:21:32,000 --> 00:21:37,000
    Yeah, I like to think that in validation 4,

    365
    00:21:37,000 --> 00:21:40,000
    we are discussing about this stage of validation,

    366
    00:21:40,000 --> 00:21:42,000
    thinking all in scalability.

    367
    00:21:43,000 --> 00:21:45,000
    When you're looking for a new product,

    368
    00:21:45,000 --> 00:21:48,000
    quality by phase appropriate is a tool

    369
    00:21:48,000 --> 00:21:51,000
    to determine the level of effort

    370
    00:21:51,000 --> 00:21:52,000
    that you need to put.

    371
    00:21:53,000 --> 00:21:55,000
    But there is some difficulty to do

    372
    00:21:55,000 --> 00:21:57,000
    in the paper-based way.

    373
    00:21:57,000 --> 00:21:59,000
    So in the moment that you have control

    374
    00:21:59,000 --> 00:22:02,000
    about all points of data,

    375
    00:22:03,000 --> 00:22:06,000
    all aspects, all risk in your process,

    376
    00:22:06,000 --> 00:22:10,000
    you can escalate this control organically

    377
    00:22:10,000 --> 00:22:12,000
    because you have digital tools to do that.

    378
    00:22:13,000 --> 00:22:16,000
    So I like to say that validation 4.0

    379
    00:22:16,000 --> 00:22:18,000
    is about validation stage.

    380
    00:22:18,000 --> 00:22:22,000
    I always consider that my process is validated,

    381
    00:22:22,000 --> 00:22:26,000
    considering the level of the rigor of my phase.

    382
    00:22:26,000 --> 00:22:29,000
    If my product goes to the phase one,

    383
    00:22:29,000 --> 00:22:32,000
    to the phase two, I have control.

    384
    00:22:32,000 --> 00:22:35,000
    And I know exactly what level of control

    385
    00:22:35,000 --> 00:22:38,000
    I need to put because I have digital system,

    386
    00:22:38,000 --> 00:22:41,000
    a digital ecosystem provide me visibility.

    387
    00:22:41,000 --> 00:22:43,000
    How my strategy is going on

    388
    00:22:43,000 --> 00:22:45,000
    and how this strategy can evolve

    389
    00:22:45,000 --> 00:22:47,000
    uses the point to me.

    390
    00:22:47,000 --> 00:22:48,000
    Yeah.

    391
    00:22:49,000 --> 00:22:52,000
    Just on that, I heard an interesting quote

    392
    00:22:52,000 --> 00:22:54,000
    and it's not direct word for word,

    393
    00:22:54,000 --> 00:22:57,000
    but I'm reading the words a little bit.

    394
    00:22:57,000 --> 00:22:59,000
    But the point was somebody asked

    395
    00:22:59,000 --> 00:23:00,000
    at a conference I was at that said,

    396
    00:23:00,000 --> 00:23:05,000
    can we get from R&D to manufacturing,

    397
    00:23:06,000 --> 00:23:10,000
    shift to research and design and manufacturing?

    398
    00:23:11,000 --> 00:23:13,000
    I don't know if you appreciate

    399
    00:23:13,000 --> 00:23:14,000
    the subtlety difference there,

    400
    00:23:14,000 --> 00:23:18,000
    but the idea is that can we get from this state

    401
    00:23:18,000 --> 00:23:20,000
    that's like, again, R&D is this whole thing

    402
    00:23:20,000 --> 00:23:22,000
    and then there's this tech transfer

    403
    00:23:22,000 --> 00:23:24,000
    and then there's this manufacturing space.

    404
    00:23:24,000 --> 00:23:28,000
    Can we get rid of this zone in the middle

    405
    00:23:28,000 --> 00:23:29,000
    where we're getting from research,

    406
    00:23:29,000 --> 00:23:33,000
    really just beginning stages of quality by design

    407
    00:23:34,000 --> 00:23:38,000
    to development and manufacturing as a stage, right?

    408
    00:23:38,000 --> 00:23:39,000
    And this is, in my opinion,

    409
    00:23:39,000 --> 00:23:41,000
    this is like, again, now you're speaking to Nirvana,

    410
    00:23:41,000 --> 00:23:44,000
    but hey, we need a North Star here.

    411
    00:23:44,000 --> 00:23:45,000
    Get to the state of just getting

    412
    00:23:45,000 --> 00:23:47,000
    to these iterative cycles really early

    413
    00:23:47,000 --> 00:23:50,000
    in the QBD process, right?

    414
    00:23:50,000 --> 00:23:53,000
    So if you are starting,

    415
    00:23:53,000 --> 00:23:55,000
    you've got the infrastructure in place

    416
    00:23:55,000 --> 00:23:59,000
    to identify risks, identify risk controls

    417
    00:24:00,000 --> 00:24:02,000
    and have a repository for,

    418
    00:24:03,000 --> 00:24:08,000
    or a place to capture evidence of control effectiveness

    419
    00:24:08,000 --> 00:24:09,000
    and loop that back,

    420
    00:24:09,000 --> 00:24:11,000
    very early in the process,

    421
    00:24:11,000 --> 00:24:14,000
    it can be a design or a process development tool,

    422
    00:24:14,000 --> 00:24:14,000
    in my opinion,

    423
    00:24:15,000 --> 00:24:17,000
    which means that you're just building evidence

    424
    00:24:17,000 --> 00:24:19,000
    of your control file from the very beginning.

    425
    00:24:19,000 --> 00:24:24,000
    I mean, in reality, you've got two control strategies.

    426
    00:24:24,000 --> 00:24:26,000
    You've got process control strategy

    427
    00:24:26,000 --> 00:24:29,000
    and contamination control strategy, right?

    428
    00:24:31,000 --> 00:24:33,000
    For contamination control,

    429
    00:24:34,000 --> 00:24:38,000
    that's somewhat molecule agnostic.

    430
    00:24:38,000 --> 00:24:42,000
    It's strictly, are you filling vials

    431
    00:24:42,000 --> 00:24:44,000
    or are you pressing pills, right?

    432
    00:24:46,000 --> 00:24:48,000
    On the process side,

    433
    00:24:48,000 --> 00:24:50,000
    yeah, they're different molecules.

    434
    00:24:50,000 --> 00:24:54,000
    And once in a while, it's really different,

    435
    00:24:54,000 --> 00:24:59,000
    but still the basic key parameters

    436
    00:25:00,000 --> 00:25:03,000
    around pills or filling vials,

    437
    00:25:05,000 --> 00:25:06,000
    I'm not saying they're the same,

    438
    00:25:06,000 --> 00:25:09,000
    but there's certainly a whole science

    439
    00:25:09,000 --> 00:25:10,000
    behind it that we understand.

    440
    00:25:11,000 --> 00:25:13,000
    How could we not start

    441
    00:25:13,000 --> 00:25:16,000
    from a blank sheet of paper every time?

    442
    00:25:16,000 --> 00:25:17,000
    Yeah.

    443
    00:25:17,000 --> 00:25:20,000
    And how does validation 4.0

    444
    00:25:20,000 --> 00:25:23,000
    bring in the lessons from other places?

    445
    00:25:25,000 --> 00:25:27,000
    Yeah, I'm just giving you the term

    446
    00:25:27,000 --> 00:25:30,000
    is maybe loosely adopted from pharma 4.0,

    447
    00:25:30,000 --> 00:25:31,000
    but like plug and produce in a way,

    448
    00:25:32,000 --> 00:25:34,000
    but in a very different sort of scope,

    449
    00:25:34,000 --> 00:25:37,000
    but can you plug and play

    450
    00:25:37,000 --> 00:25:38,000
    with different controls?

    451
    00:25:39,000 --> 00:25:42,000
    Yes, it would seem like that, right?

    452
    00:25:42,000 --> 00:25:45,000
    You're going to have to provide evidence

    453
    00:25:45,000 --> 00:25:48,000
    for that on all of your products anyway.

    454
    00:25:48,000 --> 00:25:49,000
    You're just going to have to, right?

    455
    00:25:49,000 --> 00:25:52,000
    But can you plug in a control strategy

    456
    00:25:52,000 --> 00:25:58,000
    for like pills or like vials

    457
    00:25:58,000 --> 00:26:00,000
    or can you do that?

    458
    00:26:00,000 --> 00:26:02,000
    It seems like, yes, with the digital world,

    459
    00:26:02,000 --> 00:26:03,000
    you potentially could.

    460
    00:26:03,000 --> 00:26:06,000
    Given the same parameters of X, Y, and Z,

    461
    00:26:06,000 --> 00:26:07,000
    can you take your control

    462
    00:26:08,000 --> 00:26:10,000
    and control evidence and plug it

    463
    00:26:10,000 --> 00:26:12,000
    into a different product and process?

    464
    00:26:12,000 --> 00:26:12,000
    It seems like you could.

    465
    00:26:13,000 --> 00:26:15,000
    Obviously, there's nuances to that, of course,

    466
    00:26:15,000 --> 00:26:17,000
    but like, again, just the infrastructure

    467
    00:26:17,000 --> 00:26:18,000
    would be there.

    468
    00:26:20,000 --> 00:26:24,000
    Yeah, I like I did that,

    469
    00:26:24,000 --> 00:26:25,000
    but edition four, as I said,

    470
    00:26:25,000 --> 00:26:28,000
    we said about data control of data,

    471
    00:26:28,000 --> 00:26:31,000
    the next one is too much about data.

    472
    00:26:31,000 --> 00:26:33,000
    There's several aspects

    473
    00:26:33,000 --> 00:26:35,000
    in the requirements on X, Y, and Z

    474
    00:26:35,000 --> 00:26:38,000
    saying that you need to evaluate

    475
    00:26:38,000 --> 00:26:41,000
    all data for several control strategies

    476
    00:26:41,000 --> 00:26:42,000
    in a holistic way

    477
    00:26:42,000 --> 00:26:43,000
    because obviously,

    478
    00:26:43,000 --> 00:26:45,000
    all pharmaceutical companies

    479
    00:26:45,000 --> 00:26:47,000
    has on a certain level

    480
    00:26:47,000 --> 00:26:49,000
    a contamination control strategy.

    481
    00:26:49,000 --> 00:26:51,000
    But what an X, Y, and Z brings is

    482
    00:26:51,000 --> 00:26:54,000
    we need to evaluate all these data.

    483
    00:26:54,000 --> 00:26:57,000
    So validation for under this vision

    484
    00:26:57,000 --> 00:27:00,000
    provide the tools and the approach

    485
    00:27:00,000 --> 00:27:03,000
    to ensure that all controls,

    486
    00:27:03,000 --> 00:27:05,000
    to ensure a serenity,

    487
    00:27:05,000 --> 00:27:07,000
    ensure that there is no contamination

    488
    00:27:07,000 --> 00:27:10,000
    in your facility is under control

    489
    00:27:10,000 --> 00:27:11,000
    and evaluate together

    490
    00:27:11,000 --> 00:27:12,000
    several source of data.

    491
    00:27:14,000 --> 00:27:20,000
    OK, are there any other new philosophies,

    492
    00:27:20,000 --> 00:27:22,000
    new approaches, differences

    493
    00:27:23,000 --> 00:27:24,000
    that you would find

    494
    00:27:24,000 --> 00:27:26,000
    in validation 4.0 guide

    495
    00:27:27,000 --> 00:27:29,000
    versus the past practices?

    496
    00:27:30,000 --> 00:27:32,000
    It's time for you to really show off

    497
    00:27:32,000 --> 00:27:33,000
    the newness.

    498
    00:27:33,000 --> 00:27:34,000
    What's cool?

    499
    00:27:37,000 --> 00:27:38,000
    Do you want to go, Victor?

    500
    00:27:41,000 --> 00:27:42,000
    OK, yeah.

    501
    00:27:42,000 --> 00:27:45,000
    So I think what I started with is

    502
    00:27:45,000 --> 00:27:47,000
    we didn't create quality by design

    503
    00:27:47,000 --> 00:27:49,000
    nor did we create quality risk management,

    504
    00:27:49,000 --> 00:27:52,000
    which are the fundamental key purposes.

    505
    00:27:53,000 --> 00:27:54,000
    What we've tried to do is

    506
    00:27:54,000 --> 00:27:56,000
    take an existing frameworks.

    507
    00:27:56,000 --> 00:27:57,000
    Of course, we're not going to change

    508
    00:27:57,000 --> 00:27:58,000
    the regulatory landscape.

    509
    00:27:58,000 --> 00:27:59,000
    That's not our point.

    510
    00:27:59,000 --> 00:28:00,000
    Or our objective.

    511
    00:28:00,000 --> 00:28:03,000
    So we took the existing regulatory landscape

    512
    00:28:03,000 --> 00:28:05,000
    and tried to articulate it

    513
    00:28:05,000 --> 00:28:08,000
    in terms of where we are today,

    514
    00:28:08,000 --> 00:28:10,000
    the capabilities that we have today.

    515
    00:28:11,000 --> 00:28:12,000
    Also, I think the big piece

    516
    00:28:12,000 --> 00:28:13,000
    is shifting the mindset away

    517
    00:28:13,000 --> 00:28:15,000
    from methodology.

    518
    00:28:18,000 --> 00:28:20,000
    I do, I say that because it's funny

    519
    00:28:20,000 --> 00:28:21,000
    that one of the first questions

    520
    00:28:21,000 --> 00:28:22,000
    that was asked was,

    521
    00:28:22,000 --> 00:28:23,000
    what about the three runs

    522
    00:28:23,000 --> 00:28:25,000
    of process validation, right?

    523
    00:28:25,000 --> 00:28:26,000
    Always, because when you're talking

    524
    00:28:26,000 --> 00:28:27,000
    to a validation person,

    525
    00:28:27,000 --> 00:28:29,000
    that's immediately what comes to mind

    526
    00:28:29,000 --> 00:28:31,000
    is three runs of process validation.

    527
    00:28:31,000 --> 00:28:32,000
    And it's really starting to shift

    528
    00:28:32,000 --> 00:28:34,000
    that mindset away from

    529
    00:28:34,000 --> 00:28:36,000
    this sort of finite

    530
    00:28:39,000 --> 00:28:41,000
    validation document package,

    531
    00:28:41,000 --> 00:28:43,000
    which is, let's face it,

    532
    00:28:43,000 --> 00:28:44,000
    it's a snapshot in time.

    533
    00:28:44,000 --> 00:28:46,000
    It's a static thing, typically, right?

    534
    00:28:46,000 --> 00:28:47,000
    That, oh, we might do it,

    535
    00:28:47,000 --> 00:28:48,000
    redo it each year

    536
    00:28:48,000 --> 00:28:51,000
    or some rendition of that.

    537
    00:28:51,000 --> 00:28:53,000
    But what we need to start getting towards

    538
    00:28:53,000 --> 00:28:55,000
    is a way, a methodology

    539
    00:28:55,000 --> 00:28:57,000
    to start looking at these things

    540
    00:28:57,000 --> 00:29:01,000
    sort of in uniquely

    541
    00:29:01,000 --> 00:29:02,000
    and in real time.

    542
    00:29:02,000 --> 00:29:04,000
    And the way to do that

    543
    00:29:04,000 --> 00:29:06,000
    is through really rooting ourselves

    544
    00:29:06,000 --> 00:29:06,000
    in the principles

    545
    00:29:06,000 --> 00:29:08,000
    that are important to demonstrate.

    546
    00:29:08,000 --> 00:29:09,000
    Again, I go back to

    547
    00:29:10,000 --> 00:29:13,000
    demonstrating control, right?

    548
    00:29:13,000 --> 00:29:14,000
    And if you ask any different

    549
    00:29:14,000 --> 00:29:16,000
    validation experts,

    550
    00:29:17,000 --> 00:29:18,000
    demonstrating control

    551
    00:29:18,000 --> 00:29:19,000
    is probably not the first thing

    552
    00:29:19,000 --> 00:29:20,000
    that they're going to say.

    553
    00:29:20,000 --> 00:29:22,000
    Like, I've been around

    554
    00:29:22,000 --> 00:29:24,000
    many validation people in my life

    555
    00:29:24,000 --> 00:29:27,000
    and that word never really

    556
    00:29:27,000 --> 00:29:28,000
    came up that often,

    557
    00:29:28,000 --> 00:29:29,000
    which blew my mind

    558
    00:29:29,000 --> 00:29:30,000
    when we started saying,

    559
    00:29:30,000 --> 00:29:31,000
    what is validation?

    560
    00:29:31,000 --> 00:29:32,000
    It really is about demonstrating control

    561
    00:29:33,000 --> 00:29:35,000
    in the context of

    562
    00:29:35,000 --> 00:29:36,000
    patient safety product quality

    563
    00:29:36,000 --> 00:29:37,000
    at the end of the day.

    564
    00:29:38,000 --> 00:29:39,000
    And so it's like really rooting ourselves

    565
    00:29:39,000 --> 00:29:40,000
    in these principles,

    566
    00:29:40,000 --> 00:29:42,000
    utilizing the requirements

    567
    00:29:42,000 --> 00:29:42,000
    that are already out there.

    568
    00:29:42,000 --> 00:29:44,000
    Again, I see HQ8, Q9,

    569
    00:29:45,000 --> 00:29:46,000
    utilizing digital technologies

    570
    00:29:46,000 --> 00:29:48,000
    because those are new capabilities

    571
    00:29:48,000 --> 00:29:48,000
    we have now,

    572
    00:29:49,000 --> 00:29:52,000
    new-ish, but new relative to,

    573
    00:29:52,000 --> 00:29:53,000
    you know, previous approaches.

    574
    00:29:54,000 --> 00:29:55,000
    And really getting ourselves

    575
    00:29:55,000 --> 00:29:58,000
    into a state where we can determine

    576
    00:29:58,000 --> 00:30:00,000
    and demonstrate validation in real time.

    577
    00:30:01,000 --> 00:30:02,000
    This, in my opinion,

    578
    00:30:02,000 --> 00:30:03,000
    will help us get to

    579
    00:30:03,000 --> 00:30:05,000
    potentially quicker time to value

    580
    00:30:05,000 --> 00:30:06,000
    on new products,

    581
    00:30:06,000 --> 00:30:07,000
    but really also the evolutions

    582
    00:30:07,000 --> 00:30:08,000
    of existing products,

    583
    00:30:09,000 --> 00:30:12,000
    but also potentially taking account

    584
    00:30:12,000 --> 00:30:15,000
    for upstream and downstream data, right?

    585
    00:30:15,000 --> 00:30:16,000
    There's a lot of data out there

    586
    00:30:16,000 --> 00:30:16,000
    we're not using,

    587
    00:30:16,000 --> 00:30:18,000
    whether it's our raw material suppliers

    588
    00:30:18,000 --> 00:30:20,000
    or it's real world evidence

    589
    00:30:20,000 --> 00:30:21,000
    or whatever.

    590
    00:30:21,000 --> 00:30:22,000
    Why does that not feed

    591
    00:30:22,000 --> 00:30:25,000
    into our validation loop,

    592
    00:30:25,000 --> 00:30:26,000
    our life cycle, right?

    593
    00:30:26,000 --> 00:30:28,000
    Like now maybe in like

    594
    00:30:28,000 --> 00:30:29,000
    annual product reviews,

    595
    00:30:29,000 --> 00:30:30,000
    we might look at that stuff,

    596
    00:30:30,000 --> 00:30:31,000
    but really as part of

    597
    00:30:31,000 --> 00:30:32,000
    product and process

    598
    00:30:32,000 --> 00:30:34,000
    and how that can help.

    599
    00:30:34,000 --> 00:30:36,000
    Again, this is our North Stars

    600
    00:30:36,000 --> 00:30:37,000
    trying to get to these places,

    601
    00:30:37,000 --> 00:30:38,000
    but you got to get

    602
    00:30:38,000 --> 00:30:39,000
    the infrastructure in place

    603
    00:30:39,000 --> 00:30:40,000
    and the thinking

    604
    00:30:40,000 --> 00:30:41,000
    and the cultural shifts.

    605
    00:30:43,000 --> 00:30:43,000
    Victor?

    606
    00:30:44,000 --> 00:30:45,000
    Michelle, it was perfect.

    607
    00:30:47,000 --> 00:30:50,000
    Yeah, it was perfectly all sentence.

    608
    00:30:50,000 --> 00:30:52,000
    So I believe this is the point

    609
    00:30:52,000 --> 00:30:54,000
    that we shall stage,

    610
    00:30:55,000 --> 00:30:56,000
    have control.

    611
    00:30:56,000 --> 00:30:58,000
    There is a chapter in our guide

    612
    00:30:58,000 --> 00:31:00,000
    that say that

    613
    00:31:00,000 --> 00:31:01,000
    holistic control strategy,

    614
    00:31:01,000 --> 00:31:03,000
    how you need to define

    615
    00:31:03,000 --> 00:31:04,000
    this holistic control strategy,

    616
    00:31:04,000 --> 00:31:06,000
    mapping the process,

    617
    00:31:06,000 --> 00:31:07,000
    mapping the strategies,

    618
    00:31:07,000 --> 00:31:11,000
    and how you can have this visibility.

    619
    00:31:11,000 --> 00:31:12,000
    So this I think,

    620
    00:31:12,000 --> 00:31:13,000
    this I believe is

    621
    00:31:14,000 --> 00:31:16,000
    the core of the approach.

    622
    00:31:16,000 --> 00:31:18,000
    Have control, have visibility.

    623
    00:31:18,000 --> 00:31:20,000
    How this control is

    624
    00:31:20,000 --> 00:31:22,000
    going through your process.

    625
    00:31:22,000 --> 00:31:23,000
    Understanding in,

    626
    00:31:24,000 --> 00:31:25,000
    how do you need to define

    627
    00:31:25,000 --> 00:31:28,000
    a level of effort of activities

    628
    00:31:28,000 --> 00:31:31,000
    to not to waste too much time.

    629
    00:31:31,000 --> 00:31:34,000
    Because sometimes I have seen that

    630
    00:31:34,000 --> 00:31:37,000
    there are a lot of work to do again,

    631
    00:31:37,000 --> 00:31:39,000
    but if you have control of the data,

    632
    00:31:39,000 --> 00:31:41,000
    mainly you can use to leverage

    633
    00:31:41,000 --> 00:31:42,000
    previous knowledge,

    634
    00:31:42,000 --> 00:31:44,000
    previous activities.

    635
    00:31:44,000 --> 00:31:46,000
    So control is the fundamental

    636
    00:31:46,000 --> 00:31:47,000
    of this approach.

    637
    00:31:47,000 --> 00:31:49,000
    Have control of the data.

    638
    00:31:49,000 --> 00:31:52,000
    Well, there's so many more dimensions

    639
    00:31:52,000 --> 00:31:53,000
    that we could talk about

    640
    00:31:53,000 --> 00:31:55,000
    for the next four hours.

    641
    00:31:56,000 --> 00:31:58,000
    But to bring this

    642
    00:31:58,000 --> 00:31:59,000
    to kind of a wrap up,

    643
    00:32:00,000 --> 00:32:03,000
    I'm really excited about

    644
    00:32:03,000 --> 00:32:03,000
    what's in this

    645
    00:32:04,000 --> 00:32:07,000
    validation 4.0 good practice guide.

    646
    00:32:08,000 --> 00:32:11,000
    What I see when you talk about

    647
    00:32:11,000 --> 00:32:12,000
    quality by design

    648
    00:32:12,000 --> 00:32:14,000
    and quality risk management

    649
    00:32:14,000 --> 00:32:16,000
    as being the fundamentals,

    650
    00:32:16,000 --> 00:32:18,000
    and then demonstrating

    651
    00:32:19,000 --> 00:32:23,000
    that your controls are effective,

    652
    00:32:23,000 --> 00:32:23,000
    that they work.

    653
    00:32:26,000 --> 00:32:28,000
    To me, that's what

    654
    00:32:28,000 --> 00:32:30,000
    the regulators have been

    655
    00:32:30,000 --> 00:32:32,000
    wanting us to do all along.

    656
    00:32:33,000 --> 00:32:35,000
    But we've kind of been

    657
    00:32:35,000 --> 00:32:37,000
    shackled by past practices.

    658
    00:32:39,000 --> 00:32:42,000
    And I'm hopeful that this document

    659
    00:32:42,000 --> 00:32:44,000
    helps us move towards

    660
    00:32:44,000 --> 00:32:46,000
    where the regulators

    661
    00:32:46,000 --> 00:32:47,000
    really want us to be.

    662
    00:32:49,000 --> 00:32:50,000
    And hopefully shed

    663
    00:32:51,000 --> 00:32:54,000
    some non-value-added practices

    664
    00:32:54,000 --> 00:32:57,000
    that we thought we had to do

    665
    00:32:58,000 --> 00:32:59,000
    along the way.

    666
    00:33:00,000 --> 00:33:01,000
    And really get us to where

    667
    00:33:01,000 --> 00:33:04,000
    we're always evaluating the data

    668
    00:33:04,000 --> 00:33:06,000
    as it comes in, in real time.

    669
    00:33:08,000 --> 00:33:09,000
    Maybe even making adjustments

    670
    00:33:09,000 --> 00:33:11,000
    without regulatory approval

    671
    00:33:12,000 --> 00:33:13,000
    based on data.

    672
    00:33:13,000 --> 00:33:15,000
    Yeah, I agree.

    673
    00:33:15,000 --> 00:33:16,000
    I can't agree with you more.

    674
    00:33:16,000 --> 00:33:18,000
    And you've summarized it really well.

    675
    00:33:19,000 --> 00:33:21,000
    And just one little anecdote is,

    676
    00:33:21,000 --> 00:33:22,000
    we did work with

    677
    00:33:22,000 --> 00:33:24,000
    a quality innovation group

    678
    00:33:24,000 --> 00:33:24,000
    out of the EMA.

    679
    00:33:24,000 --> 00:33:26,000
    And that was really an exciting process

    680
    00:33:26,000 --> 00:33:28,000
    that they were so willing

    681
    00:33:28,000 --> 00:33:29,000
    to spend the time with us

    682
    00:33:29,000 --> 00:33:31,000
    to review our concepts.

    683
    00:33:31,000 --> 00:33:33,000
    And they had some great input

    684
    00:33:33,000 --> 00:33:34,000
    and that did ultimately

    685
    00:33:34,000 --> 00:33:35,000
    get into the guide.

    686
    00:33:36,000 --> 00:33:38,000
    But I think they were excited.

    687
    00:33:38,000 --> 00:33:40,000
    They were excited because

    688
    00:33:40,000 --> 00:33:40,000
    they're like, this is what

    689
    00:33:40,000 --> 00:33:41,000
    they've been trying to push

    690
    00:33:41,000 --> 00:33:43,000
    for Annex 15 for so long.

    691
    00:33:44,000 --> 00:33:47,000
    And there's wording in there,

    692
    00:33:47,000 --> 00:33:48,000
    in the Annex 15 already,

    693
    00:33:48,000 --> 00:33:50,000
    it states continuous validation

    694
    00:33:50,000 --> 00:33:51,000
    and all these kinds of things.

    695
    00:33:51,000 --> 00:33:53,000
    And it pushes the principles.

    696
    00:33:53,000 --> 00:33:54,000
    And I think they thought

    697
    00:33:54,000 --> 00:33:56,000
    that maybe this will help

    698
    00:33:56,000 --> 00:33:58,000
    also push the industry

    699
    00:33:58,000 --> 00:34:00,000
    to adopt something that, again,

    700
    00:34:00,000 --> 00:34:02,000
    has been out there for a while now.

    701
    00:34:02,000 --> 00:34:04,000
    Well, that brings us to the end

    702
    00:34:04,000 --> 00:34:07,000
    of another episode of the ISPE podcast,

    703
    00:34:07,000 --> 00:34:09,000
    Shaping the Future of Pharma.

    704
    00:34:09,000 --> 00:34:12,000
    A very big thank you to our guests,

    705
    00:34:12,000 --> 00:34:13,000
    Michelle and Victor,

    706
    00:34:13,000 --> 00:34:16,000
    for sharing how Validation 4.0

    707
    00:34:16,000 --> 00:34:19,000
    will help industry apply technology

    708
    00:34:19,000 --> 00:34:20,000
    to improve quality,

    709
    00:34:21,000 --> 00:34:22,000
    reduce cost of goods,

    710
    00:34:22,000 --> 00:34:25,000
    and perhaps even speed time to licensure.

    711
    00:34:26,000 --> 00:34:27,000
    Please be sure to subscribe

    712
    00:34:27,000 --> 00:34:30,000
    so you don't miss future conversations

    713
    00:34:30,000 --> 00:34:32,000
    with the innovators, experts,

    714
    00:34:32,000 --> 00:34:34,000
    and change makers

    715
    00:34:34,000 --> 00:34:35,000
    driving our industry forward.

    716
    00:34:36,000 --> 00:34:38,000
    On behalf of all of us at ISPE,

    717
    00:34:38,000 --> 00:34:40,000
    thank you for listening.

    718
    00:34:40,000 --> 00:34:41,000
    And we'll see you next time

    719
    00:34:41,000 --> 00:34:44,000
    as we continue to explore the ideas,

    720
    00:34:44,000 --> 00:34:46,000
    trends, and people

    721
    00:34:46,000 --> 00:34:51,000
    shaping the future of pharma.

     

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