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.
Register for the 2025 ISPE Pharma 4.0™ Conference.
Get the ISPE Good Practice Guide: Validation 4.0
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Welcome to the ISPE podcast, Shaping the Future of Pharma,2
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where ISPE supports you on your journey,3
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fueling innovation, sharing insights, thought leadership,4
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and empowering a global community to reimagine what's possible.5
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Hello and welcome to the ISPE podcast, Shaping the Future of Pharma.6
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I'm Bob Chew, your host, and today we have another episode7
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where we'll be sharing the latest insights and thought leadership8
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on manufacturing, technology, supply chains,9
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and regulatory trends impacting the pharmaceutical industry.10
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You'll hear directly from the innovators, experts,11
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and professionals driving progress and shaping the future.12
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Thank you again for joining us, and now let's dive into this episode.13
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Our topic today is Unlocking Innovation,14
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Embracing Validation 4.0 for a Digital Pharma Future.15
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To share more about this topic, I would like to welcome Michelle Vuolo,16
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head of quality at Tulip Interfaces and co-lead of the Validation 4.0 guide team.17
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And fellow guide team member representing South America18
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is Victor de Oliveira Silva Ferreira,19
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Project Manager for PEQMS, Implementation of Electronic Systems20
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for the Quality Management System at the Instituto de Tecnologia21
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Em Imunobiológico Fundação Oswaldo Cruz.22
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Michelle and Victor, welcome to the podcast.23
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We're so glad to have you both with us.24
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Thanks. Thanks for having us.25
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I hope that's a thank you for invitation.26
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Well, first, before we jump into some of the questions about the guide,27
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I'm curious, how did you guys get involved in this guide?28
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What's your background? What's your passion? Why this one?29
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Michelle?30
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Sure. Yeah, I'll go ahead and start.31
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Yeah, I work at Tulip Interfaces,32
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which is a technology company providing software for manufacturing environments.33
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I've been here about five years, but before that,34
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I spent about 25 years in life sciences and doing all things quality35
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from lab to manufacturing operations quality to all the way to IT quality,36
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probably my natural progression and decided to get engaged37
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with the Pharma 4.0 community of practice.38
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And so I wanted to help modernize the way we look at quality and validation topics39
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and thought that it would best fit in the Pharma 4.0 community of practice.40
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So fast forward five years and lots of PE,41
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pharmaceutical engineering articles and conference speaking42
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and lots of really great active members in the ISPE community.43
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Later, we published the good practice.44
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And Victor?45
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I have to work with qualification and validation for entire of my career,46
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mainly with the development new strategies to release new products in my company.47
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For the last five years, I was dedicated to understand48
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how technology can enhance quality and validation strategies.49
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So I joined in validation 14 and have been working with Michelle for these years in GPD.50
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Well, great.51
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Well, let's start out with kind of the big picture.52
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What exactly is validation 4.0?53
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Yeah, I can start because I do recall when we first got our working group54
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now called subcommittee together.55
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That was the big question.56
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Like, what is it?57
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Because validation is such a broad topic covering so many aspects.58
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And it was very clear that it wasn't computerized system validation specifically,59
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because there's Gantt for that very well established group.60
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But that we wanted to look at how we could modernize validation61
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and look at how to become more efficient and effective with validation62
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in this digital world, right?63
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Like, it doesn't have to be digital, but what's happening64
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or what's driving the change to look at validation was the digital transition.65
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And I think bigger picture even on that is really trying to help enable66
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real-time validation, again, with the usage of digital technologies,67
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real-time validation, continuous validation, looking at upstream and downstream68
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sort of impacts on validation of what you're trying to validate.69
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So it's sort of the bigger picture.70
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It's rooted in the guideposts of the IEH guidelines,71
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in particular quality risk management and quality by design72
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to fundamental and foundational principles to enable validation.73
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Really, when you look at validation as just like going back and saying,74
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what is validation?75
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It's really the demonstration of control.76
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And so those are two fundamental principles and foundational aspects77
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that need to be understood to really do validation on any focused way.78
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Yeah.79
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I don't like I did that.80
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I see validation for is looking to data on the quality by design lens.81
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So you need to ensure that the probability data82
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is available for users during the entire life cycle.83
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So there is an operational approach that approach itself.84
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How do you need to do validation for?85
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But there is an aspect, the business aspect regarding86
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how you deal with validation quality as a business strategy,87
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because it was discussed in years.88
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Validation quality need to be work as business strategy89
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to enhance control around the product process.90
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So what triggered the creation of Validation 4.0?91
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Was it the Pharma 4.0 good practice guide,92
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or was it other factors in industry?93
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Yeah.94
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So, you know, we started working together as a group.95
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There's, you know, there's an ebb and flow of folks96
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that come and join on these groups,97
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which is understood because people are volunteering their time to do this98
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and have day jobs, so to speak.99
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But, you know, I think our group was doing a lot.100
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Like I said, we did a lot of101
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pharmaceutical engineering magazine articles.102
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We are trying to develop and define case studies.103
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Then we moved on.104
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We did a couple of presentations at most of the ISTE annual meetings,105
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both in the EU and in the US.106
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Also in the Eastern communities, too,107
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because the co-lead of the Validation 4.0 working group is out of Bangkok.108
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So we're able to do a lot of seminars and webinars out there in India as well.109
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I'm forgetting.110
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It's been five years.111
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But then we got involved in one of the chapters,112
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the quality chapter of the Pharma 4.0 baseline guide, right?113
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So there's baseline guides, which are sort of higher level overarching,114
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which is what GAMP is, for example.115
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I think a lot of people with ISPE are very familiar with GAMP.116
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And then under that umbrella,117
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there's lots of good practice guides that are on specific topics.118
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Like, for example, GAMP has an MES specific good practice guide.119
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So, yeah, the Pharma 4.0 baseline guide was published in December of 23, I think it was.120
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That's when we started saying,121
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what are good opportunities for documenting more information122
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on how to execute this Pharma 4.0 approach on particular topics?123
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And so Validation 4.0 is prime for that.124
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We've had our approach, our guideposts, our methodology defined.125
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We've had a few case studies.126
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So we started writing the good practice guide.127
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And, you know, with the intentions of really trying to demonstrate to the industry128
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how to do this more specifically than, you know, sort of this conceptual idea.129
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If I go back many decades, there was an FDA aseptic process validation guide,130
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if I recall correctly, talking about media fills or aseptic process simulation.131
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And it specified a minimum of three lots.132
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Now, in that case, one lot was at least 5,000 units.133
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So you really were looking at the aseptic contamination possibility134
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spread across 15,000 instances.135
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But those three lots then kind of morphed into validation, process validation.136
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And we need to do three lots.137
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Now, we all would agree that three lots is not statistically significant138
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and does not capture potential variability in raw materials and all this stuff.139
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Now, up front, you're supposed to have development work140
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that covers that base.141
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And then you do these three lots.142
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And then you do continuous process verification.143
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Tell me how this validation 4.0 changes that.144
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I can go first.145
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And, Victor, jump in for sure if you want to help support or add anything different.146
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But, yeah, so what we're trying to get away from in this validation paradigm147
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towards a new paradigm is, you know, I think traditionally the three,148
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you know, the tradition, the golden three-batch run,149
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like that's always sort of like people immediately think of that150
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when they think of, oh, how am I going to validate?151
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What we're trying to do is shift the thinking away from,152
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I have to do three runs of process validation153
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towards how have I demonstrated the controls in my process?154
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The only way to do that really is to understand your process requirements,155
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which in my opinion are around quality by design, right?156
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Quality by design, basically the fundamental of quality by design157
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is the more you know about your product and process,158
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the more you can control it, right?159
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So the idea through CPP, CQAs, these critical aspects to your process160
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are defined and identified as critical, right?161
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Using your quality risk management principles162
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and identifying the controls around each of those individually163
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and developing controls around them.164
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The validation of that is not just running through it three times.165
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The validation of that is really building an evidence story166
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around each of those controls and how you demonstrate them, really.167
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So the idea is like the culmination of all these controls,168
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the evidence of these controls really starts to become your validation package,169
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not whether you ran it three times.170
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You could have run it several times on, I don't know,171
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different parameters and different things on a particular control area172
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or a particular critical area of the process.173
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But you're building this evidence file on an ongoing basis.174
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If you can do this during product development, right?175
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These iterations of like through risk management though, right?176
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A controlled process of identify a risk and put a control in place,177
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determining if it's effective or not,178
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and iterating on that in this sort of continuous loop.179
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That's where we also want to get into this continuous validation180
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or the idea that we can, at any one point in time,181
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understand our state of control.182
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Yeah, we, using Go, said that we are going to move183
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from the stage of validation to stage of validation.184
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Because in the moment that we're starting,185
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Go have control about the data since the development.186
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You have confidence to scale up all validation activities187
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through their all study, clinical studies,188
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and to reach the commercial match understanding for the entire process.189
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This is what you should know about holistic control strategy,190
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is have all control for all strategies need to be implemented during the life cycle.191
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Okay, you mentioned quality risk management.192
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There's a lot of different views on that.193
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There's a lot of different practices on that.194
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I think those of us who have done it would agree that in most cases,195
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certainly many cases, it's subjective.196
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The probability, the effectiveness of the controls,197
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and the probability given those controls, et cetera.198
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How is validation 4.0 dealing with those,199
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that subjective nature of quality risk management?200
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And can technology turn subjectivity into objectivity?201
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Yeah, I can go first or Victor,202
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I want to give you the opportunity to go first if you want.203
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Okay, I think that we are thinking validation 4204
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in quality risk management.205
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We are not speaking about using spreadsheets,206
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but using digital tools to enhance the entire management.207
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So, this allows to have capability to integrate systems with MERS,208
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LIMS, and other kind of stuff to get data since the development,209
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going through this system, provide the control.210
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Obviously, there is some kind of complexity in doing this,211
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but in the moment that you take quality validation group and IT group,212
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look into the strategy of the whole process,213
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you can provide control for all decision214
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and activity that will occur in your manufacturing process.215
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I believe this is the main point that quality risk management216
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and validation can enhance.217
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The possibility to, since the first time they start a process or product,218
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you're working together to think,219
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okay, what can affect my process, my product?220
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How the sensor could be failed during my process221
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and how this information put through quality risk management digital222
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and send the trigger action that you can do in real time.223
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So, these are, as I see, validation for enhancing quality risk management.224
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Yeah, I think just to add to that too,225
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is like one of the things that we have,226
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like in all the presentations I've given on this,227
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like one of the things we do say is like228
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we are not prescribing a particular risk methodology at all.229
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Like we're not saying FMEA is great or not or whatever.230
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What we do, like what I do with myself231
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and what I do like about ICHQNAN is risk identification,232
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risk assessment, and risk control.233
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Just logically that process works really well.234
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And if you're doing a three-by-three matrix or a two-by-two matrix235
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or you're using detectability or frequency or likelihood,236
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we don't get into that level of detail.237
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But what we're saying is we need to identify and understand238
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the risk associated with certain data points, right,239
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associated with your process.240
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And so, and the idea is, again, as you are identifying the risk,241
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you're like a sterility assurance,242
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you identify the control, whichever it might be,243
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and then you ultimately then verify the effectiveness of that control244
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right away through several iterations or several runs.245
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But the idea is that as soon as you get an effective or ineffective data point,246
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that gets fed back into the risk,247
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identified if the risk changes,248
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which not often does the risk change itself,249
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but the risk control is either effective or ineffective.250
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And you determine if you need to adjust your risk control.251
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So again, it's not a three-by-three matrix.252
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It's not subjective or objective.253
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It's, you know, the basis is product quality, patient safety always.254
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So in those terms is where, again,255
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that continuous loop allows you to feedback256
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and adjust your controls as necessary.257
00:16:37,000 --> 00:16:40,000
But again, I just think of many examples258
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 room262
00:16:52,000 --> 00:16:54,000
trying to determine the risk level of something263
00:16:55,000 --> 00:16:59,000
and not really following up or understanding264
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 well273
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 necessarily276
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 assumes284
00:17:56,000 --> 00:18:01,000
that you have some sort of statistical understanding285
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 space296
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 tools298
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 see306
00:19:04,000 --> 00:19:06,000
that some of these digital tools for risk management307
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 guidance311
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 studies313
00:19:23,000 --> 00:19:25,000
is that it was demonstrating the ability314
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 correlations316
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 way318
00:19:40,000 --> 00:19:42,000
about how like when you identify319
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 controls323
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 ability325
00:19:57,000 --> 00:19:59,000
to do statistical analysis326
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 data328
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 controls330
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 start333
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 part336
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 state342
00:20:37,000 --> 00:20:39,000
of like just running continuously343
00:20:39,000 --> 00:20:41,000
and being able to do a snapshot validation344
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 ones347
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 studies349
00:20:51,000 --> 00:20:54,000
on the quality by design tool that we used350
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 statistics352
00:20:57,000 --> 00:20:59,000
so that you could see your effectiveness353
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 stages355
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 tool369
00:21:48,000 --> 00:21:51,000
to determine the level of effort370
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 do372
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 control374
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 organically377
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 4.0379
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 control385
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 on388
00:22:43,000 --> 00:22:45,000
and how this strategy can evolve389
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 quote392
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 asked395
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 appreciate399
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 state401
00:23:18,000 --> 00:23:20,000
that's like, again, R&D is this whole thing402
00:23:20,000 --> 00:23:22,000
and then there's this tech transfer403
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 middle405
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 design407
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 getting412
00:23:45,000 --> 00:23:47,000
to these iterative cycles really early413
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 place416
00:23:55,000 --> 00:23:59,000
to identify risks, identify risk controls417
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 effectiveness419
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 evidence424
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 strategy427
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 vials431
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 parameters436
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 science439
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 start441
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 4.0444
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 term446
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 play450
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 evidence453
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 strategy456
00:25:52,000 --> 00:25:58,000
for like pills or like vials457
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 control462
00:26:08,000 --> 00:26:10,000
and control evidence and plug it463
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 infrastructure467
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 aspects473
00:26:33,000 --> 00:26:35,000
in the requirements on X, Y, and Z474
00:26:35,000 --> 00:26:38,000
saying that you need to evaluate475
00:26:38,000 --> 00:26:41,000
all data for several control strategies476
00:26:41,000 --> 00:26:42,000
in a holistic way477
00:26:42,000 --> 00:26:43,000
because obviously,478
00:26:43,000 --> 00:26:45,000
all pharmaceutical companies479
00:26:45,000 --> 00:26:47,000
has on a certain level480
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 is482
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 vision484
00:26:57,000 --> 00:27:00,000
provide the tools and the approach485
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 contamination488
00:27:07,000 --> 00:27:10,000
in your facility is under control489
00:27:10,000 --> 00:27:11,000
and evaluate together490
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, differences493
00:27:23,000 --> 00:27:24,000
that you would find494
00:27:24,000 --> 00:27:26,000
in validation 4.0 guide495
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 off497
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 is502
00:27:45,000 --> 00:27:47,000
we didn't create quality by design503
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 is506
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 change508
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 landscape512
00:28:03,000 --> 00:28:05,000
and tried to articulate it513
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 piece516
00:28:12,000 --> 00:28:13,000
is shifting the mindset away517
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 funny519
00:28:20,000 --> 00:28:21,000
that one of the first questions520
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 runs522
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 talking524
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 mind526
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 shift528
00:28:32,000 --> 00:28:34,000
that mindset away from529
00:28:34,000 --> 00:28:36,000
this sort of finite530
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 year536
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 towards538
00:28:53,000 --> 00:28:55,000
is a way, a methodology539
00:28:55,000 --> 00:28:57,000
to start looking at these things540
00:28:57,000 --> 00:29:01,000
sort of in uniquely541
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 that543
00:29:04,000 --> 00:29:06,000
is through really rooting ourselves544
00:29:06,000 --> 00:29:06,000
in the principles545
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 to547
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 different549
00:29:14,000 --> 00:29:16,000
validation experts,550
00:29:17,000 --> 00:29:18,000
demonstrating control551
00:29:18,000 --> 00:29:19,000
is probably not the first thing552
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 around554
00:29:22,000 --> 00:29:24,000
many validation people in my life555
00:29:24,000 --> 00:29:27,000
and that word never really556
00:29:27,000 --> 00:29:28,000
came up that often,557
00:29:28,000 --> 00:29:29,000
which blew my mind558
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 control561
00:29:33,000 --> 00:29:35,000
in the context of562
00:29:35,000 --> 00:29:36,000
patient safety product quality563
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 ourselves565
00:29:39,000 --> 00:29:40,000
in these principles,566
00:29:40,000 --> 00:29:42,000
utilizing the requirements567
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 technologies570
00:29:46,000 --> 00:29:48,000
because those are new capabilities571
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 ourselves575
00:29:55,000 --> 00:29:58,000
into a state where we can determine576
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 to579
00:30:03,000 --> 00:30:05,000
potentially quicker time to value580
00:30:05,000 --> 00:30:06,000
on new products,581
00:30:06,000 --> 00:30:07,000
but really also the evolutions582
00:30:07,000 --> 00:30:08,000
of existing products,583
00:30:09,000 --> 00:30:12,000
but also potentially taking account584
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 there586
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 suppliers588
00:30:18,000 --> 00:30:20,000
or it's real world evidence589
00:30:20,000 --> 00:30:21,000
or whatever.590
00:30:21,000 --> 00:30:22,000
Why does that not feed591
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 like594
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 of597
00:30:31,000 --> 00:30:32,000
product and process598
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 Stars600
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 get602
00:30:38,000 --> 00:30:39,000
the infrastructure in place603
00:30:39,000 --> 00:30:40,000
and the thinking604
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 point609
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 guide612
00:30:58,000 --> 00:31:00,000
that say that613
00:31:00,000 --> 00:31:01,000
holistic control strategy,614
00:31:01,000 --> 00:31:03,000
how you need to define615
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 is621
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 is624
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 define627
00:31:25,000 --> 00:31:28,000
a level of effort of activities628
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 that630
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 leverage633
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 fundamental636
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 dimensions639
00:31:52,000 --> 00:31:53,000
that we could talk about640
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 this642
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 about644
00:32:03,000 --> 00:32:03,000
what's in this645
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 about647
00:32:11,000 --> 00:32:12,000
quality by design648
00:32:12,000 --> 00:32:14,000
and quality risk management649
00:32:14,000 --> 00:32:16,000
as being the fundamentals,650
00:32:16,000 --> 00:32:18,000
and then demonstrating651
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 what654
00:32:28,000 --> 00:32:30,000
the regulators have been655
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 been657
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 document659
00:32:42,000 --> 00:32:44,000
helps us move towards660
00:32:44,000 --> 00:32:46,000
where the regulators661
00:32:46,000 --> 00:32:47,000
really want us to be.662
00:32:49,000 --> 00:32:50,000
And hopefully shed663
00:32:51,000 --> 00:32:54,000
some non-value-added practices664
00:32:54,000 --> 00:32:57,000
that we thought we had to do665
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 where667
00:33:01,000 --> 00:33:04,000
we're always evaluating the data668
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 adjustments670
00:33:09,000 --> 00:33:11,000
without regulatory approval671
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 with677
00:33:22,000 --> 00:33:24,000
a quality innovation group678
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 process680
00:33:26,000 --> 00:33:28,000
that they were so willing681
00:33:28,000 --> 00:33:29,000
to spend the time with us682
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 input684
00:33:33,000 --> 00:33:34,000
and that did ultimately685
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 because688
00:33:40,000 --> 00:33:40,000
they're like, this is what689
00:33:40,000 --> 00:33:41,000
they've been trying to push690
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 validation694
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 thought697
00:33:54,000 --> 00:33:56,000
that maybe this will help698
00:33:56,000 --> 00:33:58,000
also push the industry699
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 end702
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 4.0707
00:34:16,000 --> 00:34:19,000
will help industry apply technology708
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 subscribe712
00:34:27,000 --> 00:34:30,000
so you don't miss future conversations713
00:34:30,000 --> 00:34:32,000
with the innovators, experts,714
00:34:32,000 --> 00:34:34,000
and change makers715
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 time719
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 people721
00:34:46,000 --> 00:34:51,000
shaping the future of pharma.
