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How to Set Up and Manage Quality

Control and Quality Assurance


Myriam Visschedijk1,*, Rik Hendriks2 and Katrien Nuyts3
1
TNO Quality of Life, The Netherlands
2
Johnson & Johnson Pharmaceutical Research & Development, Belgium
3
Johnson & Johnson Pharmaceutical Research & Development, Belgium

Summary
This document provides a general introduction to clarify the differences between
quality control (QC) and quality assurance (QA). In addition it serves as a starting
point for implementing a quality system approach within an organization. The paper
offers practical guidance to the implementation of quality and the importance of QC
in its relationship to QA. It can be used in conjunction with the various quality
regulations or guidelines. Appendix A provides a table of examples of various
activities, which will help guide the user to apply a quality system with both QC and
QA aspects. It is important to note, however, that the items listed in the table are
only examples and should not be regarded as the only way to set up a QC/QA system.
Appendix A is based on the Good Laboratory Practice (GLP) quality system. In
conclusion, QC is part of effective project management while QA assesses
the effectiveness of the quality systems associated with the overall process. Copyright
# 2005 John Wiley & Sons, Ltd.

Key Words: good laboratory practice; GLP; project management; quality assurance; quality
control; quality management

Aim decided to take the initiative for writing a


document that would focus on a practical
This document may be used by parties interested approach. On 1 July 1999 five working groups,
in initiating or developing a quality system headed by a lead member, had a broad discus-
within an organization. It provides a Quality sion and collected relevant material on ‘The role
Control (QC) and Quality Assurance (QA) of QC/QA in GLP’. The lead members of each
approach to systems. The starting point was working group then reviewed the findings
the Dutch Association of Research Quality together with the DARQA GLP committee to
Assurance (DARQA) Good Laboratory Practice begin development of the document. Each
(GLP) committee workshop on ‘QA/QC in prac- working group continued to meet in order to
tice’ held on 11 December 1998. Based on the further develop and formulate their results. On
positive feedback expressed for elaboration on 21 March 2000 the lead members met with the
this subject, the DARQA GLP committee involved DARQA GLP committee members to
decide on the approach to bring together all
*Correspondence to: Myriam Visschedijk, TNO Quality information into one document. Mrs Myriam
of Life, Utrechtseweg 48, P.O. Box 360, 3700 AJ Zeist,
The Netherlands. Visschedijk and Mr Rik Hendriks were re-
E-mail: visschedijk@voeding.tno.nl quested to write the document, based on the

Copyright r 2005 John Wiley & Sons, Ltd. Qual Assur J 2005; 9, 95–107.
DOI: 10.1002/qaj.325
96 M Visschedijk et al.

results of the working group discussions as Definitions


summarized by the lead members. The current
article is the result of this process. The International Conference on Harmoniza-
The text describes both a QC and QA tion (ICH) GCP [1] definitions were adopted as
process, considered to be a tool for manage- a basis. A few explanatory hints were added to
ment, QC and QA responsible personnel. provide guidance in further understanding the
Appendix A is an aid for the implementation content.
by line management.
QC
According to the ICH GCP definition, QC
Introduction
comprises ‘the operational techniques and activ-
ities undertaken within the QA system to verify
This document provides a general introduction
that the requirements for quality of the trial-
to the differences between QC and QA. It offers
related activities have been fulfilled’ (ICH GCP
practical guidance for the implementation of a
1.47):
QC system and its correlation to the QA
program. The Good Clinical Practice (GCP) * objective: process control;
and the Good Manufacturing Practice (GMP) * to ensure quality of the activities;
guidelines consider QC, as well as QA, to be * measurable: QC data.
essential parts of the quality system. Although
the Organisation for Economic Co-operation
QA
and Development (OECD) GLP Principles do
not use the term QC or specify any QC According to the ICH GCP definition, QA
activities, the same approach could be applied. comprises ‘all those planned and systematic
The goal of a quality management program is actions that are established to ensure that the
to incorporate a process of continuous improve- trial is performed and the data are generated,
ment. This is the mission of management, in documented (recorded), and reported in com-
which QC and QA play an important role. Both pliance with GCP and the applicable regulatory
QC and QA have a common aim but they requirements’ (ICH GCP 1.46):
achieve it in different ways. QC is involved in
* objective: independent inspection;
standards and limits defined by the environment,
* to assure compliance of the process within the
which prescribes the rules governing what is
quality system;
correct. In contrast, QA concerns itself with
* measurable: inspection reports.
goals and defines what is acceptable. Both
aspects are part of the culture of an organiza-
tion. Factors that Influence the Quality of a
Quality is an intrinsic state of mind among Study and How to Make Quality
staff members and is therefore result-oriented. Traceable
Management should define study-related and
general activities and implement a respective QC The factors that influence the quality of a study
and QA model. define the processes of general and study-related
Quality has to be delivered by the study activities within an organization. The study-
personnel and the QA Unit has to assure the related activities can be strictly process- or
quality through an umbrella function. Each staff study-based. The general activities can be faci-
member of an organization has QC tasks, which lity- or process-based (see Figure 1).
are part of the processes to ensure the validity of This section describes the general as well as
data. The QA tasks are linked to the QA the study-related activities. The process can
program, which is independent of the processes. reasonably be divided into six steps: study

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Set Up and Manage QC and QA 97

The content of an SOP is the responsibility of


GENERAL
STANDARD
STUDY-RELATED the qualified personnel (author) and of the
Non-Standard
Facility-based
Process-based
approving party (management).
inspections & Study-based
procedures inspections inspections
* Activity: implementation of a procedure.
* QC: communication and the implementation
Figure 1. Quality system of a new SOP to applicable personnel.
* QA: inspection of study personnel’s training
and adherence to the SOP.
Table 1. General activities (2) Organization and personnel
Process General activities QC QA Line management must ensure that there are
Study 1. Procedures   sufficient and qualified personnel and that
preparation 2. Computer system validation   training programs are implemented.
3. Management of apparatus  
4. Instrument validation   * Activity: documentation of training and
5. Sample management   experience.
6. Sample transfer  
7. Organization and personnel  
* QC: check for presence and completeness of
8. Facility   training records, assessment of training.
9. Laws and regulations  * QA: inspection of personnel files.
10. QC/QA program 

Data Deviation handling   (3) Equipment


processing Computer system validation   Facility management must ensure that the
Archiving Security   equipment used in a study is periodically
Access control   inspected, cleaned, maintained and calibrated
File management   according to SOPs and that written records are
maintained of all inspection, maintenance, test-
ing, calibration and/or standardizing operations.
preparation, study plan, study performance, data * Activity: registration of maintenance infor-
processing, reporting of the study and archiving. mation.
* QC: documentation of activity/occurrence.
General activities
* QA: inspection of facility and equipment
documentation.
For general activities QA can perform process-
and/or facility-based inspections randomly: The Data analysis
following examples are meant to clarify the QC Management is responsible to establish proce-
and QA activities for general items. The actual dures to ensure that computerized systems are
detailed execution is described in Appendix A. suitable for their intended purpose and are
Table 1 provides an overview on the general QC validated, operated and maintained in accor-
and QA activities. dance with the Principles of GLP.

Study preparation * Activity: testing of performance qualification.


(1) Procedures * QC: control of performance indicators.
A system should be in place to describe and * QA: inspection of validation dossier.
manage the critical steps of the process. There
should be a system for updating standard Reporting
operating procedures (SOPs) in a timely manner Procedures within the organization are estab-
and for communicating all changes to the lished to follow both regulatory and internal
relevant people. standards for the content and format of reports.

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98 M Visschedijk et al.

* Activity: writing the report in accordance Table 2. Study-related activities


with approved procedures. Process Study-related activities QC QA
* QC: review of report text and data for
Study Availability of materials, 
validity and accuracy. preparation means and personnel
* QA: inspection in accordance with defined Laws and regulations 
procedures as required by regulations. QC/QA program 
Request study number 
Study-related SOPs 

Archiving Study plan Content study plan as  


agreeda
The organization is responsible for providing Distribution  
archives for orderly storage and expedient Change in study plan  
retrieval of all raw data, documentation, speci-
Study Evaluation of critical  
mens, and reports and for appointing an performance phases
individual responsible for the coordination of
Data Witnessing of raw data  
these activities. processing Processing and validation  
of results
Interpretation of results 
* Activity: controlled movement of applicable
data, documents etc. into and out of the Reporting Raw data 
Study file  
archives. Content of report as 
* QC: documentation of an item’s temporary agreeda
removal. Archiving Delivery of dossier 
* QA: inspection of adherence to procedures on a
For example, in accordance with guideline, procedures,
movement of material into and out of the contracts.
archives.

Study-related activities Study plan


A study starts after the study director and, if
For study-related activities QA can perform applicable, the management and the sponsor
process- and/or study-based inspections: The sign the study plan (Table 2).
following examples are meant to clarify the
* Activity: receipt of signed study plan.
QC and QA activities for study-related items.
* QC: documentation of review of the study
The actual detailed application is described in
plan by qualified personnel and, applicable,
Appendix A. Table 2 provides an overview on
the sponsor.
the study-related QC and QA activities.
* QA: inspection of final signed study plan and
effective distribution.
Study preparation
Before a study can start, management and the Study performance and data processing
study director must agree on test item avail- In the raw data all information relevant for the
ability, standards, facilities, personnel, statistics, traceability of the study should be documented.
animal models, test guidelines and SOPs, etc. Especially in the event of deviations and amend-
ments, the involvement and the decisions of the
study director should be clearly documented.
* Activity: documentation of the characteristics
of the test substance. * Activity: performance of the steps specified in
* QC: verification as to whether the data the study plan.
comply with the specifications. * QC: control of data by double data entry,
* QA: no action on a study basis (action will documented witness at selected critical
occur under general activities, see Table 1). phases, use of spiked samples.

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Set Up and Manage QC and QA 99

* QA: inspection of selected critical phases,


process- and facility-based inspection.

Reporting
The study director is responsible for reporting
the study results on the basis of the raw data and
for drawing the conclusion.
* Activity: generation of final report.
* QC: check of data in report against raw data.
* QA: random check of data and results for
accuracy of reporting, inspection to deter-
mine whether the report completely reflects
the raw data and protocol requirements.

Archiving
The study director is responsible for the delivery
of the study file to the archivist in a timely
manner. The archivist is responsible for the
documentation and storage of the study dossier.
* Activity: appropriate storage of data in the
archive.
* QC: check of completeness of records.
* QA: no action on a study basis (this will
occur under general activities, see Table 1).

Figure 2. Flowchart for QC and QA


How Can We Make QC Traceable and
Verifiable?
of activities, e.g. preparation of the formulation
Performing QC in practice: how, when
is a critical phase consisting of several activities:
and by whom
weighing of the test item, homogenizing or
Although the study director is the single point of dissolving and the determination of the concen-
study control, the study personnel are responsible tration. There is a QC step for each activity. QC
for complying with instructions and recording is performed on the result of the process, QA is
raw data promptly and accurately. This principle performed on the process itself.
of good practices manifests itself through the The following process is described in Figure 2:
performance and documentation of QC. An activity, as part of the course of a study,
QC is incorporated into each function; it is produces a result. This result is then checked
the check on the quality of the activities within (QC). If QC shows that the activity was not
the study and the processes. This check must be done appropriately, the activity is redone. When
traceable and verifiable. Qualified personnel QC confirms the result, the subsequent step or
who are involved in the critical phase of the activity can be undertaken. Each QC check is
study should perform the QC check. documented.
To control the conduct of a study, QC has to QC documentation must include the following:
be implemented during the activity. A critical
phase can be a single activity or a combination * the person who carried out the QC;

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100 M Visschedijk et al.

* the date on which the QC was done; * inspections at regular intervals of the QC
* the items that were checked; program;
* how items were checked (e.g. as described in * inspection of studies and processes at ran-
a specific study plan or a procedure). dom;
* inspection of the facility at regular intervals;
QC is performed within the project, and * advice to management on improving pro-
reported to the relevant responsible person cesses.
according to documented procedures.
Appendix A gives examples of activities during
The decision whether to do a QA inspection
the process and of the way QC and QA can be
on this specific QC step is based on a risk
handled. It is up to the organization to make a
assessment of the activity within a critical
difference between facility- or process-based
phase of the study and/or the possible efficiency
inspections and study-related inspection on e.g.
yield of the inspection at the end of the study
the study preparation items.
process. The process is assured on a random
basis by QA.
Conclusion

This paper introduces the concept of a quality


The QA program and how it relates to system that is completely integrated in an
QC organization, implying that QC and QA tasks
QA is a separate responsibility. The goal is are incorporated into the tasks of all employees.
to assure the compliance of the study process Implementing QC in the line organization will
with regulations. The QA program must give an enormous advantage. The essence, ‘right
therefore be fully independent. Although QA first time’, means that the efficiency and quality
has a reactive inspecting role, it also has a of the studies will improve. Although the QA
proactive role in improving the quality of the program is still independent, the role of QA
organization. When processes and QC have evolves to monitoring the QC process.
proved to be an active and reliable system, the When a quality management system is set up,
organization has reached a higher level of its implementation may require a change in the
quality (Figure 3). corporate culture. From a project management
QC should focus on the results of an activity perspective, a quality management system surely
by controlling each step of data generation. helps organizations to continuously improve their
QA should focus on the result of the critical processes. This approach aims to define QC not
phase by assuring the processes and the QC as a separate job but as part of each employee’s
of the activities. This can be done through responsibilities, whereas QA is dedicated to the
conducting study-, process- or facility-based assurance function during the process.
inspections.
The independent QA program has to include, Acknowledgements
but is not limited to the following:
The authors would like to thank all persons
that attributed to this document at any stage of
its development. This includes – amongst others
– Mrs Erna Koelman, Mrs Chris Mitchell, Mr
Organization Result
QC Process QC
QC QC Walter Kafoe and Mr Frans Boersma (members
of the DARQA GLP committee), and Mrs
Marijke van den Berg, Mr Jan van de Broek,
QA Inspection
Mr Emiel Termond and Mr Alex Pouwelse (lead
Figure 3. Relationship between QC and QA members of the working groups).

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Set Up and Manage QC and QA 101

Appendix A: Examples of QC and QA for the Different Activities Within the Process

Activity Examples of QC Examples of QA


Process: study preparation
Organization and Organigrams Check and update Random inspection
personnel of organigrams on QC checks
Job descriptions Check job description Inspection of
against practice personnel files
Assignment study Check documented Inspection of list of
directors (SDs) assignment of SDs/principal
SD/principal investigators
investigator
Training Check objectives Inspection of
and evaluation training
programs
Check training
records
Communication Check documented
(study management) planning

Facilities Test system Check on availability


facilities of facilities during
planning of the study
Facilities for
handling
test and reference
items
Archive facilities

Health and safety/


waste disposal
Access control Check on access Random inspection
control system on process
House keeping Check on house Random inspection
keeping and process on process
Environmental Check on Random inspection
control environmental on process/during
conditions (ranges) study inspection
Feed/water/bedding Check on availability Random inspection
supplies and acceptance on process
criteria

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102 M Visschedijk et al.

Activity Examples of QC Examples of QA

Waste handling Check on correct Random inspection


waste handling on process
process

Apparatus (including Maintenance Check on Inspection


computerized maintenance log maintenance process
systems) books
Calibration Check on Inspection
calibration calibration process
documentation
Validation Check on acceptance Inspection validation
criteria (e.g. process/report
certificate of release)
Check
documentation
during the validation
process for
compliance with
acceptance criteria
Materials and Labelling Check the content Inspection of
reagents of the label labelling
against the
certificate
Check the content of
the label against
conditions (e.g.
temperature/expiry
date/health and
safety/etc.)
Management Check on minimum Inspection on
stock management of
materials and
reagents
Preparation Check on documen- Inspection of
tation (weighing, preparation
dilution, etc.)

Test system Ordering Check documen- Inspection ordering


tation on ordering process
Receipt Check documen- Inspection receipt
tation on receipt process (e.g. health
(acceptance criteria, check)
e.g. health check)

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Set Up and Manage QC and QA 103

Activity Examples of QC Examples of QA

Identification Check uniqueness of Inspection


identification identification
process
Housing (see
facilities)

Test and reference Management (e.g. Check Inspection on


items ordering, receipt, documentation on management
storage, availability) ordering
Check
documentation on
receipt
(acceptance
criteria, e.g.
certificate of
analysis)
Check on minimum
stock
Identification/ Check the content Inspection on
Labelling of the label labelling
against the
certificate
Check the content of
the label against
conditions (e.g.
temperature/expiry
date/health and
safety/etc.)
Formulation Check/witness on Inspection on
documentation formulation
(weighing, dilution,
etc.)
Storage (see See facilities See facilities
facilities)

Standard operating Creating procedures Review of SOPs by Inspection SOP


procedures (SOPs) all relevant parties system (e.g.
availability, training,
Approval Approval by all
current version,
required parties
historical
Distribution Check distribution/ procedures, etc.)
availability

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104 M Visschedijk et al.

Activity Examples of QC Examples of QA

Implementation/ Check training


training documentation
Application Check use of
current version
Management of Check version
historical SOPs control
Check availability
of historical SOPs
Review and/or Check need for
update cycle review/update

Study plan Request for study Check uniqueness of Inspection on GLP


number the code compliance/
adherence to SOPs
Create study plan Peer review
Communication Check on availability
of resources
Critical events/time Scheduling of
schedule inspections
Distribution Check proper
distribution

Contract Outsourcing Inspection


contractors and
Selection of
suppliers
suppliers
Financial and legal
aspects

Process: study performance in-life


Test system Randomization Check on study In-life inspection
plan/SOPs
Identification/ Inspection on QC
handling (e.g. performance and
weighing) acceptance criteria
Dose administration Process/facility
inspections
Test item Formulation analysis Check accountability
Check method for
analysis

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Set Up and Manage QC and QA 105

Activity Examples of QC Examples of QA

Storage Check environmental


conditions

Sample management Collection Check correctness of


samples at sampling
Identification/
(identification,
labelling
condition)

Transfer Check transfer


documentation (e.g.
chain of custody)
Storage Check environmental
conditions
Waste management Collection Check on study plan/
SOPs
Transfer
Storage/disposal
Study deviation Issuance of Check correctness
management deviation or of SOPs and forms
amendment for each activity
Assess and document Check adherence
any possible impact to the study plan
of deviation
Check for proper
documentation
and handling of
any deviations
Check if any
deviation
necessitates the
update of any SOP
Process: study performance analysis
Methods Validation Check validation In-life inspection
Check used method Inspection on QC
against method performance and
indicated in the acceptance criteria
study plan
Process/facility
inspections
Equipment Identification Check on use of
correct equipment
QC test before use Check against
acceptance criteria

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106 M Visschedijk et al.

Activity Examples of QC Examples of QA

Analysis Sample preparation Check


documentation
(dilution,
weighing,
calculation,
identification,
etc.)
Sample analysis Check acceptance
criteria (e.g. QC
samples, parameters,
reanalysis, etc.)

Process: study performance data management (manual and computerized)


Data management Collection Check correctness of Inspection raw
provided data data file
(e.g. animal
Inspection on QC
numbers)
performance
and acceptance
Check on forms of
criteria
manual data
collection
Transfer Check on security
of transfer
Compilation of study Check raw data
file against protocol
Data analysis Processing Check on
validated data
transfer, audit
trail, protection
and integrity
Check QC data set
Interpretation

Process: reporting
Issuance of report Draft report Check use of
correct templates
Check transfer of
data to report
Check
completeness/
correctness (100%)

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Set Up and Manage QC and QA 107

Activity Examples of QC Examples of QA

Peer review
Check for any
possible further
impact of deviations
Final report Check on QA Inspection of report
statement against
Inspection on QC
QA file
performance and
acceptance criteria

Process: archiving
Management Indexing study file Check index Process/facility
inspections
Transfer study file Check if filed data
sets or documen-
tation are
complete and
correct
Check acceptance
criteria by archivist
(e.g. chain of
custody)
Check registration of
incoming documents
Retrieval of files/ Check on SOP
access (see facilities)
Check retention
times
Note: QA can always decide to perform facility-, process- or study-based inspections.

Reference

1. Note for Guidance on Good Clinical Practice, CPMP/


ICH/135/95. Available at www.ich.org [accessed 3
November 2004].

Copyright r 2005 John Wiley & Sons, Ltd. Qual Assur J 2005; 9, 95–107.

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