BioPharm International - March 2024

BioPharm International - March 2024

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www.biopharminternational.com Quality and Regulatory Sourcebook eBook March 2024 BioPharm International ® 11 Risk Management f luence of subjectivity enhances the reliability of risk analyses and risk management at large. Conclusion Subjectivity emerges in ICH Q 9(R1) (8) as a concept that must be addressed to improve the effectiveness of risk management, and in turn the pharmaceutical quality system. In fact, O'Donnell challenges "can an organization do effective Risk-based Decision-mak- ing if its risk assessments are highly subjective?" (16). As mentioned by experts, acknowledging and addressing subjectivit y are crucial for making in- formed and effective risk-based decisions, ultimately leading to improved product quality, patient safety, and product availability. Indeed, subjectivity casts a long shadow on QRM and, by extension, the pharma- ceutical industry as a whole. Updates included in the revision to ICH Q9(R1) re- f lect the growing recognition of the significance of subjectivity in risk management within the pharma- ceutical industry. By incorporating language related to bias, evidence, data, information, knowledge, and knowledge management, the revised guideline ap- pears positioned to enhance the objectivity and reli- ability of risk assessments. These changes included in ICH Q9(R1) provide an opportunity to shine a light on this issue by emphasizing the need to address sub- jectivity and its connection to business outcomes and patient safety. However, while subjectivity has emerged as im- portant in ICH Q 9(R1), significant work remains to develop a clear and shared understanding of what subjectivit y is, when subjectivit y might exist and what to do about it when it does. These topics will be the focus of future research by the authors. Such research is also expected to explore subjectivity in other industries and study best practices. In addition, it is anticipated that training on this topic, and ex- ploring emerging technologies and methods, would be beneficial. Disclaimer The views expressed in this article are those of the authors and are not necessarily those of any organi- zations with which the authors are affiliated. References 1. ICH. Final Concept Paper ICH Q9(R1): Quality Risk Management. 2020. http://www.ich.org 2. ICH. Q 9 Qualit y Risk Management (ICH , 2005). https://database.ich.org/sites/default/files/Q9%20 Guideline.pdf 3. IC H. Q10 Phar mace ut ical Q ualit y Syste m (IC H , 2008). https://database.ich.org/sites/default/files/ Q10%20Guideline.pdf (accessed: Aug. 28, 2023). 4. O'Donnell, K. Quality Risk Management–An Up- date on the Ongoing Revision of ICH Q 9 'Deliver- ing Value and Resilience using QRM' [Conference Proceeding]. in PDA Ireland, Dublin, Ireland, Sep- tember 2022. 5. Ramnarine, E. Solving the Continual Improvement and Innovation Challenge for the Benef it of Patients: How an Ef fect ive Phar maceut ical Qualit y System (P QS) and Risk-Based Approach Could Transfor m Post-Approval Change (PAC) Management. 2021. DOI: 10.21427/960F-8S69. 6. CDER. 2019 Drug Shortages Report. 2019. https:// w w w . f d a . g o v/ d r u g s / d r u g - s h o r t a g e s / r e - p o r t- d r u g- s h o r t a g e s -r o o t- c a u s e s -a n d-p o t e n- tial-solutions 7. Peters, G. Risk of Drug Shortages-United States Senate Committee- Homeland Security & Governmental Af- fairs Report. 2023. https://www.hsgac.senate.gov/ wp-content/uploads/2023-03-20-HSGAC-Majori- ty-Draft-Drug-Shortages-Report.pdf 8. ICH. Q 9(R1), Quality Risk Management (ICH, 2023). https://database.ich.org/sites/default/files/ICH_ Q9%28R1%29_Guideline_Step4_2023_0126_0.pdf 9. Claycamp, G. Controlling Subjectivity in Risk-based Decision Making: The Benefits of Multi-criteria Deci- sion Analysis. DIT Academic Press, 2018. 10. O'Donnell, K. Strategies for Addressing the Prob- lems of Subjectivity and Uncertainty in Quality Risk Management Exercises Part I-The Role of Human Heuristics. Journal of Validation Technology, 2010. 11. O'Donnell, K. Strategies for Addressing the Prob- lems of Subjectivit y and Uncer taint y in Qualit y Risk Management–Part 2 Risk Communication and Perception Issues. Journal of GXP Compliance, 2011 15 (1). 12. Vesper, J. and O'Donnell, K. Current Challenges in Implementing Quality Risk Management. iSpeak Blog 2016 (accessed: Aug. 31, 2023). https://ispe.org/ pharmaceutical-engineering/ispeak/current-chal- lenges-implementing-quality-risk-management 13. Ramnarine, E. and O'Donnell, K. Demonstrating Pharmaceutical Quality System Effectiveness and Driving Continual Improvement: Evidence-based R isk Reduc t ion. PDA J Phar m Sci Technol , 2018 72 (3), pp. 338–345, May 2018, DOI: 10.5731/pda- jpst.2017.008524. 14. Mu l hol la nd, V. a nd Greene, A. Improv i ng R isk Based Decision Making Effectiveness: A Case for Risk Decision Review Points (KDRPs) In The Quality Risk Management Process. KENX Insight 2023 3 (3). 15. Mu l hol la nd, V. a nd Greene, A. Improv i ng R isk Based Decision Making Effectiveness: Addressing Uncertainty. KENX Insight 2023 3 (5). 16. O'D on ne l l , K . IC H Q 9(R 1) a nd S ome Pe r son a l Thoughts about Implementing the New Guidance [Conference Proceeding]. in TU Dublin, PRST Con- ference, Dublin, Ireland, June 2023. ■

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