Developing Standard Operating Procedures



Developing Standard Operating Procedures






There is no more difficult art to acquire than the art of observation, and for some men it is quite difficult to record an observation in brief and plain language.

–William Osler

An organization’s structure is in some senses a somewhat static picture in the short term of where people and functions are placed. What breathes life and activity into this picture is the work that is performed using the organization’s policies (corporate, departmental, and sectional), processes and operational procedures, both formal and informal, which educate people about how they should behave to get their work accomplished and their goals achieved. Standard operating procedures (SOPs) differ greatly for all companies; and within a single company, they differ greatly over a period of time. All companies attempt to balance flexibility and rigidity in developing SOPs that will enhance the efficiency of the activities performed, rather than inhibit and squelch them. Most pharmaceutical companies have significant experience in developing policies, guidelines, and SOPs that attempt to achieve these goals.


DEVELOPING STANDARD OPERATING PROCEDURES

Having the right people and the right environment are the two most important aspects of creating the best situation in which a company may optimize its chances to discover and develop drugs. A lesser, but still important, aspect is to have operating procedures in place that facilitate rather than hinder the work of scientists, clinicians, and others who are discovering and developing drugs. Operating procedures relate both to the bureaucracy that must be adhered to in any institution and to the facilities and equipment present to accomplish the work. Poor systems and facilities can easily lead to frustration and anger.


Purposes of Standard Operating Procedures

Marketing and many other managers believe that all of the beautiful plans generated and clinical trials conducted on early-stage drugs do not equal a single marketed drug that is generating revenue. This reflects the philosophy that a drug “in the hand” is worth the expectation of several that are currently “in the bush” (i.e., at an early stage of development). Operating procedures used to bring a drug to market must be designed to expedite each drug’s development.

SOPs that are shelved and never read are not fulfilling their purposes. The main purposes for creating and adhering to SOPs (not in an order of importance) are as follows:



  • Demonstrate to regulatory agencies that audit the company that the company is in compliance with the requirements of its SOPs for all required operations.


  • Ensure that repetitive operations are conducted the same way each time.


  • Instruct staff how to test various aspects of their work to ensure it meets the standards that are required by internal requirements and external groups.



  • Help educate both new and current staff on how to perform certain activities.


  • Address questions that may arise from new or experienced staff or managers.


  • Help protect the company from legal suits by showing how work is performed.


  • Provide a blueprint of what administrative paperwork must be maintained.


  • Facilitate the efficient running of various operations within and also external to the company. This is an important aspect of shortening the time for development of a drug through to its marketing, by assuring that the workings of a company are as smooth as possible.

If SOPs are written in a very general way to try and fit most situations, they will be a failure, as they will not be able to address many variations and questions about how to do something or how to react to new or unexpected issues. An important goal is to make SOPs as specific as possible. The authors of the SOPs should anticipate the most common problems, exceptions and variations and address each of those in an SOP. There will still be unanticipated questions that will arise, but their number and frequency will be minimized by this approach. The company may need to have one or more internal meetings to discuss which variations to include in the SOPs, as well as which issues to resolve in advance of circulating them for review, even as a draft.

One exception to this principle involves the companies or contract research organizations with offices in several countries. Each office where each site is located may wish to have different SOPs that are developed so that they do not conflict with each other. In such situations, there may be a global SOP on a certain topic that covers general approaches, as long as each site or region has created specific details and nuances that reflect local conditions and circumstances. In this situation, the local SOPs may be referred to by a different name than SOP.

Office automation is an area where great improvements in efficiency have been achieved over the past few decades. The number of new types of equipment and methods for speeding work output is truly staggering. The impact that this has had on improving business productivity, profitability, and competitive advantage is described in many sources, including The Information Edge (Meyer and Boone 1987).


Start with a Standard Operating Procedure on Standard Operating Procedures

New pharmaceutical, biotechnology, and medical device companies are being formed all the time. This means that, at some point, it will become necessary for each of them to produce SOPs. The first SOP to be prepared should be one that sets the rules for creating new SOPs, modifying existing SOPs, and inactivating ones that are in effect. It would be highly desirable if this SOP also provided guidelines of when an SOP is required, but many that the author has seen rarely provide such information. Table 58.1 shows an outline of the categories that are typically included in a SOP, although not all of these topics are necessarily present in any specific SOP. Table 58.2 shows an example of a SOP on SOPs. Before starting to create the SOP on SOPs, it is suggested that the author consult the national regulatory agency for any guidelines that may have been produced. If the company is a subsidiary of a parent company, they will need to contact their headquarters, as they are likely to have an established system of SOPs that should be used as a template for any local manufacturing plants, research facilities or other offices in another country. In addition to serving as a template, care must be taken to ensure that the local SOP does not conflict with the more global ones of the headquarters or other subsidiaries.








Table 58.1 List of categories typically included in standard operating procedures


























































Cover sheet


1.


SOP title


2.


SOP number and effective date


3.


Number of any SOP superceded


4.


Author(s) of the SOP


5.


Signatures and titles of those who approved the SOP


6.


History of changes (i.e., previous versions) of the specific SOP


SOP content


1.


Purpose of the SOP


2.


Scope that the SOP covers and in some cases what it does not cover


3.


Flow diagrams that illustrate how some (or all) of the procedures and processes described are to operate and in which order. Various overlays can provide additional information on these flow diagrams.


4.


Forms that will have to be filled out to fulfill the SOPs requirements. Alternatively, the forms may only be referenced by type and not made part of the SOP since forms almost always change more frequently than SOPs.


5.


Responsibilities (e.g., which group is responsible for each step of a SOP)


6.


Lines of communication and distribution of specific documents, products, etc.


7.


Definitions


8.


Procedures


9.


Filing of signed documentation


10.


References to the literature


11.


References to other SOPs and corporate policies



List of Standard Operating Procedures to Consider

A selected list of SOPs that are relevant, even for a small company to consider developing, is listed in Table 58.3.

This list is far from complete, and was taken from a company with 30 employees. While even this partial list may seem daunting, it should be approached based on the relevance of the specific items and on the company’s immediate and short-term needs for such SOPs. A company that is entirely focused on discovery activities will



need very few SOPs, whereas the number required will grow exponentially if and when the company enters development. If the company’s needs for new SOPs exceeds their ability to produce them internally, there are various vendors who are experienced in helping companies create tailored SOPs that will meet their needs.








Table 58.2 Standard operating procedure on developing and approving standard operating procedures: preparation, review, approval, revision, distribution, and maintenance of standard operating procedures


































































































































































































I. Purpose


To describe the process by which SOPs are developed, reviewed, approved, revised, distributed, and maintained within Company X Pharmaceutical Corporation.


II. Scope


This procedure applies to all SOPs developed for implementation within the company. SOPs will be created for those clinical research activities that are subject to compliance with regulatory requirements and that must be performed in a consistent manner to assure patient safety and data integrity.


III. Responsibility


All personnel involved in clinical research activities at the company are responsible for complying with this SOP when preparing, reviewing, approving, revising, distributing, and maintaining SOPs.


IV. Procedure


A. Administration of SOPs


Regulatory Affairs and Compliance (RAC) has responsibility for the central administration of all company SOPs. Note that a Quality Assurance (QA) Department (or another department) could have the role assigned in this example to Regulatory Affairs and Compliance.


B. SOP format, style, and content





  1. SOPs are prepared according to the standard format, style, and content outlined in this SOP.



  2. SOP format




    1. SOPs contain all the standard headings listed below. Where the heading has no relevance to a particular SOP, the text “N/A” follows the title.




      1. SOP number: Number to be assigned by RAC according to the SOP Numbering System described in Section IV.C below.



      2. Title.



      3. Purpose: Describes what the procedure is intended to achieve.



      4. Scope: Identifies the range of activities covered by the SOP as well as any limitations or exceptions.



      5. Responsibility: Identifies the title/position of the individuals responsible for assuring compliance to the SOP.



      6. Procedure:




        • Describes each component task in the procedure.



        • Identifies by job category or title (e.g., project leader, clinical trials monitor) all individuals responsible for performing the specified tasks.



      7. Review and revision: SOPs will be routinely reviewed on a biennial basis or if personnel report that the SOP does not reflect current operations or is no longer consistent with published policies and regulations governing the conduct of clinical trials or other functions covered by the SOP.



      8. Contingencies: Statement that if the SOP cannot be followed this is reported to the Vice President of Regulatory Affairs who arranges to have the SOP revised or takes corrective action if a planned deviation is not in place.



      9. References: Contains:




        • Related SOPs



        • Any applicable regulations and regulatory guidelines



      10. Definitions: Definitions of words which need clarification in the SOP; if a definition is needed, and one exists in the applicable regulations, that definition is to be used.



      11. Attachments: A list of all attachments with their titles. Supporting documentation can be included in this section.


        Note: Changes made to supporting documents (e.g., forms) shown as attachments to an SOP require the SOP version to be updated.



      12. History of change: Chronological listing of change history of the SOP—includes version number, SOP sections affected, changes made, and effective date. The effective date in the history of change section should be identical to the effective date in the SOP heading.



    2. RAC provides the following for inclusion with the SOP:




      1. Effective date (date on which SOP is implemented into practice—occurs no more than 30 days after SOP receives final authorization.)


        Note: The time between final authorization and the effective date is to allow for training on the SOP.



  3. SOP numbering




    1. SOP numbers consist of a two letter function designator followed by a dash and a chronological three digit number starting with “001” and incrementing by 1 for each new SOP. The function designators are as follows:


      AD = Administrative


      RA = Regulatory Affairs and Compliance


      CL = Clinical Operations


      MA = Marketing


      PR = Production, etc.



    2. The initial new SOP is given version number “.00”, with this number placed at the end of the SOP number, e.g., AD-001.00. The first revision of a document shall be given version number “.01”, e.g., AD-001.01. Succeeding revision numbers are labeled “.02”, “.03”, and so forth.


C. Development, review, and approval of SOPs





  1. Any employee within the company may identify the need for a new SOP or the revision of an existing SOP.



  2. All requests for change require the SOP author to consult with Regulatory Affairs and Compliance on the need for the proposed new or revised SOP. This consultation can take place using electronic mail.



  3. If Regulatory Affairs and Compliance confirms the need for the new/revised SOP, the SOP author drafts the SOP along with any other supporting documentation.



  4. The SOP author is responsible for sending the draft SOP, supporting documentation, and an “Initial Request for SOP Review” (see Attachment A) to Regulatory Affairs for review. a) For a new SOP, write “New” for SOP number and SOP title and “Issue New SOP” for change requested.



  5. Regulatory Affairs and Compliance completes its review and signs the “Initial Request for SOP Review” and returns the form, the draft SOP, and supporting documentation to SOP author with revisions and comments, if any.



  6. As needed, the SOP author makes revisions and again circulates the revised draft SOP and any supporting documentation for review and comment.



  7. Once the final reviewers’ comments are incorporated, the SOP author forwards to Regulatory Affairs and Compliance an electronic copy of the final version of the SOP and any supporting documents.



  8. Regulatory Affairs and Compliance circulates the SOP for approval signatures.



  9. After obtaining all approval signatures, Regulatory Affairs and Compliance adds an effective date to the SOP, as detailed in Section IV.B.2(b)(2). A period for training is often allotted prior to the effective date, and the need for training may be part of the SOP itself, particularly as it applies to new employees.


D. Periodic review of SOPs and document maintenance





  1. Regulatory Affairs and Compliance maintains the master SOP manual with the original, signed paper copy of each SOP and its attachments.



  2. All previous versions of revised/inactivated SOPs are maintained in the Regulatory Affairs historical files.



  3. The review of each SOP is initiated and documented by Regulatory Affairs and Compliance on a biennial basis to determine whether it should remain in use and/or whether revisions are needed.



  4. If it is determined that an SOP is no longer necessary, a “Request for SOP Inactivation” (see Attachment B) is signed by both the person who approved the SOP and the Vice President of Regulatory Affairs to approve inactivation of the SOP. Inactivating the SOP also inactivates any supporting documents and closes any planned deviations in effect. The inactivated SOP and all of its supporting documents are removed from each SOP manual and the company SOP directory. Regulatory Affairs and Compliance maintains a list of all inactive SOPs.



  5. If no changes to the SOP are necessary after the biennial review, the SOP is still revised to the next appropriate revision number with the History of Change stating the revision as “Biennial review, no changes”.



  6. SOPs are confidential internal documents of the company. SOPs are not given to personnel who are not employed by the company without prior authorization from Regulatory Affairs and Compliance. Regulatory authorities may request to examine SOPs when auditing the company’s files.


E. Distribution of SOPs





  1. When an SOP is approved, Regulatory Affairs and Compliance is responsible for placing the original signed paper copy in the master SOP manual and updating the table of contents.



  2. Regulatory Affairs and Compliance also updates the SOP directory on the company m: drive for use by company personnel.


F. Planned deviations





  1. Under certain circumstances, a deviation from an existing SOP is necessary and appropriate. Planned deviations are requested and implemented in accordance with SOP AD-002 and must be documented prior to implementation.


V. Review and revision





  1. This SOP is reviewed on a biennial basis or if personnel report that the SOP does not reflect current operations or is no longer consistent with published policies and regulations governing the conduct of clinical trials or other functions.


VI. Contingencies





  1. Any circumstances indicating that this SOP cannot be followed must be reported to the Vice President of Regulatory Affairs. Inability to conform to this SOP must result in either prompt revision of the SOP or an immediate corrective action if a planned deviation is not in place.


VII. References



AD-002



Planned Deviations


VIII. Definitions



Standard Operating Procedures: Detailed, written instructions to achieve uniformity of the performance of a specific function. Planned Deviations: Deviations from an existing SOP which are planned and approved in advance.


IX. Attachments (forms)





  1. Initial Request for SOP Review



  2. Request for SOP Inactivation


X. History of change


Note: All SOPs produced prior to issuance of this version of this SOP (AD-001.00) do not contain a history of change. The history of change for previous versions of SOPs will not be added retrospectively to the SOPs.


Version number


SOP section affected


Changes made


Effective date


CL-001


Rev 0 (previous SOP)


N/A


N/A


9/29/02


AD-001.00


SOP Number


SOP numbers are revised to reflect new numbering system and a new procedure for all SOPs.


1/21/05




All


Complete SOP rewrite to reflect new practice.


AD-001.01


Section 2. b.


Date on which SOP is implemented into practice. This occurs no more than 30 days after the SOP receives final authorization and any required training is completed.


6/01/05


Attachment A


Initial request for SOP review


Initiated by:





Date initiated:





SOP number:





SOP title:





Change requested:


Reason/Justification for change:


Reviewed by


Title


Signature/date


1.



VP, Clinical


2.



VP, Manufacturing





Others (add titles)


3.



VP, Regulatory Affairs


4.





Attachment B


Request for SOP inactivation


Initiated by:





Date initiated:





SOP number:





SOP title:





Justification for SOP inactivation:


Approved by


Title


Signature/Date


1. Name of Person who originally approved the SOP


Others as in Form A


Same as in Form A


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Oct 2, 2016 | Posted by in GENERAL SURGERY | Comments Off on Developing Standard Operating Procedures

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