fierce biotech webinar mar2015
TRANSCRIPT
Leveraging Cloud toEnable Agility in
Regulated Industries
31 March, 2015Amy Shutkin, Senior Project Manager, NateraBob Kenney, Customer Success Manager, Veeva Systems
• Fast growing genetic testing company that develops and commercializes non‐invasive methods for analyzing DNA
• Company Mission: Help families diagnose and manage genetic disease
• Building innovative cloud‐based products for global life sciences industry
• Over 200 customers in 80 countries
• Company Mission: Customer Success, Employee Success, Speed
Companies
• Disruptive Innovation• Regulation and Innovation• Agile Methodology• Role of EDMS and Selection Process• Document Change Control• Successful Migration• Conclusions
Discussion Overview
Three Horizons of GrowthMcKinsey & Company
Profita
bility
0‐2 years
H1: defend & protect the core business
H2: penetrate adjacent markets
H3: create or develop new markets
3‐5 yearsTime
>5 years
• Regulatory Requirements– FDA 21 CFR Part 11
• Esignatures etc.
– ISO‐13485– CAP accreditation– CLIA certification– New York State DOH– IEC‐62304
Regulatory Compliance
Confidential and Privileged
Product LaunchProduct Launch
9
Design Control Drives New Products to Market
Concept Feasibility & Planning Development Validation Rollout &
Launch SustainingG1 G2 G3 G4 G5
Idea screen Build business case
Try
Fail
Learn
Development Testing & Validation
FDA mandates stage‐gate process but no guidance on how that is achieved
Feasibility & Planning Gate: Design Review
Feasibility & Planning Gate: Design Review
Management Go/No Go decision
Management Go/No Go decision
Development Gate: Design
Review
Development Gate: Design
Review
Validation Gate: Design
Review
Validation Gate: Design
Review
Product Development Characteristics
• Put stake in the ground
• Cross‐functional iterations
• Challenge the results
• Rapidly change direction
BENEFITS OF AGILE PROCESSES
Fail Fast and Learn
Allows for Change
Early Risk Mitigation
Respond Faster
Enables Work in Parallel
Predictable Results
Case Studies
Confidential12
Flexibility is the critical success
factor!
“…too much structure can inhibit creativity.”
Adhering to stage gate process while building in flexibility
Design History File Documents
Quality Management System (QMS) Deliverable Feasibility and
Planning Development Validation Launch Responsible Design History
File (DHF) D U U U,C QA
Requirements Document D U U C Product Mgmt
Specifications document D U U C R&D (Mol Bio,
Stats, Biofx, EngRegulatory Plan D U U C QA
Risk Mgmt Plan / Assessment D U U C
Product Development
Team
Design Plan and Key Milestones D U U C
Team Lead withMol Bio, Stats,
Biofx, Eng Service and Support Plan D U C Support
Traceability Matrix D U C
Product Development
Team Design
Verification Protocol
C C C R&D w/ Team Lead, Biofx, Eng
Manufacturing Plan D U C Manufacturing
Deliverable Feasibility and Planning Development Validation Launch Responsible
Sales Forecast D C Sales Marketing Plan D C Marketing
Post Market Surveillance D C
Customer Support, Produc
Transfer Regulatory
Notifications and Approvals
D C Regulatory
Manufacturing Procedures D C Manufacturing
Design Validation Protocol
D,C C Project Leader wR&D, Biofx, Eng
Design Validation
Report C C Project Leader w
R&D, Biofx, Eng
Labeling Plan D C Manufacturing Stability Studies
Protocol D,C C
Development
Stability Studies Report
D,C C Development
Design Validation
Report D,C C
Project Leader wR&D, Biofx, Eng
Software Verification and
Validation Report
D,C C Project Leader
Supplier Evaluation
D,C C Manufacturing
Launch Plan D C Product
Development Team
Manufacturing and Supplier Agreement
C Manufacturing,
Legal
D = DraftU = UpdateC = Complete
Regulatory and Quality Assurance Requirements Comments
1. Ease of UseIT requirements, document status and reporting capabilities, dashboards
2. Web‐based Cloud‐based, device agnostic
3. Search FunctionalitySearch by document metadata and full text, saved searches
4. Change Order/ControlIterative version/revision control, workflow management
5. Training AutomationLinked to new &/or changed documents, automated calendar retraining scheduling
6. Simultaneous Editing Document review/revision management
7. Security / Access Privileges Legal and IP protections
8. Audit Trails Laboratory focus / CLIA & ISO compliant
9. Integration with Gmail, Okta Automated assignments, reminders
10. FDA 21 CFR Part 11 & HIPPA Compliant Electronic signature support
EDMS Requirements (Not Ranked)Regulatory Compliance is Fundamental
EDMS Vendor Heat MapDeveloped by Natera
Requirements A B C D E Veeva Vault QualityDocs
1 Ease of Use 4 4 3 3 4 5
2 Web‐based 3 4 3 5 5 5
3 Search Functionality 4 3 1 3 3 5
4 Change Order/Control 2.5 2.5 1 1 2.5 4
5 Training Automation 5 3 2 1 5 5
6 Simultaneous Editing 2.5 2 1 4 2 4
7 Security / Access Privileges 3 3 1 2 4 5
8 Audit Trails 5 4 1 1 5 5
9 Integration with Gmail, Okta 3 2 2 4 4 4
10 FDA 21 CFR Part 11 & HIPPA Compliant
5 4 1 2 4 5
Example of Savings Analysis
Average Hourly Creator/Approver Wage $50 $50 n/a
TOTAL COST TO MANAGE A DOCUMENT $4,700 $975
Number of New Documents Per Year 100 100
Average Percent Document Revisions Per Year 25% 25%
Total Documents Per Year 125 125
ANNUAL COST TO MANAGE ALL DOCUMENTS $587,500 $121,875
Manually(in hours)
Automation via Vault
(in hours)
Percent Savings
Note: Numbers are representative and for illustration purposes only. They do not reflect company’s actuals.
DocumentDocumentDocument
Document Change OrderMultiple Affected Documents
Document Change Order
Document Document Document
New Revise Withdraw
SOP‐00108SOP‐00108SOP‐00108SOP‐00108SOP‐00108SOP‐00108
Document Change OrderApproval Process & Version‐Specific Relationships
DCO‐00014
SOP‐00108
v0.1
v1.1
DCO‐00014
SOP‐00108
v1.0
v2.0
SOP‐00108
v2.0
Draft
Draft
DCO‐00014
v0.3
In Approval
SOP‐00108SOP‐00108
SOP‐00108
v1.4
On DCO
Approved
Approved
Doc ControlApproval & Release
Effective
Optional Iterative Review
Release Doc
Document Change OrderBenefits Compared to Document Change Request
UpdateDoc
Redlined DocCopy
Create DCO
Create DCR
UpdateDocs
Change Request Process
Change Order Process
Release Docs
Release Doc
Approve DCR
Approve DCO
Release Doc
Approve Docs
Approve Doc
Buy‐in From‐ Executive Team‐ Cross‐Functional
User Group
Buy‐in From‐ Executive Team‐ Cross‐Functional
User Group
Mindful Shift in CultureVend
or Evaluation
Rollout Initial
Users
2nd Rollout
3rd Rollout
nth Rollout
Make it Easy
Phased Rollout‐ Leveraged Vault’s R&U ‐ New group of users per week
Accessible Self‐Help Training
Clinical Lab Trainers
QA Executives
….
Migration ETL Best Practices
IdentifyMigration approachDocument inventory
ExtractExtract from source(s)
Data MappingMap source / targetReview & update data
TestDry run load processUpdate data as needed
LoadExecute loadVerify migration
• Define data to be migrated: core subset, or full data?• Data owners extract and transform• Use a product for extract, transform, and load steps where possible• Create PDF of source audit trail and associate to migrated record• Use reports to verify / document results• Test business processes using migrated records
Migration and Implementation
System Design
System Configuration
Validation Testing
Implementation Migration
Production Deployment and Data Migration
Identify Source Data
Perform Data Mapping
Perform Data Augmentation
Migration Dry Run
• Benefits of Agile for Innovation• Build Agility into the Stage Gate Process• The Right Application Enables Agility in a Highly Regulated Environment– E.g. supports the 34 requirements for electronic signatures
– Flexible and Configurable Document Change Control Options
Conclusion
• Migration and new system• 1. What were you using before?• Answer: We were on paper and tracking documents manually
• 2. What was the biggest challenge moving to the new system?
• 3. What documents are you managing in the new system?
• 4. Were there any other benefits than agility?• Answer: We can mitigate risks ‐ we have visibility into the process e.g. who has not
completed their R&U tasks, reduced our compliance risks with detailed audit trails and electronic signatures that are 21 CFR Part 11 compliant
• Evaluation• 5. How long did it take to evaluate all the vendors and can you provide some more
info on the evaluation process? Was there an RFI (request for information) you used, demos, or POC?