sop do what you say say what you dos
TRANSCRIPT
SOPs: What happened to say what you do and do what
you say?
Document control is still one of the most commons areas of
non‐conformance in audits and inspections. Analysis of these
non‐conformances identifies the failure is most often the result
of non‐compliance to the procedure, rather than
noncompliance to the regulation or standard. Let’s look at
some of the practices in industry that contribute to these types
of issues.
Sometimes, SOPs are written very explicitly in an attempt to
error proof them for the employee. As employees become
familiar with the process, they don’t always have the written
document open in front of them when performing the specific
process. This opens opportunities to omit steps or small details
that were included in the procedure, but are not truly critical to
the completion of the process.
Clarity of the procedure is a delicate balance in the amount and
type of detail provided in the instructions. There are some
processes where explicit detail is necessary to assure the
quality of the end product. Here are a couple of examples:
∙ Mix 30 minutes at 37 degrees C. – Is 30 minutes critical? What
happens if it mixes 35 minutes? Or 25 minutes? What if the
temperature goes to 38 degrees?
∙ Product must sit in staging for up to 48 hours – can the
product be released to the marketplace if it sits 50 hours? 72
hours?
∙ Adjust pH to 7.2 – what is the impact on the product if you
overshoot the pH adjustment? Can you adjust further without
ruining the product?
∙ Turn screw 2 ½ times – what happens if you turn the screw 3
times? Or only 2 times?
While these examples may seem extreme, they demonstrate
the importance of clarity in the SOP. Product and process
validation should determine the criticality and impact of
specifics, such as the examples on the end product. Tolerances
should be established (37 +/‐ 2; stage 48‐72 hours) where
appropriate to allow adequate flexibility and prevent potential
manufacturing deviations and non‐conformances. If a
measurement or action is Critical To Quality (CTQ) for the end
product or process, this should be documented in the SOP.
There are many approaches you can take when writing SOPs for
usability. Remember, the auditor is looking for compliance from
two perspectives:
∙ To regulations or standards
∙ To your own processes
Suggest ions for suc c ess:
· K eep i t s im ple. Mak e i t easy for
t he employee t o be com pl ian t
· Too m uc h det a i l (no t c r i t i c a l to
t he qua l it y o f t he end produc t )
c reates pot ent ia l fo r e r ror and
nonconformance
· Make i t c lear i f s teps m ust be
per formed in sequenc e
· Cons ider the use of f low c har t s
over lot s of w ords
· Val idat e t he SOP