Will Remote Pharma GMP Auditing Endure Post-Pandemic?

Before the COVID-19 pandemic, the pharma industry and its regulators would not have entertained the concept of remote audits to verify that the manufacturing and distribution standards of supply-chain partners were being maintained. Even the suppliers themselves would not have expected to be monitored at distance.

The past two years have changed that, as lockdowns, social distancing, and travel restrictions disrupted normal conditions. Rather than curtail audits altogether, with potential risk to product quality and patient safety, regulators like the European Medicines Agency (EMA) adapted their requirements to ensure that inspections could still take place. As well as allowing a grace period, so that marketing authorization holders did not fall foul of compliance requirements if they failed to maintain a maximum three-year auditing cycle (in Europe), the authorities made provision for virtual assessments to be conducted online.

This was only ever intended as a temporary measure, allowing generic-drug manufacturers to continue to qualify and audit their suppliers. Although remote audits offered a convenience that has appealed to service providers conducting audits, that may have lacked suitably qualified local experts on the ground, and to suppliers being inspected, for pharma brands and for industry regulators, the prospect of standardizing on remote audits in the longer term is untenable.

With the best will in the world remote inspections cannot go into sufficient detail compared to on-site audits, meaning there is a risk that something important might be overlooked. That could be something as seemingly innocuous as a cracked floor (which could present a hazard, breaching compliance) to poor levels of cleanliness or haphazard warehouse organization (contamination risk/potential labeling mix-ups). Even in a live remote session with a video link, these transgressions could be missed if cameras are not directed into every corner.

View from the trenches

To understand more fully how the industry has adapted its auditing activities and expectations and the impact this has had, and to gauge emerging priorities for a time beyond the pandemic, in February 2022, Rephine conducted some research among both pharma clients and senior auditors internationally (1). Of the approximately 30 people polled, just over half were in the quality function of pharma companies (the balance comprising professional auditors), and around two-thirds of responses were from Europe, the remainder primarily from Asia—most notably India.

For both respondent groups (clients and auditors), the greatest challenge with remote auditing has proved to be the lack of a site tour, to enable that all-important granular insight into facilities and practices. Although there is the potential for some of this to be covered within virtual sessions, in this scenario it is the auditees that are in control of what is shown. There is much less scope for auditors to spontaneously go off plan and explore behind closed doors if they have a hunch about something and want to look into it further.

As a consequence, auditors taking part in the survey cited the restricted scope for real-life face-to-face interaction, and the ability to apply their softer skills (e.g.,that sixth sense, honed with experience, that something warrants further investigation) as the second major challenge with remote audits. Specifically, the reduced opportunity to identify non-compliance with required standards was of grave concern for professional auditors.

Clients, too, strongly agreed that this limitation presented a concern, though overall they worried more about technology-based issues such as a loss of connection, potentially preventing or interrupting remote inspections.

Can remote audits ever be truly trusted?

Further reflecting the lack of trust in remote auditing as a permanent solution, two-thirds of pharma clients said they wouldn’t accept a remote-only audit as a means of qualifying a new API supplier. Auditors responded similarly. Too much would be left to interpretation, without the option of a physical site visit and a chance to meet teams and assess facilities and processes in person.

Following the same logic, almost two-thirds of client company quality assurance (QA) respondents said they would not be comfortable going more than two years before re-auditing, following a remote inspection: a fifth said they would want to redo the audit within a year. (For auditors taking part in the survey, two-thirds said they would look to re-audit within a year following a remote-only inspection.)

For services like packaging (particularly secondary packaging), remote audits felt more tolerable for pharma clients, but for suppliers of active ingredients or finished products indefinite reliance on virtual inspections was unthinkable. The vast majority [of all respondents or those dealing with packaging?] agreed or strongly agreed that remote/virtual audits were a good temporary solution during the pandemic, but ultimately that an on-site audit carries more weight. A sizeable proportion of client QA respondents also felt that remote auditing could even require additional resources, compared with an in-person inspection (in other words, this isn’t a more time-efficient or cost-effective option).

Could hybrid on- and off-site audits be the way forward?

Going forward, two-thirds of audit clients suggested they would be happy with a hybrid approach to supplier auditing, in which routine aspects such as sharing and completing documentation could be done remotely while on-site inspections took place physically. A third of respondents said they would favor a return to 100% in-person audits. Only one client expressed a preference for persisting with remote audits across both the documentation element and physical inspections.

Open responses in the survey suggested that for remote auditing to have any long-term value this would be for occasional use and in the context of a long-term, trusted relationship, and where standard operating procedures had been shared ahead of time. For auditors, it was felt that any decisions about continued use of remote audits would need to be risk based, and would depend heavily on the willingness of auditees to cooperate, for instance in making the right documents and people available to maximize what was possible.

Where client respondents had themselves played host to remote audits during the pandemic, three-quarters favored a hybrid approach in future, whereby a day on site could be combined with a day providing documentation remotely.

Consolidated auditing

Almost all favored the idea of working with an independent third-party auditor to generate a single, comprehensive report that could be shared with multiple customers, to reduce risks associated with allowing multiple auditors on site over one to three years.

It was through conducting this kind of activity, with strict observance of social distancing, testing, and personal protective equipment (PPE) use, that our own auditors were able to continue conducting on-site audits throughout the pandemic. Although numbers of physical audits halved during 2020 in favor of increased remote activity (and the sharpest reduction in activity was really only during that first global lockdown from March–May of 2020), by 2021 highly accredited auditors located on the ground in target markets were largely back on site—with 82% inspections conducted in person and just 11% done virtually (compared to a ratio of 72% on-site/28% remote audits in 2020).

Whatever the allowances that have been made by regulators during the unprecedented conditions of the past two years, the onus is on all manufacturers and suppliers to maintain regular auditing activity, to safeguard patient safety and to maintain their own industry reputation. One of the useful disciplines encouraged by regular inspections is that of being audit-ready (in other words, maintaining consistently high standards) at all times.

Ultimately, whatever the perceived convenience of at-distance documentation sharing and virtual inspections, there is no substitute for the real thing, and remote activity should only ever be seen as a support activity to the main event. Indeed, any auditing firm worth their salt would not put their name to a remote one-day audit if they could not guarantee its scope and quality and would certainly be looking to complete an additional onsite follow up audit within a year of any virtual activity.

As 2022 progresses, it remains to be seen what the next phase of the pandemic will bring. In some regions with high vaccination rates and reduced hospitalization, a tentative return to some form of normality is already being seen. In other countries with dense populations and still-high infection rates, the situation over the coming months is more uncertain. The key to maintaining high standards of supplier compliance will depend on continued, tailored vigilance—via the optimum blend of audit approaches, underpinned by prompt on-site re-audits as soon as is humanly possible.

Reference

1. Rephine, “Is Remote GMP Auditing in Pharma Viable in the Long Term?” White Paper, June 15, 2022.

About the author

Alasdair Leckie is operations director at Rephine Ltd.