Norm Howe's blog

Napoleon’s Secret Weapon

Napoleon…now you can learn it; better yet, it’s free.

Napoleon knew how to inspire great achievements in others.  Why everyone doesn’t make use of Napoleon’s knowledge, I don’t know.  They could dramatically improve performance, if they did.  Before I tell you Napoleon’s secret, you should understand why you probably don’t already know it. 

Why Does FDA Hamstring Dietary Supplement Manufacturers?

Why?FDA gives greater flexibility to drug makers than to Dietary Supplement manufacturers.  Why?  Moreover, the flexibility that FDA accords drug makers actually allows them to build better quality into their products than dietary supplement manufacturers.

How to Streamline Your Business Processes

StreamlineSeveral times in this blog I’ve talked about the need to simplify business processes.  In June I discussed how to Speed Process Validation with Limited OQ.  Here’s an example from a completely different business.  The applications of this company’s innovation to regulatory processes are many.

How to Hire Good Quality Assurance Personnel

Manfred Kets de Vries said, “First class people hire first class people.  Second class people hire third class people.  How do you put this maxim into action?

Hiring the right personnel is always critical.  Hiring good QA personnel has a unique set of problems.  And – not to put too much pressure on you or anything – your department IS who you hire.

Speed Process Validation with Limited OQ

speedWhen FDA published its guidance document on process validation in 2011 it re-affirmed the importance of process development.  This sounds like a lot of extra work for people who are barely managing IQOQPQ.

FDA had forced the issue a decade earlier with medical devices and design control.  Now they are telling manufacturers of drugs and biologicals that the DESIGN of their process is just as important as the qualification of their equipment.  But simply documenting Stage 1 of Process Validation is not enough.

It’s Chaotic on the Inside, but We’re Dedicated to Our Customers

rushingIs your workplace chaotic?  Is everybody running in reactive mode?  Does everyone acknowledge that it’s hectic, and then excuse it by saying, ‘We’re responding to our customers’.  Yet, everyone knows that a hectic organization is a costly one, because rushing creates errors.  Nothing drives up costs like an error prone business.

Every Time a Problem Gets Blamed On Operator Error a Quality Consultant Dies

perp walkWhat do you see when you categorize the causes for your nonconformances?  Does operator error account for more than ten percent?  If so, you need to review your Root Cause Analysis system.  You are risking an FDA citation.  More than that, you are leaving money on the table.

Which Metric Really Drives Your Business?

Sales PitchEverybody has a favorite business metric.  Read any best selling how-to manual and somebody will try to sell you an abstract parameter that will surely make you successful.  All you have to do is tweak up that metric and your bonus will break the stratosphere.

My favorite metric is profit.  Profit is a business’s most critical measure.  Without profit, everything else is irrelevant.  You can have the best compliance record in the business and you will soon be out of business.  You can have the best customer satisfaction ratings in the business and you will soon be out of business.

Do We Really Have to Validate? Really??

validation overloadActually, no, you don’t.  But you might want to know what the conditions are.  First, you need to know the difference between validation and verification.  Let’s review how FDA defines validation.  From FDA's Guidance for Industry, Process Validation:  General Principles and Practices

“…the collection and evaluation of data, from the process design stage throughout production, which establishes scientific evidence that a process is capable of consistently delivering quality products.”

The Myth of the Generic SOP

How many times has this happened to you?  You have been assigned the task of writing a Standard Operational Procedure (SOP).  When you grimace and explain that you don't have an extra eight hours to spend on it, your boss says "Why can't we just download a generic one off the internet?"

He says this with such naivete that you realize that more discussion is pointless.  You decide to give in and go along.  Big mistake.

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