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School of Economics and Management University of Växjö How does Good Laboratory Practice improve quality? Bachelor’s degree thesis in Business Administration Management Control, FEN 330, Spring 2006 Authors: Malin Jansson & Mirja Wynn-Williams Supervisor: Lecturer Stig Malm Examiner: Professor Rolf G Larsson

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School of Economics and Management University of Växjö

How does Good Laboratory Practice

improve quality?

Bachelor’s degree thesis in Business Administration Management Control, FEN 330, Spring 2006 Authors: Malin Jansson &

Mirja Wynn-Williams

Supervisor: Lecturer Stig Malm

Examiner: Professor Rolf G Larsson

Abstract Bachelor’s degree thesis in Business Administration School of Economics and Management, University of Växjö, FEN 330, Spring 2006 Authors: Malin Jansson and Mirja Wynn-Williams Supervisor: Stig Malm How does Good Laboratory Practice improve quality? Background: The quality systems that steer manufacturing of pharmaceutical products from the testing phase to commercial manufacturing are the national and international regulatory frameworks and legislation. Good Laboratory Practice (GLP) is a quality system concerned with the organizational process and the conditions under which non-clinical health and environmental safety studies are planned, performed, monitored, recorded, archived and reported. In Sweden the Medical Products Agency monitors and regulates compliance with the principles of Good Laboratory Practice. Aim: The aim of our thesis is to explore the reasons why companies/laboratories adopt Good Laboratory Practice. We shall do this by identifying the advantages and disadvantages of adopting GLP principles for companies/laboratories, and how quality is improved by adopting GLP principles. We have summarized our aim in one principal question: How does Good Laboratory Practice function as a tool for quality improvement? Limitations: We will focus on GLP, and this thesis will not consider other Good Practice procedures such as Good Manufacturing Practice or Good Clinical Practice. Only laboratories in Sweden monitored by the Medical Products Agency are targeted in the empirical part of this work. Method: Literature research and interviews with GLP contact persons listed by MPA. Results and conclusions: Though costumers’ needs and legislation seem to be the motivations for companies deciding to comply with GLP, quality improvement seems to be the biggest advantage of validation. Proposal for further research: Do laboratory assistants and technical employees differ from management in their experience and views on GLP?

ABBREVIATIONS CRO Contract Research Organization

FDA Food and Drug Administration

GCP Good Clinical Practice

GLP Good Laboratory Practice

GMP Good Manufacturing Practice

GXP GCP, GLP and/or GMP

MPA Medical Products Agency

OECD Organization for Economic Co-operation and Development

PDCA Plan Do Check Act

QA Quality Assurance

SOP Standard Operating Procedures

CONTENTS 1 BACKGROUND AND INTRODUCTION TO GLP ......................................................... 1

1.1 THE PHARMACEUTICAL INDUSTRY.................................................................................. 1 1.2 GOOD LABORATORY PRACTICE...................................................................................... 2 1.3 NEED FOR RESEARCH...................................................................................................... 3 1.4 WHY DID WE CHOOSE THIS SUBJECT? ............................................................................. 3 1.5 AIM ................................................................................................................................ 4

1.5.1 Research question ..................................................................................................... 4 1.6 HYPOTHESIS UNDERLYING OUR RESEARCH..................................................................... 5 1.7 RESEARCH DESIGN.......................................................................................................... 5

2 METHODOLOGIES AND METHODS ............................................................................. 7 2.1 RESEARCH METHODS...................................................................................................... 7

2.1.1 Qualitative research methodology ............................................................................ 7 2.1.2 Quantitative research methodology .......................................................................... 7 2.1.3 Case study ................................................................................................................. 7 2.1.4 Choosing the right research methods ....................................................................... 8

2.2 HERMENEUTIC RESEARCH PARADIGM............................................................................. 8 2.3 DESCRIPTIVE, EXPLANATORY, EXPLORATORY, DIAGNOSTIC AND PROBLEM SOLVING RESEARCH..................................................................................................................................... 9 2.4 DATA COLLECTION METHOD......................................................................................... 10

2.4.1 Literature studies .................................................................................................... 10 2.4.2 Interviews................................................................................................................ 11 2.4.3 Study plan ............................................................................................................... 11 2.4.4 Cumulativeness ....................................................................................................... 12 2.4.5 Representativeness .................................................................................................. 12

2.5 TRUSTWORTHINESS, AUTHENTICITY AND INTEGRITY IN PRODUCING DATA .................. 13 2.5.1 Qualitative research data........................................................................................ 13

2.6 VALIDITY AND RELIABILITY ......................................................................................... 13 2.6.1 Validity.................................................................................................................... 14 2.6.2 Reliability................................................................................................................ 15

2.7 ANALYSIS AND INTERPRETATION STRATEGIES.............................................................. 15 2.7.1 Cluster analysis....................................................................................................... 16 2.7.2 Typologies............................................................................................................... 16

3 THEORY ............................................................................................................................. 18 3.1 HISTORY OF GOOD LABORATORY PRACTICE................................................................ 18 3.2 GOOD LABORATORY PRACTICE.................................................................................... 19

3.2.1 Scope of GLP principles ......................................................................................... 20 3.2.2 Test facility organization and personnel................................................................. 20 3.2.3 Quality assurance programme................................................................................ 21 3.2.4 Standard Operating Procedures (SOPs)................................................................. 22 3.2.5 Facilities ................................................................................................................. 23 3.2.6 Equipment, material and reagents .......................................................................... 25 3.2.7 Test systems............................................................................................................. 25 3.2.8 Test and reference items ......................................................................................... 26 3.2.9 Performance of the study ........................................................................................ 27 3.2.10 Reporting of study results................................................................................... 29 3.2.11 Storage and Keeping of Records and Materials................................................. 31

3.3 QUALITY SYSTEMS ....................................................................................................... 33 3.3.1 Quality systems and the pharmaceutical industry................................................... 34 3.3.2 Quality systems as a managerial tool ..................................................................... 35

3.4 GLP QUALITY SYSTEM ................................................................................................. 35 4 RESULTS............................................................................................................................. 37

4.1 COMPANIES INTERVIEWED............................................................................................ 37 4.2 REPLIES FROM RESPONDENTS ....................................................................................... 38

4.2.1 Interview questions ................................................................................................. 38 4.2.2 Adoption of GLP principles .................................................................................... 39 4.2.3 Why did laboratories seek validation?.................................................................... 41 4.2.4 Implementation and changes needed ...................................................................... 42 4.2.5 Quality systems ....................................................................................................... 42 4.2.6 What advantages did the laboratories gain from GLP? ......................................... 43 4.2.7 Has GLP improved quality, and if so, how? ........................................................... 44 4.2.8 Quality and continuous improvement ..................................................................... 45 4.2.9 Have laboratories experienced any disadvantages from GLP registration? .......... 46 4.2.10 What are the sanctions for non-compliance?..................................................... 48

5 ANALYSIS AND CONCLUSIONS................................................................................... 50 5.1 DRIVERS FOR SEEKING GLP STATUS ............................................................................ 50 5.2 QUALITY ...................................................................................................................... 51

5.2.1 Two paradigms........................................................................................................ 51 5.2.2 How does GLP improve quality?”.......................................................................... 51 5.2.3 PDCA cycle and continuous improvement.............................................................. 52

5.3 VALIDATION PROCESS .................................................................................................. 53 5.4 TO COMPLY OR NOT TO COMPLY................................................................................... 54 5.5 ARE OUR RESULTS REPRESENTATIVE? .......................................................................... 55 5.6 SANCTIONS................................................................................................................... 55 5.7 NO SUCH THING AS A PERFECT SYSTEM ........................................................................ 56 5.8 ANALOGY OF THE GLP CONCEPT ................................................................................. 57 5.9 FUTURE OF GLP ........................................................................................................... 58 5.10 INDIRECT BENEFITS OF GLP ......................................................................................... 60

6 REFERENCES.................................................................................................................... 61 6.1 BOOKS.......................................................................................................................... 61 6.2 DOWNLOADABLE FROM AUTHORITIES’ AND ORGANIZATIONS’ WEBSITES .................... 61

6.2.1 Läkemedelsverkets författningssamling .................................................................. 61 6.3 MANUALS FROM ORGANIZATIONS ................................................................................ 62 6.4 ARTICLES ..................................................................................................................... 62 6.5 NEWSPAPERS................................................................................................................ 62

7 APPENDIX 1 ....................................................................................................................... 63

INTERVIEW QUESTIONS ........................................................................................................ 63 ADOPTION OF GLP PRINCIPLES................................................................................................... 63 HOW THE GLP FUNCTION TODAY? ............................................................................................. 63 OVERALL QUALITY IMPROVEMENT ............................................................................................. 63 SANCTIONS ................................................................................................................................. 63

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1 BACKGROUND AND INTRODUCTION TO GLP

1.1 The pharmaceutical industry Years of research and testing take place before a new medicine reaches the

market, and hundreds of thousands of dollars of costs are incurred before it can be

approved and be licensed. In 2003 over 21 billion euros were spent in the

European Union and 29 billion euros in the USA on pharmaceutical research

(Lääketietokeskus, 2005). By 1938 companies in the USA already had to submit

data and convince the FDA that their products were safe before they would be

approved as ready for sale. In Sweden the regulatory authority is

Läkemedelsverket (or Medical Products Agency in English). In the European

Union a licence is required to sell a new drug and it can be applied from either the

European Medicines Agency (EMEA) or in Sweden from MPA (GLP Handbook).

In February 2006, one pharmaceutical company withdrew its application to

market a new drug (EMEA, press releases) because it caused liver damage as a

side effect. The company not only withdrew the product, it also announced that it

had stopped all further research concerning this medicine, presumably at a large

financial loss to the company. This company’s non-clinical laboratory has GLP

status. Were the principles of GLP properly adopted?

In the 1960s, Thalidomide was a medicine that had been approved by many

national medical agencies (it was marketed under various names in different

countries, including Neurosedyne in Sweden). It had been tested on mice. It was

recommended for morning sickness, but tragically when taken by pregnant

women, it resulted in the birth of thousands of deformed babies (Immel, 2000). In

the 1960s GLP principles had not yet been developed. Could this disaster been

prevented by GLP principles?

Regulatory frameworks (covers stages 2-4 in Figure 1) aim to avoid such

disasters, as do GLP principles (covers stage 2 in Figure 1) that raise the quality of

pharmaceutical procedures.

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Stage 1 DISCOVERY ↓ Stage 2 NON-CLINICAL ↓ Stage 3 CLINICAL ↓ Stage 4 POST-APPROVAL ↓ MANUFACTURING Figure 1: Drug development process The estimated time from stage 1 to manufacturing is approximately 10 years (GLP

Handbook).

1.2 Good Laboratory Practice There have been some disasters with new medicines, such as

Neurosedyne/Thalidomide (Immel, 2000). The quality systems that steer and

regulate manufacturing of pharmaceutical products from the testing phase to

commercial manufacture are the national and international regulation frameworks

and legislation. They include GXP principles, which are quality and validation

systems for the pharmaceutical industry. Good Manufacturing Practice principles

provide regulations for production of pharmaceuticals and Good Clinical Practice

analogous regulations for clinical studies. Good Laboratory Practice is a quality

system concerned with the organizational process and the conditions under which

non-clinical health and environmental safety studies are planned, performed,

monitored, recorded, archived and reported.

The aims of these Principles of Good Laboratory Practice are to promote public

health and environmental safety and to minimize technical trade barriers. Each

country has a regulatory authority responsible for monitoring and inspecting its

companies’ compliance with these principles.

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1.3 Need for research We have not found any research in Sweden or Finland that focused on principles

of Good Laboratory Practice. However, there is a lot of research in related

subjects such as safety and information technology in reporting clinical laboratory

results and other testing in clinical laboratories, and also research on quality in

health care services in general.

1.4 Why did we choose this subject? Quality has become increasingly important to companies as stakeholder groups,

interest groups and members of the public require that their concerns about certain

aspects of companies’ operations are taken into account by managers of the

companies. As highlighted above, unforeseen consequences raise people’s and

authorities’ awareness. GLP principles set out standards for conducting non-

clinical research. GLP principles are stipulated in law, but are not yet well known.

There is a lot of scope for improvement in education as regards GLP principles.

Many students that graduate with degrees that qualify them to work in the

pharmaceutical industry and on research have not even heard of GLP. Literature

in this field is very limited, often very expensive and not easy to access. We

would like promote knowledge of GLP through our thesis.

The authors have very different backgrounds. Malin Jansson is a Master of

Science in Engineering Biology from the Technical Institute in Linköping,

Sweden. She is currently working on microbiological non-pharmaceutical

research at the Institute of Molecular Botany at the Ruhr University in Bochum,

Germany. She is knowledgeable in research laboratory terminology, laboratory

research methods and standard operating procedures.

Mirja Wynn-Williams worked on internal control, risk management and quality

improvement in a Finnish bank in Sweden in the 1990s. This post was created in

the aftermath of the property crash, when banks in Sweden lost billions of

Swedish krona through lax lending, lack of proper risk management, poor

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management control and lack of quality improvement work. In those days

company reports did not include sections called “Corporate Governance” or

“Corporate Responsibility”.

We are both especially interested in GLP principles, though for different reasons.

We approach the complex of problems in this research from different sides. Malin

would like improve her working methods and apply the relevant principles of

GLP in her research work. Mirja is interested in quality improvement. Her current

specialist sector, business advisory services, lacks any national standards, and

quality varies from poor to excellent.

1.5 Aim The aim of our thesis is to explore the reasons why companies/laboratories adopt

Good Laboratory Practice. This will be done by identifying the advantages and

disadvantages of adopting principles GLP for companies/laboratories, and how

quality is improved by adopting GLP principles.

1.5.1 Research question When we were formulating the question we set out to answer, “How does Good

Laboratory Practice function as tool for quality improvement?” we thought that

there are two equally important aspects to this question.

The first part of our question is “How does Good Laboratory Practice function?”

GLP is a quality system that applies to non-clinical research and testing of a

medicine. Why is quality so important in non-clinical pharmaceutical research and

industry?

The last part of our question “a tool for quality improvement” highlights the

importance of one aspect of quality work: it has to be managed. Quality

improvement is a continuous process and it has to be monitored. Quality

improvement helps a company to implement its strategy successfully.

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In adopting any quality system, it is important that all personnel are committed to

quality improvement. According to Deming’s principle, top management has a

key role in promoting quality. Sustainable quality improvement can be achieved

only if the top management are wholeheartedly involved in quality improvement

issues (Bergman et al., 1998).

1.6 Hypothesis underlying our research Why do companies work according to GLP? Is the only reason the demands from

authorities (legislation), and is the major benefit that it makes it possible to sell

and market pharmaceuticals, or does the quality aspect of the system play an

important part? The hypothesis underlying our research is depicted in Figure 2:

Legislation GLP validation

Quality

Alternative validations

Other benefits

Marketing/selling of medicines

Patent issues

Safety

Other drivers

Figure 2. We assume the main driver for companies to seek GLP validation is that it is stipulated by law. Companies are obliged to comply with the legal and regulatory requirements set for pharmaceutical industries.

1.7 Research design We studied the regulatory framework governing GLP Principles. We needed to

study books and publications about GLP, general theories and research

methodology theories to be able to conduct the research. We studied MPA’s web

pages and its electronic publications. We collected data and information on the

laboratories and companies from reports on operations and information on

companies’ web pages.

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Before carrying out our interviews, we selected the laboratories and contacted

them to ask whether they were willing to participate in our research. We then

prepared interview questions to send prior to the interviews so that respondents

had time to prepare their answers. We had sets of open-ended and closed-end

questions.

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2 METHODOLOGIES AND METHODS

2.1 Research methods There are two primary ways of carrying out research in social sciences:

quantitative and qualitative research methods (Andersen, 1998:31,). A third way

is a case study. This is better for showing how and why a company or an

organization operates as it does (Yin, 2003).

2.1.1 Qualitative research methodology Qualitative research is carried out to understand meaning, or to describe and

understand a specific subject, experience, idea or problem. The data collected for

this research includes very little statistical or mathematical data or formulas. The

purpose of this research method is to promote understanding and not to explain

the causality of a phenomenon. Ideally, the data for qualitative research are

gathered through interviews and observations (Andersen, 1998).

2.1.2 Quantitative research methodology Quantitative research methods are used in natural science research. Data collected

to underpin this type of research can be measured or verified through numerical

data. This type of research is based on statistics and mathematical formulas. The

main purpose of quantitative research is to verify the cause of an existing

phenomenon or to prove a hypothesis concerning the subject being studied.

Surveys and questionnaires are suitable methods of collecting this type of data

(Andersen, 1998:31).

2.1.3 Case study According to Yin (2003), the case study approach is the preferred strategy when

the questions “how” and “why” should be answered. Other circumstances that

favour a case study approach are when the investigator has little control over the

events to be studied and if the study is focusing on events happening today.

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2.1.4 Choosing the right research methods According to Andersen (1998:33), the key factors in choosing the right research

methods are:

• Research subject

• Approach to the subject

• Knowledge sought through research

We have chosen to use qualitative research methods, which means seeking

through our research wider knowledge and understanding of our subject, which is,

“How does GLP improve quality?” We have assumed in our research that

laboratories adopt GLP principles mainly because of legal requirements. We

chose qualitative research because the interviewees will enlighten us with their

experience of how they have carried out safety studies in compliance with GLP

principles in their laboratories, and thereby increase our understanding of this

subject. The case study approach could also have been chosen. This would be a

contemporary study and we do not have any influence on GLP practice. The

questions we would like to answer in the thesis are of the “how” and “why” type.

However, the case study approach, although theoretically useful, would not be

possible in practice. Professional secrecy is one of the main obstacles that would

make it impossible to get in-depth information about the GLP systems of the

companies surveyed. One other problem is the fact that this kind of approach

would require more time from the laboratories’ employees. Moreover, a good case

study would require personal meetings and visits to sites for observation, which

would also be impossible.

2.2 Hermeneutic research paradigm The hermeneutic research paradigm aims at increasing understanding of the

subject being researched. It does not focus on validity, but on trustworthiness and

authenticity. The hermeneutic research method focuses on interpreting and

understanding (Rosengren et al, 2002:323). It claims that the best understanding

of a person’s actions comes from trying to put oneself into that person’s shoes and

trying to understand his or her actions from the inside. The hermeneutic approach

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often uses qualitative data. This approach accepts the fact that the researcher’s

personal experience affects the study and analysis. Absolute objectivity is not

required in the hermeneutic approach (Andersen, 1998).

Our research approach is hermeneutic in character. We gather people’s

experiences of GLP through the interviews that we undertake to gain a wider

understanding of how GLP functions.

2.3 Descriptive, explanatory, exploratory, diagnostic and problem solving research According to Rosengren and Arvidsson (2002), the purpose of results sought from

research is the starting point for defining the research task. There are three

common research methods: descriptive, explanatory and exploratory research.

Descriptive research is often used on subjects where a lot of research has already

been carried out and the phenomenon under research is already known. According

to Rosengren and Andersson (2002), this approach answers questions that start

with where, who, how long and how often. Surveys and questionnaires are often

used for this type of research.

Explanatory research aims to find out why something is the way it is. According

to Rosengren and Arvidsson (2002), the question this research approach often

answers is why. This research approach often uses an experiment.

Exploratory research is ideal for studying subjects that are unknown, that have not

been explored before. The purpose with this approach is to create a hypothesis or

a theory that can be tested through research (Andersen, 1998). A lot of data needs

to be collected through a field study, for instance. According to Rosengren and

Arvidsson (2002), this approach answers questions that start with what.

Andersen (1998) presents two more research approaches: diagnostic and problem

solving. The aim of diagnostic research is to propose which factors produce

positive or negative results based on identified symptoms. The problem solving

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approach goes one step further and also aims to suggest solutions to the problems

or how to eliminate identified, diagnosed problems.

Our research approach will be explanatory and promote wider knowledge and

understanding. We consider this approach the most useful for our research. The

most common question under this approach is why, but our research question is,

“How does GLP function as a tool for quality improvement?”

2.4 Data collection method The data collected can be secondary data, in other words data compiled by other

people, researchers or institutions, or primary data that is collected for the thesis

in question (Andersen, 1998).

Primary data that we shall collect comprise interviews with the persons

responsible for quality work in the companies that have GLP status in Sweden.

2.4.1 Literature studies We have listed all types of publications and material in our list of references.

These are secondary data for our research. To gain understanding of the problem

and knowledge of the subject we have chosen for our thesis, we started by

searching for suitable literature. We found the main regulatory framework in the

Swedish Medical Product Agency’s website, which also had links to the OECD

regulations and EU legislation. We searched the Internet and found out that

Karolinska Institutet organizes five credit courses in GLP. We studied the

literature for this course and also online publications for it. We contacted the

inspectors at the medical products agencies in Finland and Sweden, and they

provided us with further information and publications. We have also studied the

two main books for the Management Control System course of the School of

Economics and Management of Växjö University. Through colleagues in other

research laboratories, Malin accessed a GLP Handbook and articles on GLP. We

also obtained warning letters published by the FDA in the USA following

inspections of GLP laboratories in the USA.

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2.4.2 Interviews According to Andersen (1998), there are many characteristics of an interview

conducted for research. An interview can be structured so that the questions are

presented from beginning to end. Questions can be standard questions depending

on a situation. Standard questions in a standard interview situation help to reduce

the time needed for the interview. Both open-ended questions and closed

questions can be included in a standard set of questions.

Closed questions do not serve our research purpose. We would like to find out

how good laboratory practice functions for quality improvement and what are the

drivers for seeking GLP status. Some of our questions for the interviewees are

standard questions. According to Andersen (1998), a semi-structured interview is

suitable for when one has knowledge of some theory and empirical data, but will

gain new information from the interviewees that will serve the purpose of the

research.

We interviewed persons responsible for quality work and also some managers of

the companies that are validated in Sweden through semi-structured interviews.

Keeping our interviews short, avoiding sensitive information and compiling the

results in a short time were all factors that increased the motivation for companies

to participate in research (Andersen, 1998).

2.4.3 Study plan First, we studied the literature and publications in our reference list. Our

presentation of how GLP principles function and what the companies’ compliance

with the principles means is based on these studies.

Our studies were limited by confidentiality and business secrets. We also had

limited time and resources for this thesis. We could not recompense our

interviewees for the working time the interview took. We intended to share the

findings of our project with the companies, so we hoped that people would be

willing to invest the time we required for the interviews.

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Laboratories were not selected for inclusion in or exclusion from our research.

There are only 12 laboratories listed on the Swedish Medical Products Agency’s

GLP inspection programme with GLP status. We invited all these laboratories to

participate in our study. We considered it unlikely that all the laboratories would

participate in our study, so if 10 laboratories participated, that would mean 83% of

GLP laboratory operations subject to MPA’s inspection in Sweden were included

in our research. As we had to limit the time required for the interviews, we had

only a limited number of questions as the basis for the interviews. The questions

were emailed in advance. The interview took place by telephone. Time and

resources permitting, we hoped to visit and meet some of these laboratories.

2.4.4 Cumulativeness This concept means continuing from where science has already reached. Scientific

theory should incorporate existing theory (Rosengren et al, 2002). There is plenty

of literature on the reasons why society has an interest in GLP validation and the

history of GLP validation, but the amount of theory on the reasons for each

company to comply with GLP is negligible. If such information exists, it may be

confidential. We have not found any other work concerning the reasons for

companies to operate according to GLP.

2.4.5 Representativeness This means that the results are concluded to be representative of the group under

investigation. It is important is that the dropout rate is limited and that the

sampling is random and appropriate (Rosengren et al., 2002). However, there is

no sampling in this thesis. There are only six people listed in the Medical Products

Agency as laboratory contact persons (for the 12 companies) for Good Laboratory

Practice Inspections. We tried to keep the dropout rate down through deliberately

drawing up our method to take as little time as possible for the personnel. We also

formulated our questions to exclude any information that we thought would be

hard to answer because of confidentiality. The time available was very limited.

All of these factors should, according to Andersen (1998), make companies less

reluctant to participate.

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2.5 Trustworthiness, authenticity and integrity in producing data

2.5.1 Qualitative research data The data produced in qualitative research focuses on trustworthiness and the

authenticity and integrity, rather than validity, of data (Rolf Larsson’s Lecture F4.

Kvalitativ metod del 3, spring 2006). The data collected through this research

method were interpreted, and this required integrity and trustworthiness from the

person doing the research. All data collected from interviews or observations must

be recorded and written down carefully with every detail. We recorded and wrote

notes during our interviews. We were also in written communication with our

interviewees through email so we could clarify anything that remained unclear

after the interview.

We deliberately gave some time for the interviewees to consider the questions

before answering. We wanted them to have time to think about their answers

thoroughly. This minimized the effect of the interviewee’s personal mood on the

day and the interviewer on the answers.

Although we are adopting qualitative research methods, we could expect some

basic answers from the persons responsible for GLP at the companies would be

the same if we asked them the same questions a month later. However, even

within a month’s time, new equipment or personnel, or SOPs, or requirements

from new management or government regulations could change the situation, and

hence their answers.

2.6 Validity and reliability Validity and reliability are commonly referred to in quantitative research where

quantitative data can be measured in an objective way (Rolf Larsson’s Lecture F4.

Kvalitativ metod del 3, spring 2006).

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2.6.1 Validity To achieve a high degree of validity, the conformity of the theoretical conception

and the empirical variables has to be high. Validity consists of two concepts:

validity and relevance (Andersen, 1998).

Validity says something about the conformity of theory and reality. Relevance

says something about how relevant the empirical variables chosen are to the

problem. There is no objective way of measuring the validity of qualitative data; a

position must be justified (Andersen, 1998). As for the overall relevance of this

thesis, the theoretical material we present in this thesis is common to all of the

GLP validated laboratories that we surveyed. Compliance with GLP requirements

at individual level would be very interesting, but we could not discuss that

because of confidentiality. Our goal is to find out the reasons and consequence of

GLP validation and increase understanding how compliance with GLP principles

functions. Individual answers are therefore irrelevant.

A common and simple way of defining validity is that a valid measurement

measures what it is supposed to measure. Validity is also absence of systematic

errors (Rosengren et al, 2002). Validity can also be external validity, which means

that the findings of a study can be generalized beyond the immediate case study

(Yin, 2003).

This generalization will be applicable to the results of this thesis. The system is

global and although the respondents of our survey will be national, the results will

be applicable to all companies following the GLP guidelines. Systematic errors

are avoided through open questions to which the respondents were totally free to

answer in any preferred way. Questions were posed concerning the general

advantages and disadvantages of GLP, as well as directly about the advantages for

quality. This makes it possible for us to analyse all quality aspects.

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2.6.2 Reliability The objective is to be sure that a later investigator following the same procedures

as described by an earlier investigator would arrive at the same findings and

conclusions (Yin, 2003). For comments regarding this thesis, see 2.6.1.

2.7 Analysis and interpretation strategies We identified from the data from our interviews the reasons why the

laboratories/companies sought GLP validation and how compliance with GLP

principles has affected them. We analysed the reasons on the basis of the theories

we have studied.

The analysis of empirical material should reveal the patterns and relations to be

found in the data. All analysis is a sort of simplification. If the aim of the project

is not purely describing, it is the task of the researcher to arrive at an

understandable explanation of the patterns found (Andersen, 1998). However, the

analysis should not include all the information gained in the project, otherwise

clarity will suffer (Andersen, 1998). Our research approach is explanatory and

promotes wider knowledge and understanding, so the thesis should try to explain

the empirical facts collected.

Analysis of unstructured interviews is much more demanding on the interviewer

in terms of time and creativity than numerical analysis of surveys (Andersen,

1998). Analysis of qualitative data requires that concept definition, categorization,

operationalization, analysis and interpretation are woven into each other and take

place in parallel and to a greater or lesser extent during the whole research process

(Andersen, 1998). We conducted semi-structured interviews, which we hoped

would enable categorization and operationalization, but not eliminate the

opportunity away to gain new information from our interviewees.

Interpretation and discussions of alternative explanations should increase the

reliability of the conclusions from the empirical material. After interpreting a

phenomenon, alternative possible interpretations should be considered to arrive at

the most probable one (Andersen, 1998).

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Our hypothesis is that legislation is the main reason why organizations comply

with GLP principles. That makes it possible for them to produce and sell

manufactured goods. We define the reasons why companies choose to comply

with GLP and determine the effects of the validation on the companies. In doing

so, we look out for other variables affecting the companies than those expected.

The following factors should influence the analysis:

• The characteristics of the data

• The kind of knowledge we wish to produce (Andersen, 1998).

The kind of analysis used depends on the aim of the survey, the researcher’s prior

knowledge of the area of research and its nature (Andersen, 1998). The less prior

knowledge, the more explorative the work must be (Andersen, 1998:186).

Electronic data processing requires coding of the data (Andersen, 1998). As our

data cannot be coded, there will be no electronic data processing in our thesis.

2.7.1 Cluster analysis Cluster analysis aims to define groups of survey units from empirical data that

share similarities and are differentiated from different groups by different values

for defined variables. The critical part of this analysis is to define those variables

(Andersen, 1998). One important task in analysis and interpretation is to

formulate relevant, comprehensive and precise categories from the collected data

(Andersen, 1998).

2.7.2 Typologies One important product of the analysis and interpretation process must be the

construction of a typology, which requires searching for attributes that appear

frequently in the material (Andersen, 1998). The basis is the single survey unit

and the goal is to find subgroups of units that are similar. Though the number of

companies is quite limited, we categorize them into groups according to how they

- 17 -

have answered certain questions. This helps us make the material more

understandable to the reader.

According to Andersen (1998), the question “What does the data say?” is crucial

in qualitative research. The data must be selected. During the work, we tried to

separate actual information from its interpretation by the interviewee. We

analysed the empirical data several times and tried to look beyond the literal

answers to see what the interviewees really meant.

- 18 -

3 THEORY

3.1 History of Good Laboratory Practice The policies behind Good laboratory practice principles were created and

developed in the USA in the 1970s by the Food and Drug Administration (FDA).

This public health agency has protected American consumers by enforcing public

health legislation concerning foods, drugs and cosmetics since 1906. In the 1970s

the FDA inspected some non-clinical laboratories and revealed that some

pharmaceutical studies submitted in support of the safety of regulated

pharmaceutical products had not been conducted in accord with good practice.

The data were inaccurate or insufficient, and therefore inadequate to ensure the

safety of the product. The FDA bases its decisions concerning safety on data from

companies’ studies, so the data must be correct and accurate. The FDA started

drafting a policy for non-clinical laboratory practices that resulted in Good

Laboratory Regulations (Good Laboratory Regulations, 21 CFR Part 58,

December 22, 1978 (43 FR 59986)). The regulations, which came into effect in

June 1979, establish standards for the conduct and reporting of non-clinical

laboratory studies (ISO Guide 25, Agilent Technologies).

The OECD countries followed the FDA’s example and compiled Principles of

Good Laboratory Practice to promote public health and environmental safety in

all OECD countries. These common principles are also intended to minimize

technical trade barriers and make test data comparable between countries so that

duplication of work can be avoided. Each OECD country has a regulatory

authority responsible for monitoring and inspecting companies’ compliance with

these principles. Once validated in one OECD country, this makes it possible to

operate in the whole OECD community. GLP principles can also be adopted in

countries outside the OECD. GLP status in a non-OECD country can be approved

by authorities in an OECD country and will then be accepted in all other countries

(GLP Handbook).

- 19 -

3.2 Good Laboratory Practice The OECD’s principles of Good Laboratory Practice spell out a clear principle:

laboratories should plan, prepare, perform, record and report non-clinical safety

studies and testing carefully and accurately. The validity of the data must not be

compromised at any stage of a study. The test materials, all activities and

methods, and the results should be documented and stored in such way that the

study can be reconstructed. An internal, independent, quality assurance unit is

required in a laboratory or company to ensure the quality of the data, the whole

process and procedures. In this thesis we refer to the OECD’s principles of Good

Laboratory Practice utilizing it for definitions of terms. They can be downloaded

from <http://www.olis.oecd.org/>www.olis.oecd.org.

According to the OECD’s Principles of Good Laboratory Practice revised in 1995

and 1996, “The purpose of these Principles of Good Laboratory Practice is to

promote the development of quality test data. Comparable quality of test data

forms the basis for the mutual acceptance of data among countries. If individual

countries can confidently rely on test data developed in other countries,

duplicative testing can be avoided, thereby saving time and resources. The

application of these Principles should help to avoid the creation of technical

barriers to trade, and further improve the protection of human health and the

environment” (OECD’s GLP principles, Section I, Introduction).

The GLP principles address the following, and so set requirements on them:

• Recruiting, appointing and training of staff and allocating of responsibilities

• Handling of test materials

• Choice of test methods and standard operating procedures

• Quality assurance and quality measurement

• Maintenance and calibration of equipment and machines

• Samples and test data

• Documentation, keeping and storing records and materials

- 20 -

It is ultimately the responsibility of the management of a company or organization

to ensure that it complies with the GLP principles, so it is in the best interest of

the company or organization to raise awareness of GLP.

3.2.1 Scope of GLP principles According to OECD principles section I, item 1, “These Principles of Good

Laboratory Practice should be applied to the non-clinical safety testing of test

items contained in pharmaceutical products, pesticide products, cosmetic

products, veterinary drugs as well as food additives, feed additives, and industrial

chemicals. Non-clinical health and environmental safety studies covered by the

Principles of Good Laboratory Practice include work conducted in the laboratory,

in greenhouses, and in the field.

“Unless specifically exempted by national legislation, these Principles of Good

Laboratory Practice apply to all non-clinical health and environmental safety

studies required by regulations for the purpose of registering or licensing

pharmaceuticals, pesticides, food and feed additives, cosmetic products,

veterinary drug products and similar products, and for the regulation of industrial

chemicals.”

3.2.2 Test facility organization and personnel The management of a laboratory organization or company is ultimately

responsible for the quality and integrity of the testing and studies conducted in its

laboratories (P. A. Carlsson et al, 1998). Section II of GLP principles sets this

requirement out in the first item: “Each test facility management should ensure

that these Principles of Good Laboratory Practice are complied with, in its test

facility.”

What are the duties of management required by the GLP principles? The

management should select qualified individuals to serve as the Study Director

and Deputy Study Director, and also provide a sufficient number of qualified

laboratory staff. The job descriptions, qualifications, training and experience of all

- 21 -

the personnel should be recorded and updated regularly. Each study conducted at

the laboratory requires the appointment of a responsible Study Director and

Deputy Study Director. The Study Director drafts a new study plan, which must

be approved by the management before it is started. The management should

ensure that there are Standard Operating Procedures that have to be approved by

the management before implementation. They should also ensure that there is a

Quality Assurance Programme and that the Quality Assurance unit carries out its

duties in accordance with GLP principles.

The Study Director shall assume full responsibility for the GLP compliance of all

activities and procedures of a study, and must approve and sign the final report of

the results. The Study Director is also responsible for ensuring that no data in the

study or testing are compromised at any stage. If something is not conducted in

accordance with GLP principles, the Study Director must take corrective action

(GLP Handbook).

3.2.3 Quality assurance programme GLP principles require that a laboratory/company has a quality assurance unit and

QA inspector (head of QA unit) that monitor and inspect the facilities and the

operations carried out in the laboratory. The company/laboratory has to have a

quality assurance statement. The regular inspections by the

laboratory’s/company’s own Quality Assurance Unit are reported and the reports

kept. The inspections should cover organizational issues (such as staff levels,

qualifications, planning of work, understanding duties), procedures for QA,

facilities (such as health, safety, hygiene requirements), animal facilities (such as

housing of different animal species separately, separation of clean and dirty

areas), test substances, laboratory operations (such as different laboratory

operations for different activities, monitoring of environmental conditions,

facilities for the retention of samples and records) and equipment (such as

condition, tolerance). These inspections also cover manual data recording and

computer generated data, as well as standard operating procedures, preparations

of reports and archiving of them (P. A. Carlsson et al, 1998). Detailed raw data

audits should be carried out as part of these inspections. Errors such as wrong

- 22 -

species, wrong factors or data used in calculations, inappropriate statistics applied

and misspellings or missing or wrong references to test substances must be listed

in audit reports.

These records are available to government inspections and sponsors. These

internal inspections are an excellent opportunity to promote best practices and

prevent errors, rather than detect them. We refer to the details of this GLP

principle requirement and the internal inspections in the enclosed OECD’s GLP

principles.

3.2.4 Standard Operating Procedures (SOPs) The OECD principles state that GLP laboratories should have written SOPs and

they should cover the following categories of laboratory activities: test and

reference substance, apparatus and reagents, record-keeping, reporting, storage

and retrieval, test system, quality assurance procedures, and health and safety

precautions.

SOPs need not to be limited to these categories. OECD principles list the key

issues in each required category (see OECD’s principles). SOPs depend on the

organization and activities of each laboratory. GLP principles require that SOPs

should be approved by management. What company CEO would want to

authorize sixty different instructions in non-clinical laboratory activities? What

responsibility would such an approving signature entail? The purpose of

authorization is to decide on an appropriate method for a given procedure,

standardize the laboratories’ performance of the procedure, and communicate

these decisions to everyone involved (P. A. Carlsson et al, 1998). A rational

approach to effective authorization is to include this in a company policy in which

this authority to approve SOPs is delegated to someone with management status

and special insight and knowledge. Those persons empowered with this authority

must be high-ranking managers in the organization, as they take full responsibility

for authorizing the procedures. This is a requirement of government officials in

some countries.

- 23 -

The SOPs must communicate their message effectively in the language currently

used in the laboratory. Instructions should be written in the right order using clear

short words and terms, and short sentences where possible. Everyone involved

should have immediate access to SOPs.

Serious deviations from SOPs should be immediately reported to the Study

Director and fully documented in the study data. Such deviations may delay the

whole study, but rescheduling and redoing the test in full compliance with SOP is

better than having the data of the whole study declared invalid in the final report.

SOPs should be reviewed regularly. SOPs should also include a procedure for

updating a SOP. SOPs bring other advantages to the company/laboratory in

addition to production of quality data: they clarify working routines and

responsibilities. Good SOPs signal the management’s commitment to quality

documentation and GLP (P. A. Carlsson et al, 1998).

3.2.5 Facilities The OECD principles state that GLP studies should be carried out in testing

facilities of suitable size, construction and location to meet the requirements of the

study and minimize disturbances that would interfere with the validity of the

study. The building materials used in construction of GLP laboratories should be

such that they are easy to clean but do not allow test materials to accumulate and

cross-contaminate others. Any internal or external potential threat to the study

should be minimized. Testing facilities should be designed so as to provide an

adequate degree of separation of the various aspects of the study (OECD

principles). The objectives of the study and how to achieve them should be

carefully considered. The functions or activities must be separated so that they

would not compromise the study. Walls, filters and isolators can be used for

physical separation.

Entries to certain areas should be restricted. If clean and dirty materials are moved

around the facility and they cannot be handled in separate areas, they should be

handled at different times of day.

- 24 -

Areas within a laboratory should be defined for carrying out certain activities.

Special attention to areas concerned with test material control and mixing with

vehicles is required. Areas should be designated so that they allow laboratory staff

to carry on their work without risk of getting in each other’s way or mixing up

different materials. Separation can also be achieved by letting the staff carry out

different function at different times, allowing time for cleaning between working

shifts.

The GLP Handbook lists these as important areas to be separated:

• Storage of test items under different conditions

• Storage of control items

• Handling of volatile materials

• Weighing

• Mixing of different dose formulations, e.g. in the diet or as solutions or

suspensions

• Storage of prepared doses

• Cleaning equipment

• Offices and refreshment rooms

• Changing rooms

According to the GLP Handbook, the following areas should be kept separated in

animal facilities to meet the requirements set by GLP principles:

• Species

• Studies

• Quarantine

• Changing rooms

• Receipt of materials

• Storage

– bedding and diet

– test doses

– cages

• Cleaning equipment

- 25 -

• Necropsy

• Laboratory procedures

• Utilities

• Waste disposal

3.2.6 Equipment, material and reagents All appropriate equipment including computer systems with adequate capacity

should be available for proper conduct of the study, and they should be

periodically inspected, cleaned, maintained and calibrated to ensure accurate

performance. Dates and details of maintenance, repairs, calibration and any non-

routine work should be recorded and retained (GLP Handbook).

The OECD principles state that materials used in a study should not adversely

interfere with the test systems.

Requirements concerning labelling and providing details of all chemicals,

reagents and solutions used in the study are specified in the OECD principles.

3.2.7 Test systems The definition of a test system according to GLP is very varied. Test systems are

often animals, but they can also be plants, bacteria, organs, cells or analytical

equipment (GLP Handbook). Analytical apparatus used to generate physical or

chemical data should be suitably located and of appropriate design and adequate

capacity. The integrity of the physical or chemical test systems should be ensured

(OECD principles).

If the test system is biological, proper conditions should be established and

maintained for the storage, housing, handling and care of biological test systems

to ensure the quality of the data. Newly received animal and plant test systems

should be isolated until their health status has been evaluated. At the experimental

starting date of a study, test systems should be free of any disease or condition

that might interfere with the study. Any diagnosis or treatment of any disease

- 26 -

before or during a study must be recorded. Records of source, date of arrival, and

arrival condition of test systems should be maintained. Biological test systems

should be acclimatized to the test environment for an adequate period before the

first application of the test or reference item. All information needed to identify

the test systems properly should appear on their housing or containers (OECD

principles).

Housing or containers for test systems should be cleaned at appropriate intervals

during use. Any material coming into contact with the test system should be free

of contaminants at levels that would interfere with the study. Bedding for animals

should be changed as required by sound husbandry practice. Use of pest control

agents should be documented. Test systems used in field studies should be located

so as to avoid interference in the study from spray drift and from past usage of

pesticides (OECD principles).

3.2.8 Test and reference items Reference items or substances are important because they are used to calibrate

instruments. The accuracy of the analytical method is therefore determined by the

accuracy of the reference item (ISO Guide 25, Agilent Technologies).

Records should be kept including test item and reference item characterization,

date of reception, expiry date, and quantities received and used in studies (OECD

principles). Methods of synthesis, fabrication or derivation of test and control

articles should be documented and included with the study (ISO Guide 25,

Agilent Technologies). Handling, sampling and storage procedures should be

controlled so that stability is ensured as far as possible and contamination or mix-

up are prevented. Storage containers for the test and reference items should carry

identification information, expiry date and specific storage instructions (OECD

principles). Storage containers should be assigned to a particular test article for

the length of the study (ISO Guide 25, Agilent Technologies).

Each test and reference item should be appropriately identified. It must be

possible to define each different batch of the test. In cases where the test item is

- 27 -

supplied by the sponsor, there should be a mechanism to verify the identity of the

test item subject to the study. The stability of test and reference items under

storage and test conditions should be known for all studies (OECD principles).

The stability of each test or reference item should be determined. This can be

done either before starting the study or according to written SOPs that provide for

periodic reanalysis of each batch (ISO Guide 25, Agilent Technologies). A sample

for analytical purposes from each batch of test item should be retained for all

studies except short-term studies (OECD principles).

3.2.9 Performance of the study Study Plan

A written plan for each study should exist before the start of the study. The study

plan should be approved by the dated signature of the Study Director and verified

for GLP compliance by Quality Assurance personnel. Changes to the study plan

must be scientifically justified and approved by the dated signature of the Study

Director and kept with the study plan (ISO Guide 25, Agilent Technologies).

Deviations from the study plan should be described, explained, acknowledged and

dated in a timely fashion by the Study Director and maintained with the study raw

data (OECD principles). Changes must not obscure the original (ISO Guide 25,

Agilent Technologies).

Content of the Study Plan

The study plan should contain, but not be limited to the following information:

Identification of the Study, Test Item and Reference Item

A descriptive title and a statement that reveals the nature and purpose of the study

and the test items and reference item to be used must be identified by a code or

name

Information Concerning the Sponsor and the Test Facility

Name and address of the sponsor, the test facilities, test sites and Study Director.

- 28 -

Dates

The date of approval of the study plan by the signature of the Study Director. The

date of approval of the study plan by the signature of the test facility management

and sponsor if required by national regulation or legislation in the country where

the study is being performed.

Other important dates are the proposed experimental starting and completion

dates.

Test Methods

Reference to the OECD Test Guideline or other test guideline or method to be

used.

Issues (where applicable)

• Reason for selection and characterization of the test system.

• Method of administration and reason for selecting it.

• Detailed information on the experimental design.

Records

A list of records must be retained.

Conduct of the Study

According to the OECD principles:

1. A unique identification should be given to each study. All items

concerning this study should carry this identification. Specimens

from the study should be identified to confirm their origin. Such

identification should enable traceability of the specimen and

study.

2. The study should be conducted in accordance with the study

plan.

- 29 -

3. All data generated during the conduct of the study should be

recorded directly, promptly, accurately and legibly by the

individual entering the data. These entries should be signed or

initialled and dated.

4. Any change in the raw data should be made so as not to obscure

the previous entry, should indicate the reason for change and

should be dated and signed or initialled by the individual

making the change.

5. Data generated as a direct computer input should be identified at

the time of data input by the individual(s) responsible for direct

data entries. Computerized system design should always provide

for the retention of full audit trails to show all changes to the

data without obscuring the original data. It should be possible to

associate all changes to data with the persons having made those

changes, for example, by use of timed and dated (electronic)

signatures. Reason for changes should be given.

3.2.10 Reporting of study results GLP principles provide detailed information and requirements for how a final

report for each long-term study should be prepared. For short-term studies, a

standardized final report may be prepared. These reports should be dated and

signed by the Study Director, principal investigators and/or scientists who were

involved in the study. The signing of the data by the Study Director indicates

compliance with GLP principles, and his acceptance of responsibility for the

validity of the data. The Study Director is responsible for the scientific

interpretation of the results of the study (GLP Handbook). Reasons for

amendments (corrections and additions) to a final report should be clearly

specified and approved, then signed and dated by the Study Director.

Reformatting of the final report to comply with the submission requirements of a

regulatory authority does not constitute an amendment to the final report

(OECD’s GLP principles).

- 30 -

The detailed contents of the final reports according to OECD’s GLP principles

shall be:

“1. Identification of the Study, the Test Item and Reference Item a) A descriptive title; b) Identification of the test item by code or name (IUPAC,

CAS number, biological parameters, etc.); c) Identification of the reference item by name; d) Characterization of the test item including purity, stability

and homogeneity. 2. Information Concerning the Sponsor and the Test Facility a) Name and address of the sponsor; b) Name and address of any test facilities and test sites

involved; c) Name and address of the Study Director; d) Name and address of the Principal Investigator(s) and the

phase(s) of the study delegated, if applicable; e) Name and address of scientists having contributed reports

to the final report.

3. Dates Experimental starting and completion dates. 4. Statement A Quality Assurance Programme statement listing the types of

inspections made and their dates, including the phase(s) inspected, and the dates any inspection results were reported to management and to the Study Director and Principal Investigator(s), if applicable. This statement would also serve to confirm that the final report reflects the raw data.

5. Description of Materials and Test Methods a) Description of methods and materials used;

- 31 -

b) Reference to OECD Test Guideline or other test guideline or method.

6. Results a) A summary of results; b) All information and data required by the study plan; c) A presentation of the results, including calculations and

determinations of statistical significance; d) An evaluation and discussion of the results and, where

appropriate, conclusions. 7. Storage The location(s) where the study plan, samples of test and

reference items, specimens, raw data and the final report are to be stored.”

We have presented this section in detail, as we consider that compliance with this

section is crucial to ensure success in high quality testing and research. The

fundamental principle of this section is that laboratories should conduct non-

clinical testing and safety studies carefully and document all the activities so that

the study can be reconstructed in future at any time.

3.2.11 Storage and Keeping of Records and Materials For regulatory purposes and for the company’s own research purposes, the records

and materials of a study conducted according to GLP principles should be stored

and the records safeguarded. If any data are lost or details are not recorded

properly, the validity of the data is compromised. In other words, what was done,

how, by whom and when must be accurately included in the records. The archives

should be maintained in a systematic, organized way, and storing and record

keeping should be conducted simultaneously so that nothing is lost or forgotten.

GLP principles set out the requirements for reconstruction of a study, so it is

important to store and keep records and materials in a safe place for a period of

time. How long they must be stored is specified by the regulatory authorities.

- 32 -

The archives should be indexed and recorded in a way that makes accessing them

easy. Only authorized people should have access to the archives, and the moving

of records in and out should be monitored and recorded.

The following should be stored and kept according to OECD’s GLP principles:

“a) The study plan, raw data, samples of test and reference

items, specimens, and the final report of each study;

b) Records of all inspections performed by the Quality

Assurance Programme, as well as master schedules;

c) Records of qualifications, training, experience and job

descriptions of personnel;

d) Records and reports of the maintenance and calibration of

apparatus;

e) Validation documentation for computerized systems;

f) The historical file of all Standard Operating Procedures;

g) Environmental monitoring records.

“In the absence of a required retention period, the final disposition of any study

materials should be documented. When samples of test and reference items and

specimens are disposed of before the expiry of the required retention period for

any reason, this should be justified and documented. Samples of test and reference

items and specimens should be retained only as long as the quality of the

preparation permits evaluation.

- 33 -

“If a laboratory or test facility or an archive contracting facility goes out of

business and has no legal successor, the archive should be transferred to the

archives of the sponsor(s) of the study(s).”

As more and more data are recorded and stored electronically, the security and

safety of hardware and software increases in importance. Laboratories and

companies should have proper authorization systems and restricted access to

appropriate files. There should be adequate user ID management, regular changes

of passwords and firewalls installed. When storing information in electronic form,

it is also important to store the data in a form that will be retrievable in the future.

As hardware and software are all the time being developed and upgraded, it is

important to retain hardware or software that can retrieve the stored files, or

alternatively a procedure to convert the files to an upgraded version should be

defined and undertaken accordingly. In a large company or laboratory, the

computer function may be centralized. The requirements spelled out in GLP

principles should be clearly communicated to this function, which should provide

back-up systems for computer failures and means of retrieving any data lost in

breakdowns.

Normally, a company has an emergency or crisis management plan for

unexpected events beyond its control, such as war or a state of emergency

declared by the government, natural disasters, fire or attack by terrorists or animal

rights activists or persons opposed to genetically modified crops. The appropriate

requirements of GLP principles should be fully incorporated into this plan to

ensure no loss of crucial data.

3.3 Quality systems The purpose of quality systems is to improve quality within the company. The

roots of today’s quality systems originate from the USA. In the 1920s W. A.

Shewhart developed methods for product control, and in the 1950s Joseph Juran

and W. E. Deming developed methods for process control (Bodin et al, 2003).

The most significant quality improvement took place in Japan, where kaizen

- 34 -

(continuous quality improvement) and kanban (just in time) were developed by

Japanese companies to gain a competitive edge over competitors. The Total

Quality Management (TQM) philosophy was developed in the 1980s, and the

Malcolm Baldrige National Quality Award based on TQM philosophy was

established as a standard in 1987. This was the model for the Swedish standards

established by the Swedish Standards Institute, SIS (Sweden), which was

established by a government decree in 1990 (Bodin et al, 2003).

The International Organization for Standardization is responsible for the

international quality management system ISO 9000 series of standards. Each

company can choose the standards suitable for its operations. ISO 9000 is a

certification granted to companies that manufacture goods. It specifies that they

have properly recorded all of their processes, which meet certain specifications.

The standards deal with factors such as quality management system, management

responsibilities, resource management (material and human resources), and the

processes a company uses and how it measures data to monitor its quality control

and then use the results to improve quality requirements. EN ISO 9001-2000 is a

quality assessment scheme for laboratory medicine. Guidance for document

management, for instance, is in ISO 9000 and ISO 14000.

3.3.1 Quality systems and the pharmaceutical industry Quality systems, and national and international standards are created to improve

the quality of products and services. Quality has many dimensions and works on

many levels. According to definitions of quality, customer satisfaction is the

ultimate benchmark of quality (Bergman et al, 1998:298). Quality according to

many definitions is essentially satisfying customers’ needs and expectations,

preferably over-satisfying these needs (Bergman et al, 1998). For pharmaceutical

products, the safety of a product is its key quality factor after its therapeutic

purpose: a medicine must have no significant adverse side effects. In general

terms, one could say that for a medicine, good quality means that it is good for its

therapeutic purpose and has no significant adverse effect, so the pharmaceutical

industry should manufacture such medicines to satisfy their customers.

- 35 -

3.3.2 Quality systems as a managerial tool Elements of management control systems include strategic planning, budgeting,

resource allocation, performance measurement, evaluation, reward, responsibility

centre allocation and transfer pricing (R. Anthony et al 2003). The overall purpose

of a management system is to help a company to implement its strategies. When a

company decides to implement a quality system as a part of its management

system, this can enhance its performance in many ways.

Improved quality can affect profitability in many ways:

• More satisfied customers, who buy again

• Lower staff turnover and days of sick leave

• Improved competitive position in the market

• Shorter standstill times, delays

• Facilitates effective use of capital resources

• Less defects, unusable products and rework

• Improved productivity

(Bergman et al, 1998, including its Figure 2.1)

Deming describes this in the following figure (Deming, 1986):

Improve quality } → Costs decrease because of less rework } → Productivity improves } → fewer mistakes,

fewer delays, fewer snags, better use of machine time and materials } → Capture market } → Stay in business

} → Provide jobs and more jobs } → with better quality and lower prices

3.4 GLP quality system A good understanding of Good Laboratory Principles and their adoption helps

laboratories in their quality improvement. GLP is a managerial tool covering the

organizational process and the conditions under which non-clinical laboratory

studies are designed, conducted, monitored, recorded and reported. A good

documentation practice ensures high ethical standard in any study a laboratory

undertakes. The intention of GLP is to promote the quality and validity of the data

forming part of the studies. The requirement spelled out in GLP principles on

- 36 -

internal quality assurance within a company must be seen as one part of an overall

quality system of the company’s total quality management system. The duties of

management personnel as described by GLP principles entail great responsibility.

According to Deming’s principle, it is the top management that have a key role in

promoting quality. Only through top management being wholeheartedly involved

in quality improvement issues can a sustainable quality improvement be achieved

(Bergman et al, 1998). Compliance with GLP principles increases the company’s

profile as a provider of safe and high quality products and enhances its

competitive position in the market. The scientific work that companies produce

can also be commercially utilized as it is produced to international standards

(P.A. Carlsson et al., 1998).

- 37 -

4 RESULTS

4.1 Companies interviewed We invited all the twelve GLP laboratories listed in MPA’s GLP programme to

participate in our research. These twelve GLP laboratories were represented by six

contact persons on MPA’s list because one person represented seven laboratories

owned by the same pharmaceutical company. All these six people were

interviewed and contributed valuable information to our study, which covers the

operations of all the GLP laboratories monitored by MPA in Sweden. The

companies have a wide range of activities and different sizes.

Here follows a short description of the companies in alphabetical order.

Active Biotech

The present company, situated in Lund, originated from part of Pharmacia that

was bought by Active Biotech in 1997. Active Biotech focuses on developing

pharmaceuticals for medical fields in which the immune system plays a central

role.

AstraZeneca

AstraZeneca was formed in 1999 through the merger of Astra AB of Sweden and

Zeneca Group PLC of the UK. The company has research, production and

marketing facilities in Sweden. Astra AB, which was founded in 1913, is

headquartered in Södertälje. Astra was an international pharmaceutical group

engaged in the research, development, manufacture and marketing of

pharmaceutical products, primarily for four main product groups: gastrointestinal,

cardiovascular, respiratory and pain control. Some research effort was also put

into the central nervous system.

BioVet

The company was founded in 1983 in Stockholm. BioVet is a veterinary medicine

laboratory that concentrates on pets and racehorses. It specializes in

histopathology, cytology and immunology tests.

- 38 -

Quintiles Transnational

Quintiles is a global contract research company established in North Carolina,

USA in 1982. It provides the full spectrum of product development and

commercialization activities, from early compound development, laboratory

services and regulatory submission to sales and marketing. Quintiles employs

about 16,000 people in 50 countries, including 400 working on Quality Assurance

and 1,000 on information technology and communications.

National Veterinary Institute (SVA)

The National Veterinary Institute is a Swedish national authority that strives for

good animal and human health, a good environment and sustainable food

production. GLP studies are only a small part of its operations: only two of SVA’s

four hundred employees work on GLP studies carried out by SVA as a Contract

Research Organization. SVA provides diagnostic activities and preparedness by

developing diagnostic methods and laboratory products. Bacterial diagnostics,

substrate products and cell culture media are mainly prepared for SVA’s own

diagnostics. Blood products are produced from horses, cattle, sheep, goats, rabbits

and poultry from SVA’s own Swedish herds and flocks. SVA also supplies the

vaccines required in preventing disease. It has its own research, production and

marketing of autogene vaccines.

Visionar Biomedical

Visionar, which was established in 2000 in Uppsala, Sweden, has five employees.

It is a contracting research company providing services for pharmaceutical and

biotechnology companies. Visionar helps its customers even with the evaluation

of their preclinical project strategy, or gives a “second opinion” about the

potential of a product.

4.2 Replies from respondents

4.2.1 Interview questions The questions asked can be divided into three groups. First, we wanted to know

about the validations process: why did the company want to implement GLP,

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when did it start the process of compliance, how long did that take and what are

its experiences of the process? Secondly, we wanted to know what changes GLP

had brought to the company, especially positive and negative effects on quality.

Thirdly and finally, we asked what effect losing GLP quality status would have on

the company (for a complete list of questions, see appendix 1).

A summary of the answers that does not link the answers to a specific company

will be given here.

4.2.2 Adoption of GLP principles The time that GLP has been in use in the various laboratories differs a lot. One of

the businesses employed the first workers engaged in GLP on 20th June 1979 as

GLP became statutory through legislation in the USA, whereas one has been

validated only since 2001 (see Table 1).

Table 1. Dates of introduction of GLP and time needed for implementation.

GLP since Duration of validation process 1979 - About 1990 - 1996 1-2 years 2000 1 year 2000 1-2 years 2001 6 Months

Of the two respondents not specifying a duration, one said that the company had

been working according to GLP for such a long time before validation was

conducted in Sweden that it was impossible to say how long the validation

process took, and the other said that the company was already validated when it

was bought by the current firm.

For the laboratories that sought validation immediately after the regulatory

framework became into force in Sweden in the 1990s, it took between one and

two years to gain GLP status, whereas for the laboratories that sought GLP

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validation after 2000, it took only one year, and for the laboratory that gained

GLP status most recently, it took only six months to be approved by MPA as a

GLP laboratory.

There has been compliance with GLP principles for over ten years in Sweden, but

our research shows these principles are still not well known. Bioanalyst training,

for instance, does not include any training in GLP principles.

The laboratories provided internal and also external training to keep staff updated

on GLP principles. All but two laboratories stated that the staff they recruited had

no knowledge of GLP: one respondent said that if there were two applicants

otherwise equally qualified, but one had experience of GLP, then the one that had

experience of GLP would be recruited; another respondent did not answer the

question. Regulatory frameworks including GMP and GLP principles aim to raise

the quality of pharmaceutical procedures. However, although GMP and GLP

principles are stipulated in law, they are not yet well known. This is a problem for

pharmaceutical companies needing to employ graduates that are qualified to work

in the pharmaceutical industry, as hardly any of them have heard of the principles

of GLP. Three of the six respondents stated that new recruits to GLP laboratories

had no knowledge of GLP at the time of recruitment. They had to be trained in

GLP principles.

The interviewees’ overall experiences of adopting and complying with GLP

principles were good. All but one respondent stated several ways through which

quality had been improved by adopting and adhering to GLP principles. The only

laboratory that had no experience of quality improvement stated that the question

whether GLP had improved quality of its operations did not apply because it had

been set up with a business strategy of doing only GLP studies, in other words this

laboratory did not start its operations until MPA had approved its status as a GLP

laboratory, so it had achieved consistent GLP high quality from the start.

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4.2.3 Why did laboratories seek validation? Two laboratories stated that they sought GLP validation because it was a

requirement from authorities for doing the type of studies (GLP studies) the

laboratories wanted to conduct. It was necessary for the firm to be able to keep on

working as before. Working according to GLP became obligatory in the USA in

1979. Pharmaceutical companies that wanted to keep on registering drugs there

had to introduce GLP in the daily work. Two of the firms are or were part of large

pharmaceutical businesses and were very early on implementing GLP. One of

them indicates that it would have been too expensive to go outside of the firm for

all GLP studies that had to be made.

The other four organizations are more or less contract research laboratories and it

was either demands from their customers or the opportunity to be able to perform

more studies that made them comply with GLP.

The reasons given for complying with GLP included:

“To be able to perform GLP compliant studies” (otherwise it would have been an

additional cost to make another laboratory do the tests for which GLP is

mandatory).

“It is necessary to be able to register drugs in the USA.”

“There is more work for a GLP validated laboratory.”

“We’re working as a contract laboratory and it was demanded by our customers.”

“It was demanded by the customers. They wanted to have a study performed that

required GLP status.”

“It was a way to make money.”

Of the six interviewees, one respondent for a GLP laboratory said it had chosen as

its business strategy to set up a GLP laboratory to make money, in other words its

motivation was purely business related. As the respondent said, “We sought GLP

status for purely business reasons: we wanted to make money.”

A reason given by three respondents was that it was a requirement from their

customers, in other words the customers for which they were supplying services

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demanded that the non-clinical studies were conducted in compliance with GLP

principles. These laboratories wanted to satisfy their customers’ needs.

4.2.4 Implementation and changes needed According to four of the companies, the key changes in the process of seeking

GLP status were, writing SOPs (Standard Operating Procedures) and agreeing

what to write in them. SOPs must be established for the personnel working

according to GLP. On the other hand, once this tedious and time-consuming task

had been completed, it proved a great help in training new recruits. The SOPs can

be used as a reference book above all for new employees, but also for others. All

of the activities in the laboratory will be documented in a way that makes all

routines easy to access. The SOPs also make the work more reproducible, since

every one is working according to the same manual.

It is also necessary to start up a partly new organization for the GLP. The QA and

its independent audit function is part of that, as some of the contact persons

mentioned. Since a GLP study has to follow GLP in every link of the chain, one

company had to start to buy the living material that it uses in the studies from a

different firm than before, one working according to GLP. Some were working in

a very GLP-like manner before and did not have to go through such a hard

process of change to implement GLP. “The adoption wasn’t that extensive, but

there were many details. Others had to start to work and document in a completely

new way. It took much more time than we had expected. It was a much bigger

work.”

4.2.5 Quality systems Table 2. Quality systems employed before and parallel with GLP

Quality system before GLP Quality System parallel with GLP Written routines - GMP, GCP GMP, GCP, six sigma, lean, ISO 9000 Not specified - EN 45001 ISO 17025

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Quality system before GLP Quality System parallel with GLP EN 17005 EN 17005 (Swedac) - -

Half of the companies were working according to other named quality systems

before they implemented GLP. All of these also have other systems parallel with

GLP today. ISO 9000 is a certification granted to companies that manufacture

goods. This is really parallel to GMP (Good Manufacturing Practice) and not

really to GLP. EN ISO 9001-2000 is a quality assessment scheme for laboratory

medicine.

4.2.6 What advantages did the laboratories gain from GLP? According to our research findings, adherence to GLP principles brings the

following advantages:

1. Increased business through GLP compliance:

• requirement of customers

• GLP status attracts more new customers

• GLP studies lead to other development studies

• GLP status an excellent reference

2. Operations become more efficient, systematic and better organized;

3. Easier induction of recruits;

4. Human capital retained as knowledge within the company when an

employee leaves.

Respondents’ answers

One respondent said, “It’s a quality label that proves the non-clinical studies were

conducted in adherence to GLP principles as agreed with the customer, so the

customer can then apply for the Stage 2 clinical trials required to get the medicine

approved by MPA.”

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Another said, “GLP is beneficial because it forces a company to work in a

structured and organized way. As our company already worked according to such

principles, there were no major changes for us.”

Another respondent noted, “Having GLP status enhances our chances of gaining

more GLP and other studies — more business. It is like an advertisement.”

Another respondent pointed out, “Adherence to GLP principles helps preserve

knowledge. If a researcher leaves the company without documenting everything

he had worked on, then a lot of knowledge would disappear with him. More

comprehensive and improved documentation leads to knowledge being retained in

the company. We cannot afford to lose knowledge! Other advantages of following

GLP are that every SOP must be written down and stored. For the recruits, it is

especially advantageous that all processes are clearly and straightforwardly set

down in writing, like an encyclopaedia that can be picked up and read through any

time necessary. There is then no need always to ask somebody.”

Another respondent said, “Operations are run more systematically and we can find

things because we have better documentation. We also review what we file and

store in the archives after the studies have been completed. That is part of

documentation, so it improves quality.”

Another respondent summarized the benefits from adhering to GLP principles as

“GLP is mandatory for preclinical safety documentation, and thus necessary to

adhere to.”

4.2.7 Has GLP improved quality, and if so, how? GLP does indeed improve quality. Our research revealed several ways:

• providing a competitive edge as an indicator of superior quality that

attracts more customers;

• routinely adopting GLP principles in other studies, even when not

required, increases overall quality not just in GLP studies;

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• improved, more detailed documentation and record keeping reduces the

risk of mistakes and faults;

• defining tasks and responsibilities, and ways of doing things, enhances

performance;

• regular inspections by authorities, QA and sponsors prevents any cheating

or falsification;

• increased safety of the studies due to stringent compliance with SOPs and

study master schedules;

• increased communication (everyone must follow SOPs) and dialogue

between Study Director, employees, sponsors and inspectors;

• improved quality through continuous improvement of the quality system.

4.2.8 Quality and continuous improvement Continuous quality and improvement work is an important part of the GLP system

according to several of the respondents:

“In our company GLP isn’t so much an instrument of control, but rather a

proactive method.”

“At first you have to set the quality base for the work according to the principles

of GLP and then continuously maintain that quality and work to improve quality.”

“You think about what you do and how you do certain things. It is an ongoing

process.”

One respondent said that in the end, the whole reason for the GLP system and also

for the work of the company is to deliver good quality to the customer.

Traceability has improved for many of the organizations. “When we had to follow

studies backwards in time, after the validation, it was possible to see exactly what

had happened to the sample.”

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One firm has become more systematic in the way the instrumentation is calibrated

and maintained. This must also be done in a controlled and regular manner. One

other respondent said, “GLP forces the company to work in a structured and

organized way.”

The documentation has become better, more extensive and more uniform. This

has made it possible to save knowledge more efficiently. “The company can’t

afford to lose knowledge.”

Answers from respondents also included the following comments:

“We all have the same understanding of the processes and do things in almost the

same way, so in this way operations have become more efficient. It is easier for us

to gain new assignments as we advertise that we have GLP status, and we get

other assignments, development assignments. It’s an advert.”

Written regulations, guidelines and SOPs are of little use unless they are followed.

Every employee needs to take responsibility for adhering to the principles, and

needs to follow SOPs and all guidelines in the smallest detail. One respondent

summarized this in her reply:

“We try to COMMUNICATE very often . . . and EVERYONE needs to be

INVOLVED in the LOOP.”

4.2.9 Have laboratories experienced any disadvantages from GLP registration? Four of the respondents talked about bureaucracy as a problem with GLP. One of

the respondents meant that it is absolutely essential to find a balance. The SOPs

and the increasing documentation will increase bureaucracy, but it must not take

too much time and the system must not become inert. With a good balance, it is

possible to get most of the benefits of GLP. Another meant that there is no way of

getting over the bureaucracy problem. It is a part of the system. Another important

aspect is connected to the very soul of science. “Science is to document. If you

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don’t save your results, the knowledge won’t stay and there won’t be any result of

the studies performed.” Sometimes the inspectors can be very meticulous:

“How do you know that the freezer stays at -14º C?”

“Because the thermometer says so.”

“How do you know that the thermometer displays the correct temperature?” and

so on.

GLP makes studies more expensive, since there has to be a QA. The composition

of the QA, states one of the respondents, is very important for how the GLP work

functions. One other thing that is important for how smoothly GLP

implementation works and how it is continued is the attitude of the management.

The specific points were raised by respondents can be summarized as follows:

• GLP increases costs for the customer;

• keeping SOPs updated and providing staff training to keep them up to date

increases costs;

• sometimes customers expect the laboratory to have even more

documentation;

• GLP-related problems can be created by inexperience or personality, or

management’s attitude (whether they see GLP as a necessary evil or an

opportunity to improve quality, and QA staff are crucial in this respect);

• increased bureaucracy;

• the specific “triangle problem” of CROs.

The “triangle problem” refers to a situation where a Study Director at a CRO who

is responsible for compliance with the Master Schedule of the GLP study is

“pressured” by the sponsor providing the money for the GLP study as to how the

study should be carried out. One respondent said, “So there are difficulties

sometimes in matching GLP with reality, but in our case it is the customer that

has the money who is the person that decides in the end, and not the Study

Director. This we have discussed with the Medical Products Agency’s inspector,

but it is GLP that says that the Study Director has the overall responsibility. In

some way we try to cope with the system. It is a little bit difficult sometimes.”

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The Study Director also has to meet the MPA inspector’s statutory requirements

for approval, so in some respects a sponsor or an inspector could have the last

word even though according to GLP Principles it is the Study Director who has

the responsibility for a GLP study.

4.2.10 What are the sanctions for non-compliance? When we asked respondents what the consequences for their laboratory would be

if they lost GLP status, loss of business (financial consequences or preventing

them from getting approval for their potential medicines) was the most common

answer.

According to Senior Expert Dr Ragnar Hede of the Medical Products Agency,

there are no legal sanctions for non-compliance, in other words failing to comply

with GLP does not entail prosecution or sanctions such as fines or imprisonment.

Even in a case of cheating, falsification or plagiarism, which is very unlikely with

GLP studies but unfortunately takes place in some studies at some universities,

the criminal definition of fraud in Swedish law does not cover this type of action.

Non-compliance can lead to loss of GLP status. An inspector can through an

inspection of a GLP laboratory find three types of deficiencies in compliance:

minor, major and critical. The GLP laboratory replies to MPA in writing stating

how any minor deficiencies have been eliminated. In the major and critical

deficiency cases, suspension and loss of GLP status may follow.

The question on the consequences for the company for non-compliance was

answered quite differently. New drugs could be stopped, customers could be lost,

and increased project costs could be a consequence because compliant CROs

would have to be hired for the GLP studies. One respondent answered that it

would also save money, since it is an extra cost to stay validated. For all (100%)

the CROs, loss of GLP status would lead to loss of business and customers, with

serious financial consequences.

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For the in-house pharmaceutical GLP laboratories, loss of GLP status would

prevent them from getting approval for their potential medicines, in other words

there would be financial consequences.

Extracts from some respondents answers:

“We would lose a lot of business and there would be financial consequences.”

“I think we would lose some of our customers, because it is a requirement for

them that they use laboratories that have GLP.”

“A consequence of non-compliance would be that potential medicines would be

blocked.”

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5 ANALYSIS AND CONCLUSIONS We set out to find out how Good Laboratory Practice functions for quality

improvement and what drivers there are for seeking GLP status.

5.1 Drivers for seeking GLP status We have assumed in our research that laboratories adopt GLP principles mainly

because of legal requirements. Our expectation of why laboratories/companies

seek GLP compliance turned out to be incorrect. We expected legislation to be the

major reason why laboratories/companies sought GLP validation, but the main

reason was that laboratories wanted to meet customers’ needs and requirements,

as well as authorities’ requirements.

Figure 3. We have in open interviews with GLP laboratories learned that the main driving force for GLP validation is demands from the customers. Figure 2 had to be corrected correspondingly, as above.

Legislation seems to be directly influencing the need for GLP validation only

when the company wants to register drugs in the USA. In this case the benefit is

also the one we had expected: marketing and selling of medicines. In companies

working as CROs, customers’ demands, often due to legislation and authorities’

demands, are the major driver for GLP validation. Compliance with GLP for these

companies is beneficial financially, since they can accomplish more assays for

more companies or do not have to hire GLP competence. The major benefit

according to respondents, though, is increased quality. Documentation (SOPs and

Legislation

GLP validation

Quality

Alternative quality systems

Financial benefits

Customer demands

Marketing/ selling of medicines

Authorities

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records) becomes more comprehensive, which improves reproducibility and

safety. Training and communication must be part of the system, and continuous

quality improvement is also embedded in the system.

5.2 Quality The first part of our goal was to find out how good laboratory practice functions

for quality improvement.

5.2.1 Two paradigms According to definitions of quality, customer satisfaction is the ultimate

benchmark of quality (Bergman et al, 1998:298). According to Deming’s

principle, top management has a key role in promoting quality.

Both paradigms have also been stated by some of our respondents. They are aware

that customers are their key stakeholders and aware of the importance of the

management thinking.

5.2.2 How does GLP improve quality?” According to the OECD’s Principles of Good Laboratory Practice revised in 1995

and 1996, the purpose of these Principles of Good Laboratory Practice is to

promote the development of quality test data. Adoption of GLP principles not

only improves the safety of non-clinical studies, it can also improve the overall

quality of operations. Meeting customers’ needs (they require studies conducted

in accordance with GLP) can gain more satisfied customers, and with more

satisfied customers, it is easier to gain more business.

The overall quality of operations can be improved by adopting GLP in other than

GLP studies. Management of the organization becomes more efficient as GLP

addresses key areas including personnel, processes, documentation and reporting.

SOPs and record keeping in detail help everyone involved in the studies and

operations to access information required. By complying with GLP principles,

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managers have assurance through the company’s internal quality assurance unit

that the studies conducted in their laboratories are performed to high standard. As

GLP principles specify standard operating procedures, very few procedures need

to be repeated.

As mentioned above: When a company decides to implement a quality system as

a part of its management system, this can enhance its performance in many ways.

Improved quality can affect profitability in many ways:

• More satisfied customers, who buy again

• Lower staff turnover and days of sick leave

• Improved competitive position in the market

• Shorter standstill times, delays

• Facilitates effective use of capital resources

• Less defects, unusable products and rework

• Improved productivity

Our respondent did not mention any positive effects of the points in grey

originating from the GLP system, but all other factors were said to be advantages

of the GLP system.

5.2.3 PDCA cycle and continuous improvement Quality improvement work is an ongoing process. The more systematically

quality improvement is embedded in operations, the greater the improvement in

operations. According to the answers we got, this is the case for GLP, which

makes it a little like kaizen, which is continuous quality improvement.

Continuous dialogue and communications with staff, QA, inspectors and sponsors

keeps everyone updated and in the loop of improvement, and any weaknesses or

uncertainties in the whole organization can be minimized or eliminated.

This extract from the mission statement of one of our respondents summarizes

GLP’s function in quality improvement very well:

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“We thrive on continuous IMPROVEMENT and QUALITY enhancements

through attention to detail, consistent feedback, state-of-the-art systems,

TRAINING and TEAMWORK.”

Figure 4. The PDCA cycle shows the loop for continuous improvement of a quality system.

1. Identify a need for improvement by reviewing, analysing and defining current status of activities

A P Act PlanC D Check Do

2. Implement improvement in for example - staff (training) - processes,safety - doc./reporting - IT, communic.

3. Monitor effects of action taken - results - staff/customer satisfaction - performance

4. Conclusions for creating - best practices - benchmarking Is there a need to do something better?

5.3 Validation process An interesting point about the process by which the laboratories obtained GLP

validation was that for the laboratories that sought validation immediately after

the regulatory framework became into force in Sweden in the 1990s, it took

between one and two years to gain GLP status, whereas for the laboratories that

sought GLP validation after 2000, it took only one year, and for the laboratory

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that gained GLP status most recently, it took only six months to be approved by

MPA as a GLP laboratory. This could be because the guidelines or policies for

GLP are so vague. What to do is outlined, but not at all how. It might be possible

to validate faster when there are concrete examples to use as models, as then one

does not have to build a totally new method from very theoretical documents. It

also might be because the process of validation was compulsory for a company in

the 1990s and optional before. This might influence the resources invested by the

company.

5.4 To comply or not to comply Despite the fact that GLP principles have existed for thirty years, opinions about

what GLP principles mean are somewhat divided. One company thought that it

was difficult to keep GLP and other studies separate, but stated that they had to be

kept separate because there were different requirements for non-GLP and GLP

studies. Another company stated that GLP had to be applied to all studies

conducted at the test site. That was a requirement of inspectors.

According to our other sources, this respondent was right. According to the GLP

Handbook, compliance with all aspects of GLP principles is required to gain the

status of a GLP laboratory; there is no possibility of complying with only a

selection of requirements and still claiming GLP compliance. A GLP laboratory

has to comply with all requirements at all times. If a GLP laboratory closes down,

a special procedure concerning the archives, test data and disposal of micro-

organic test material must be followed (GLP Handbook).

The only company that seems to work according to GLP principles only when

doing a GLP study for a customer (in other cases according to the company’s own

principles) seems to be more dissatisfied about the GLP system than the others. It

might be necessary that the whole organization totally complies with GLP to be

able to benefit from the system properly.

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5.5 Are our results representative? There is a risk that we have received too positive responses. Almost all our

respondents were involved in the process of validation and the decision to

comply, or are now working very actively with GLP high up in the hierarchy. It is

possible that we would have received less positive responses if we had asked

laboratory employees. However, we believe the favourable view of GLP of senior

management would be more representative because they can more easily see the

overall picture and the benefits of GLP to efficient operation of the whole

organization.

5.6 Sanctions In Sweden the threat of losing GLP status is enough sanction to make GLP

laboratories adhere to GLP principles. As stated in the results, faults in non-

clinical testing and studies can have serious financial consequences. Non-

compliance and sanctions in the USA have even more severe consequences. The

FDA in the USA provides information on two cases of severe defrauding of non-

clinical laboratory testing (in the USA falsification of drug and food studies is a

crime).

The FDA found out through its inspections that Industrial BioTest laboratories

falsified its reporting of GLP studies and its laboratory work, dead animals were

replaced with fresh animals without the replacement being recorded, and

documentation on substances were fabricated. Three officials of IBT were found

guilty of falsifying research and jailed for many years. Chemical companies that

had used IBT’s products had to spend millions of dollars repeating the tests and

studies to keep their products on the market. IBT no longer exists (P.A. Carlsson

et al, 1998). Biometric Testing’s two Vice Presidents pleaded guilty to conspiring

to falsify reports of animal tests on certain drug products to prove them harmless

although the tests had not been carried out. The company went bankrupt (P.A.

Carlsson et al, 1998). In Sweden such sanctions may be considered in the future,

but not yet.

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5.7 No such thing as a perfect system Even with rigorous GLP principles for non-clinical studies and monitoring of their

compliance, testing in humans can go wrong. Six male volunteers had to be

rushed into intensive care in London in March 2006 immediately after being

injected with a trial monoclonal antibody intended to treat chronic inflammatory

conditions and leukaemia by affecting the immune system. An interim report

found no evidence of human error, contamination or failure to follow GLP

protocols by the German company TeGenero that had conducted the non-clinical

studies and manufactured the drug. The intense reaction to the drug was

unprecedented and could not have been predicted (The Times, 4 April 2006).

We raised some problems in the Introduction that have risen in real life

concerning the safety of pharmaceutical products. In the case in February of

withdrawal of a medicine that caused liver damage as side effect, the company

had fully complied with GLP principles, as had TeGenero in the other case we

presented. Drug development is a complex and very long process. Statutory

requirements cannot alone guarantee total safety of non-clinical studies and

products developed based on the studies. Human input is crucial in quality

improvement. Even with state-of-the-art equipment and calibration, human error

or negligence may threaten a GLP study. All statutory requirements, regulations,

quality systems, guidelines and policies require that everyone involved in the

organization takes responsibility for quality and follows regulations in detail,

otherwise quality cannot be improved. It is important to note that adoption of the

regulatory framework is ineffective unless all personnel contribute and comply

with the regulatory framework. Motivation of laboratory personnel is crucial to

the success of adopting and complying with GLP principles. According to

Bergman et al (1998), it is vital that the whole organization is involved in

sustainable quality improvement work.

However, even following the regulations into the smallest detail cannot always

guarantee success with the GLP studies. All scientific studies include an element

of interpretation. Choosing the right test samples and species of animals, and

interpretation of data are crucial in developing science. Open and creative

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dialogue and communication should therefore be included in the quality

improvement work, in addition to compliance with all regulations. Regulations

restrict scientific creativeness in conducting studies, but when drafting the master

schedule of a GLP study and also in analysing the results, creativeness should be

allowed to ensure that every health and safety aspect has been covered and

researched. Unknown territory in, for example, monoclonal antibodies should be

researched even more profoundly than known territory in drug development.

Openness should be encouraged. New thoughts and ideas are created in situations

when one’s mind is open to new ideas.

5.8 Analogy of the GLP concept A key characteristic of GLP is that it is a total concept. It is not enough that a

laboratory meets the required standards. All its suppliers must too.

This is like how air safety affects an airline company.

The company’s pilot must exactly follow instructions from air traffic control

when flying his plane. He must be qualified to international standards to fly the

plane, and the airline company must meet the strictest international standards to

be allowed to use a European airport.

The airline company’s suppliers must also meet the strictest standards. The

manufacturer of its aircraft must meet very demanding standards for its aircraft to

be allowed to fly.

Nowadays, these are not just legal requirements, they are commercial necessities.

Airline companies are linking in alliances (Finnair flights to Britain also have a

British Airways flight number and British Airways flights to Finland also have a

Finnair flight number). Airlines will not link with a partner airline unless they are

sure the partner airline has the same highest standards of safety, otherwise its own

reputation will be damaged. Airlines that cannot find partners will lose business.

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Both also have full documentation of every single thing that happened, allowing

the whole sequence of events to be analysed: the GLP laboratory in its detailed

records of all procedures, the aircraft in its black box. Thankfully, they are very

rarely needed because airlines and GLP laboratories maintain such high standards

of quality.

5.9 Future of GLP We conclude our analysis with a prediction. This highlights our key finding that

the main reason for a company to comply with standards can change: the

company begins by complying with standards to meet legal requirements, but then

finds that strict compliance with standards improves overall efficiency, attracts

customers and increases business.

Testing laboratories and modem manufacturers have the option of complying with

certain standards (GLP for the laboratories, Windows for the modem

manufacturers). Nowadays, all modem manufacturers have realized the

advantages of 100% Windows compatibility so compliance is universal, but still

only some laboratories comply with GLP. We believe the similarities between the

cases suggests in time a much larger percentage of laboratories will seek GLP

status.

The situation of a laboratory as regards GLP is like the situation of a manufacturer

of a personal computer modem and its software. We had expected the motivation

for laboratories to seek GLP status was to satisfy the legal requirement that the

national testing authority had created to ensure the safety of the public who would

be using medicines tested by the laboratory. Similarly, years ago the only reason

for a modem to comply with certain standards was to be approved by the national

testing authority (the national telephone company) and so be permitted to connect

to the telephone network. Again, the national testing authority (the national

telephone company) had set its standards to protect the safety of the public,

because a faulty modem could be electrically to dangerous users of the telephone

network.

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However, there are now also other strong motivations for a modem manufacturer

to follow very strict design guidelines and manufacturing standards, and to

document them thoroughly. Customers need total confidence that a modem will

automatically work with their computer. Unless they can see proof of this on the

package, they will buy another brand, and the company’s business will collapse.

Nowadays, this means confirmation by Microsoft or similar that the modem and

software have been tested to be Windows compatible. As with GLP laboratories,

there must be verification of compliance at both government authority and lower

inspection levels.

Also, compliance must be total. Complying with 99% of GLP regulations is

useless as the laboratory will then lose GLP status. Similarly, a modem that is

99% Windows compatible will not work properly and the computer may crash. In

both cases maintaining a high reputation for quality and reliability is essential. A

laboratory losing GLP status would go out of business; so would a modem

manufacturer if computer magazines reported problems with its latest modems.

Finally, comprehensive documentation is not only essential in both cases, it is a

real business advantage. Documenting compliance with GLP practices or

Windows standards is essential in both cases for approval. For GLP laboratories it

is also needed to be able to repeat the testing exactly; for a modem manufacturer it

is essential for smoothly upgrading the modem and software to the next version of

Windows. But in both cases there is also another key benefit: detailed

documentation makes it much easier to preserve the knowledge of staff who have

left and to bring new employees up to speed quickly.

In both cases companies have found that strict compliance with standards

improves efficiency so much that this more than compensates for the extra burden

of complying with the standards. This is a key motivator to strive to maintain the

standards.

However, there is one crucial difference between these two cases. Nowadays,

every modem manufacturer must be able to display proof on the box that the

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modem is 100% Windows compatible. Nobody will buy a modem that cannot

claim that. But GLP status is still optional. Some laboratories want GLP status,

some do not think they need it. In view of the great similarities between these two

cases, we think this will be only a difference of timing. For commercial reasons,

all modem manufacturers already comply with Windows standards, but only some

laboratories comply with GLP. We think as laboratories realize the advantages of

GLP, more and more of them will adopt GLP, till GLP status becomes essential

for commercial reasons in some cases.

5.10 Indirect benefits of GLP In our thesis we have provided direct answers to our question “How does Good

Laboratory Practice improve quality” by explaining the direct benefits to quality

of GLP. However, it is also clear that GLP has very important indirect benefits to

quality, too. As companies and laboratories see that the strict following and

detailed recording of procedures required by GLP has economic benefits through

improving overall efficiency, they become even more motivated to enforce the

highest standards of quality. This is positive feedback that further improves

quality, benefiting the laboratory, its customers and ultimately the public, who

will be using the pharmaceutical products being tested. GLP improves quality,

and the improved quality benefits the laboratory’s owners, employees, customers

and the public.

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6 REFERENCES

6.1 Books Andersen, Ib, Den uppenbara verkligheten - Val av samhällsvetenskaplig metod,

1998

Anthony, Robert, Govindarajan, Vijay, Management Control Systems, Mcgraw-

Hill Education, 2003

Bergman, Bo och Klevsjö, Bengt Kvalitet från behov till användning.

Studentlitteratur, 1998

Bodin, Sven, Sahlen, Tom, Sjögren, Carina, Dokumenthantering i företag och

organisationer - en kvalitetsfråga, Folkrörelsernas Arkivförbund, Stockholm, 2000

Carlsson, P.A., Dent, N. J. Good Laboratory and Clinical Practices, Butterworth –

Heineman Ltd, Oxford, 1998

Rosengren , Karl Erik, Arvidsson, Peter, Sociologisk metodik, 2002

Yin, Robert K., Case study research- Designs and Methods, 3rd edition, 2003

6.2 Downloadable from authorities’ and organizations’ websites Food and Drug Administration

FDA, 21 CFR58.35

Eudralex, Volume 4, Medicinal Products for Human and Veterinary Use. Good

Manufacturing Practices

EMEA: European Medicines Agency (Europeiska läkemedelsverket)

Lääketietokeskus electronic and printed publications, Helsingfors, Finland, 2005

6.2.1 Läkemedelsverkets författningssamling GMP

LVFS 2001:1

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LVFS 2001:5

LVFS 2001:8

LVFS 2003:11

LVFS 2004:6

LVFS 2004:11

GLP

LVFS 1999:8

6.3 Manuals from organizations ISO Guide 25, ISO 9000 GLP for analytical laboratories, Agilent Technologies

Handbook- Good Laboratory Practice, UNDP/World Bank/WHO (not dated)

6.4 Articles Immel, Barbara K, A Brief History of the GMPs for Pharmaceuticals,

Pharmaceutic Technology, 2001

6.5 Newspapers The Times, 4 April 2006

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7 APPENDIX 1

INTERVIEW QUESTIONS

Adoption of GLP principles - How long has GLP been adopted in your laboratory? - Why did your laboratory apply for GLP registration? - How long did the validation process take from the decision to adopt

GLP principles and seek GLP status to the approval by Medical Products Agency?

- What quality processes or systems did your laboratory have before seeking validation according to GLP Principles?

- In your view, what were the key changes required in the laboratory operations in order to gain approval by Medical Products Agency?

How the GLP function today? - What is your overall experience of conforming to Good Laboratory

Practice Principles? - How has your laboratory directly or indirectly benefited from GLP

status? - Has GLP improved quality? How? - Was it easy or difficult to implement overall? - Could GLP principles be utilized more effectively to benefit the

company? How? - Have you experienced any disadvantages from GLP registration? - How could these disadvantages be overcome?

Overall quality improvement - Any other quality systems such as ISO or GMP adopted in parallel?

Sanctions - What would the consequences for the company be of non-compliance

and a loss of GLP status?