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I posted this on the VEEV board, and thought you might be interested too. Here’s my thoughts on why I think Veeva Systems has a great opportunity supporting QA Systems in the consumer goods space. In fact, I think that opportunity may dwarf that of drug development space. For the record, I have over 30 years of R&D and process development experience mostly with Fortune 500 consumer goods companies.
I think that a lot of QA systems actually have their roots with a drug failure. That failure was like the Dr. Seuss book “Because a Little Bug went Kachoo”. In that story, a little bug’s sneeze resulted in mayhem. In the QA story, a failure by a company called G.D. Searle & Co during the registration of an antibiotic caused a regulatory landslide.
Searle’s drug, Flagyl, was an antibiotic that was being tested for long-term use. An external researcher, not associated with Searle, submitted an article to the National Cancer Institute that showed animal studies would reasonably show that Flagyl is a carcinogen. However, in a separate study by Searle that went to the FDA at about the same time reported no such problem. The FDA confirmed the external researcher’s finding with a study of their own.
During July of 1975, the FDA launched the largest raid in their history to that date. I have been told that over 100 FDA investigators descended on Searle in one day. They discovered animals with tumors removed, records that had been falsified, and technicians forced to restate their results fraudulently. Searle’s leadership defended Searle by claiming that they had no idea what their rogue scientists and technicians were up too. That catalyzed the FDA to develop Good Laboratory Practices or GLP in 1987 to combat that fraud in drug development. Soon GLP was also adopted by the EPA for products like disinfectants or other pesticides. Later a variation was adopted for “Good Manufacturing Practices” or GMP. Later still, major quality programs like ISO 9000 adopted aspects of GLP too.
Basic, tenants of GLP and other quality programs are:
1.Org charts identifying clear accountabilities must be up to date for each facility.
2.People must show their technical proficiency for their roles in an organization through training records.
3.Standard Operating Procedures must be developed for common activities.
4.Regular external quality audits for GLP studies, quality labs, and manufacturing processes should be performed by external personnel (e.g. FDA, EPA, or third party auditors such as ISO)
5.Quality documents need to be controlled so they can only be changed by the test method or SOP developer together with the quality manager.
6.Records of measurements must be are stored for a specified period of time.
7.Maintenance records need to be available for varying periods of time.
8.Rejected product and raw materials need to be segregated and kept from production.
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Raw materials need to be traceable to their source.
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Adverse events from product use must be recorded and reported to the correct regulatory agency.
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A list of hazards and mitigation plans need to be recorded.
12.Finished product shipment records must be kept so that product recalls can be implanted if necessary.
There are significant variations between QA programs for automobiles, toothpaste, and laundry bleach, but most QA systems have elements from the list above. In any case, it is a mountain of paperwork to keep track of. It’s ironic that QA mostly flowed from drugs to consumer products, and Veeva Systems is flowing record management from drugs to consumer products. Veeva landed a “large consumer goods producer” last quarter. Doesn’t surprise me in the least. I expect many more to come.
Best,
bulwnkl
Long VEEV and expecting to stay that way for a long, long time.