Untrue Supplier-Audit Reports: The Danger of Ethnocentric GMP-Auditing
If You are in any QA / QU role and are responsible for audits and audit reports in the GxP-context, I encourage You to take time and read this, it will be worth Your while. And if You are a QP (like I have been), this is likely to help You.
Where We Pick Up the Audit Topic
Manufacturers of pharmaceutical products and marketing authorization holders are required to ensure that audits at critical suppliers and service providers are done in a regular basis: active substance suppliers, suppliers of primary and printed packaging materials, and many others. This is basic, everyone knows this. However…
The supply chain is typically globalized and suppliers and manufacturers of materials are located all over the globe. When audits are carried out at suppliers located in a different culture, auditors always bring in their understanding of GMP and quality expectations-and here is the news: these are projected by the auditors on the auditees in culturally driven way and interpretation.
Auditors are Biased and Lack Understanding
Often auditors are trained to ask clear questions, closed questions, sometimes intentionally open questions, hypothetical questions, and often “show me” questions. Auditors expect to hear clear cut answers, yes or no, black or white, clarity – ambiguity is not typically acceptable as an answer.
But this way of auditing and listening in audits is actually called #ethnocentrism and it leads to very inaccurate audit reports. Such inaccuracy is very dangerous for supply chain and product quality asusrance! And this is a danger this industry cannot affort. We don´t produce umbrellas, but medication, we do this for patients, people who have serious needs..
Auditors assume to be heard and understood like they would be in their own birth cultural context, and even in their own company. It is an expectation which auditors bring with them due to their cultural bias in how communication should work. And so they filter what they see and hear in an audit through what they believe everyone uses to communicate.
Another assumption is that because a standard like GMP is laid down in writing, everyone sort of will understand this the same way, or at least to a contained degree of variability. Another ehtnocentric assumption: keeping in with the text of GMP requirements is what drives quality. As long as everyone else shares this – no problem. But the issue is: not everyone does! As a matter of fact, most cultures in this world do not share the mindset that underlies GMP.
The underlying problem is that GMP and similar quality standards have spawned in a Western cultural framework. This framework is not the majority reality in the world, it is a minority view no matter how important we think we are. Auditors do in almost all cases not know this, and they do not understand how big the impact of this is on what is heard and understood in audits, and what documents and records really mean.
It is needless to say that many drug manufacturing companies care very little about this aspect of audits and audit reports. Since the auditee is perceived as a supplier and only as that, the auditors feel – just like their company – that treating audit situations as an exchange of two business partners is not necessary. Another proof of ethnocentrism.
Real Consequences – Supply Contraction and Patient Risk
Especially in Asia (supplier in China, India, Japan to name a few) this will ultimately lead to a contraction of the supply range, meaning that the supply to European and Western-based companies will be a decreasing market priority to these Asian suppliers. Suppliers in Asia are fine with the Asian market alone, we must not forget that. The West is a very small part of the global village community. If we don´t take this seriously then it is our own fault.
The much bigger issue for the now is though that audit reports most often misrepresent what is going on at the supplier. Miscommunication happens so often without the auditor(s) even noticing it. And it ends up in the audit report, either as a conclusion that a particular audit topic was fine at the supplier (though it wasn´t) or that observations and deficiencies are noted that are simply not true.
The issues that come with ethnocentric auditing, which happens in almost every cross-cultural audit are significant and relevant! And they are essentially unaddressed. Auditors should not be sent into such an audit setting without a proper understandig of this.
Now What?
We seek to train our consultants and audit specialists at EI and our client auditors regarding this issue. And although no person can be truly multicultural, knowing the pitfalls makes a world of difference for the quality that is delivered.
If You are an auditor You cannot guess things in another culture, even in a business or highly regulated setting. Someone needs to show You, teach You, make You understand, and apply it. If not then audit reports will be sub-standard, inaccurate at best. And we will convince ourselves erroneously that we did a good job, and we will deceive ourselves to think that we were the ones who taught the auditee something new, although it is us who had a chance to learn and we did not take it.
Do You want to be an auditor who after 30 or 40 years of work realizes “goodness I got this wrong all my life”? Patient health and safety depend more on accurate auditing than we might think. We owe it to those who depend on medication to do our vey best.
#auditsandinspections #thegoodauditor #interculturalcommunication #GMP #business #activesubstances #api #excipients #supplierqualification #supplychainmanagement
If You like to know more about this, feel free to contact d.gross@expertsinstitut.de or visit www.expertsinstitut.de.
Vita
- COO Experts Institut
- Senior Project Consultant
- Apotheker
- Langjährige internationale Projekttätigkeit in Europa, Nordamerika, Asien, Russland
- Sachkundige Person (D – AMG, AMWHV, CH – HMG, AMBV)
- Breite Compliance Expertise im Commercial (c)GMP- und Development GMP-Bereich (IMP-GMP)
- Langjähriger Third-Party GMP-Auditor (GMP- und Non-GMP)
- GMP/GDP-Trainer seit 2010
- Quality Culture Mediator
- Trained in cross-cultural aspects of communication, contextualization, and cultural anthropology as part of an MA.MIn and DIcs enrollment at Grace College&TS, US.
