lyobovnik
Manager QA at small Med. Device Mfr.
Background:
I am a QA Manager at a small business (~20 employees) that is a contract manufacturer for a very large MDM. I have completed no degree higher than a high school diploma, did not go to school for this, started at the lowest position here and basically fought to carve my path here every step of the way. I'm a big supporter of higher education, it just wasn't an opportunity for me.
Anyway... Occasionally I develop a view that disagrees with my VP.
I'm not interested in alienating the one who does my performance appraisal, of course(!), but he has also consistently told me never to let him "screw up." I committed to doing my best there.
So, of course, I try to exercise discernment and not voice every piddly thing... but when I don't think he's right on something major, I believe it's due diligence to find a way to communicate it. I'd hate to see anything bad happen that I could have prevented.
Today's Context:
Without getting into causes, let me say that lately we are very short-staffed in Production and have a ridiculous turnover rate. So much so, that to stuff something in this bleeding hole, Top Management reallocated half of my Quality technicians there "indefinitely" to work as Production operators instead.
Now I am even being told that I and rest of the audit team should also go out to Production and work there as well. As much as possible.
(I'm starving... oh wait... I can eat my eyeballs!)
Feeding auditors to this fire confuses me the most, and nevermind the "how will any QA work get done"... Rather - how can it even work per 21CFR820.22?
I don't see how we aren't each "directly responsible" for our actions, and from that I can't see how someone using a process is not directly responsible for the same. On those grounds I can't think that any process users can count as "individuals who do not have direct responsibility for the matters being audited" when the process is what's audited. E.g., it would not occur to me to have a "Production operator" audit Product Realization. I suggested to my VP that any auditor so assigned should lose qualification for auditing Product Realization, but I was shot down. Apparently, "as long as the auditor avoids using in audits any records that show their involvement, they are not 'auditing their own work' and therefore there is no significant conflict of interest." I trust my VP means well and I'm sure it's not intentional, but the FDA may not agree. I'm concerned they could see it as shifting samples to hide a nonconformance. I do not think shifting samples until you get one that doesn't show the issue works in Inspection, I don't see how it works in auditing, and I still believe it is no substitute for an independent audit.
Question:
Am I missing or misunderstanding anything significant with the regulation?
I am a QA Manager at a small business (~20 employees) that is a contract manufacturer for a very large MDM. I have completed no degree higher than a high school diploma, did not go to school for this, started at the lowest position here and basically fought to carve my path here every step of the way. I'm a big supporter of higher education, it just wasn't an opportunity for me.
Anyway... Occasionally I develop a view that disagrees with my VP.
I'm not interested in alienating the one who does my performance appraisal, of course(!), but he has also consistently told me never to let him "screw up." I committed to doing my best there.
So, of course, I try to exercise discernment and not voice every piddly thing... but when I don't think he's right on something major, I believe it's due diligence to find a way to communicate it. I'd hate to see anything bad happen that I could have prevented.
Today's Context:
Without getting into causes, let me say that lately we are very short-staffed in Production and have a ridiculous turnover rate. So much so, that to stuff something in this bleeding hole, Top Management reallocated half of my Quality technicians there "indefinitely" to work as Production operators instead.
Now I am even being told that I and rest of the audit team should also go out to Production and work there as well. As much as possible.
(I'm starving... oh wait... I can eat my eyeballs!)
Feeding auditors to this fire confuses me the most, and nevermind the "how will any QA work get done"... Rather - how can it even work per 21CFR820.22?
I don't see how we aren't each "directly responsible" for our actions, and from that I can't see how someone using a process is not directly responsible for the same. On those grounds I can't think that any process users can count as "individuals who do not have direct responsibility for the matters being audited" when the process is what's audited. E.g., it would not occur to me to have a "Production operator" audit Product Realization. I suggested to my VP that any auditor so assigned should lose qualification for auditing Product Realization, but I was shot down. Apparently, "as long as the auditor avoids using in audits any records that show their involvement, they are not 'auditing their own work' and therefore there is no significant conflict of interest." I trust my VP means well and I'm sure it's not intentional, but the FDA may not agree. I'm concerned they could see it as shifting samples to hide a nonconformance. I do not think shifting samples until you get one that doesn't show the issue works in Inspection, I don't see how it works in auditing, and I still believe it is no substitute for an independent audit.
Question:
Am I missing or misunderstanding anything significant with the regulation?
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