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You have an OOS test result!
Written by: Dr. Wolfgang Pitsch What is your first reaction in the Quality department? Okay… let’s be honest: the first thought is often, “Oh no. This is going to be messy.” But after that initial gut punch, what happens next defines your quality culture. Step 1: Pause and Think The instinct to “fix the number” is strong. Many teams jump straight to retesting because it feels like action. But here’s the question: If the original result had been within specification, would you have rerun the test? No. So why now? Step 2: Understand the Regulatory Expectation Both FDA Guidance for Industry and EudraLex Volume 4, Chapter 6 are clear: The expected next step is not to retest blindly. It is to investigate! A second test without a hypothesis gives you no new knowledge. If the retest passes, it might just reflect natural variation. If you average the two results into compliance, you still don’t know what went wrong with your product or your process. That’s not science—that’s gambling. Step 3:
17 October 2025
What GMP Really Requires – From Compliance to Performance
Marlous van der Hooft In radiopharma, GMP compliance is the baseline. But what truly differentiates high-performing organizations isn’t just adherence to regulations—it’s the ability to embed trust into every layer of the GMP system. At Qualificiency Consulting, we believe GMP should be more than a checklist. It should be a culture of reliability, where systems support processes, and processes empower people. Why Trust Matters in GMP Radiopharmaceuticals operate under extreme constraints: short half-lives, complex logistics, and high regulatory scrutiny. In this environment, trust isn’t optional—it’s operational. Trust enables: Faster decision-making in time-critical production Cross-functional alignment between QA, production, and planning Resilience when deviations or unexpected events occur But trust doesn’t happen by accident. It must be designed into the system. Three Ways We Help Firms Build Trust into GMP Systems 1. Transparency Protocols We help teams implement structured trans
20 August 2025
Reddeloos, Redeloos, Radeloos: A Historical Lens on Quality Culture Challenge
Marlous van der Hooft In 1672, the Netherlands experienced het Rampjaar — the Year of Disaster. The country was attacked from all sides, leadership collapsed, and the people were described as: “Reddeloos, redeloos en radeloos.” Without salvation, without reason, without counsel. This powerful triad captures the essence of systemic breakdown — and it offers a striking metaphor for what can happen in GMP organizations when quality culture is weak or reactive. At Qualificiency Consulting, we often encounter companies where compliance is technically in place, but the culture behind it is fragile. Let’s explore how these three words reflect common pitfalls in quality culture: Reddeloos – Without Salvation When quality systems are overly complex, reactive, or disconnected from daily operations, teams feel overwhelmed. They’re stuck in a loop of deviations, CAPAs, and audits — with no clear path forward. This is what happens when compliance becomes a burden rather than a support structure. Ou
18 August 2025
From Power to Performance: Building Trust in GMP Teams
Marlous van der Hooft In my previous articles, I explored the Montesquieu Triangle of Powers—a lens through which we can understand the dynamics of influence and control in GMP environments. I spoke about the importance of transparency and the factors increasing risk for fraud. Today, I want to shift the focus from power to performance, and from control to collaboration. Let’s talk about trust—the foundation of high-performing teams—and how Patrick Lencioni’s Five Dysfunctions of a Team model can be applied to GMP organizations striving for excellence. The GMP Triangle of Trust In GMP environments, compliance is non-negotiable. But compliance alone doesn’t drive results. What does? Trust, transparency, and teamwork. Lencioni’s model outlines five key behaviors that build functional teams: Trust – Vulnerability-based trust, where team members feel safe to admit mistakes or ask for help. Conflict – Healthy, productive conflict around ideas, not personalities. Commitment – Clarity and buy
29 July 2025
Why Culture Matters in GMP
Marlous van der Hooft The Hidden Cost of Poor Culture in Pharma In highly regulated environments like pharmaceuticals, we often assume that compliance is enough. But what if the real risk isn’t just in the SOPs we write—but in the culture we tolerate? Let’s talk about the hidden costs of poor culture in GMP environments: Compliance Failures Even with robust systems, a disengaged or fearful workforce can lead to data integrity issues, deviations, and audit findings. Culture is the invisible hand behind every checklist. And the consequences are real: These issues don’t just stay on paper. They lead to higher operational costs, delays in batch release, regulatory penalties, and even unsafe working conditions. Most critically, they can compromise patient safety and erode trust. Poor culture directly impacts “hard” KPIs like Right First Time (RFT), batch rejection rates, CAPA cycle times, and employee turnover. Fraud and Ethical Drift Donald Cressey’s Fraud Triangle reminds us: when pressur
29 July 2025
Why Good People Sometimes Do the Wrong Thing: The Fraud Triangle in GMP
Marlous van der Hooft In the last weeks, I’ve written several articles on the importance of transparency and trust in GMP environments. These values are not just regulatory checkboxes—they are the foundation of a culture where quality and integrity thrive. But even in the most well-intentioned environments, things can go wrong. People don’t come to work intending to do harm. They come to do what’s right. So why do some still end up doing the wrong thing? Let’s talk about the Fraud Triangle—a behavioral model that helps us understand how and why this happens. 🔺 The Fraud Triangle: A Lens on Human Behavior The Fraud Triangle suggests that fraud or misconduct is more likely when three elements converge: Opportunity – A perceived chance to act without being caught. Weak controls, lack of oversight, or blind spots in digital systems can create this. Pressure – A personal or professional incentive to act unethically. Think financial stress, unrealistic KPIs, or fear of failure. Rationalizat
29 July 2025
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