Regulatory challenges

Industry 4.0 in a GxP environment

industry 4.0
  • Blog
  • 5 minute read
  • March 04, 2024

Digitisation and artificial intelligence are developing swiftly and spreading everywhere across our daily lives. The concept of industry 4.0 is based on the application of these technologies to the manufacturing environment. It started with low-risk digitisation mechanisms, and has scaled up rapidly: in just a couple of years, by leveraging the power of AI, industry 4.0 has developed into integrated, controlled, autonomous, and self-organising production systems. 

 

While we see the applications of AI and Generative AI being developed across industries, the pharmaceutical industry seems to be lagging behind in the digitisation race. The main reason for this gap is to be found in the fact this is a highly regulated environment, which is of course to ensure patient safety. Regulators are aware of this delayed progress and working on developing a framework that would enable the optimisation of pharmaceutical manufacturing processes using Artificial Intelligence, Machine Learning, Process Models and other applications without impacting the quality of the products and therefore patient safety. 

 

Both the FDA and the EMA have put together work groups to address and discuss the regulatory issues faced by digital technologies when applied to manufacturing pharmaceutical products. These work groups comprise representatives from the regulatory sector, academia and the pharma industry to get an all-encompassing view on potential digital developments, the issues caused by a lack of framework, and to propose solutions.

 

PwC Belgium participated in the EMA work group on the subject. We shared our experiences and looked into solutions to better support pharmaceutical companies in their digitisation journey. In this blogpost, we share three challenges that should be taken into account by regulators and companies when defining a digitisation strategy in a GxP environment.

 

Digital Data Storage

Data storage is an integral aspect of implementing digital solutions such as AI. The system requires a database to access stored data, and this database should be large enough to ensure that the AI solution works optimally and takes all factors into account to propose, predict and perform its activities. On top of the storage itself, there are two other important factors: ensuring that existing data is captured, and that data is governed via lifecycle management.

An AI system cannot work without data, therefore historical data needs to be stored and made easily available. Depending on the process and its optimisation, the data can be already digitised, which simplifies the task. Whatever the case, it is imperative that the data be accurate and consistent. To ensure this, an exercise in data collecting, assessment and sorting should be conducted before it is fed into the digital tool.

Once the system is running, the data grows exponentially and requires effective governance practices to ensure its quality, security, and compliance. This involves assigning responsibility for data management to specific individuals or teams within the organisation. In many companies, this translates into a growth of the IT compliance department, which creates the need for a clear operating model enabling better interactions with other departments, including the quality team as they are responsible for controlling the compliance of systems and the impact on products and patients.

Personnel

As mentioned, digital systems require proper management and dedicated personnel with sufficient knowledge of these systems.

One of the key concepts that should be discussed here is the Human-in-the-loop (HIL). This concept refers to a process where human intelligence and machine intelligence work together; a combination leading to more accurate, reliable and efficient outcomes. The human aspect may relate to the decision-making process, by providing input and oversight. In the pharmaceutical industry, where the outcome of critical process steps must be tested and controlled, the HIL concept ensures that human expertise is incorporated in quality control and decision-making processes, allowing accountability and error detection.

Personnel is an important part of GxP, nevertheless there is no requirement yet for specific roles having a certain level of knowledge and understanding of digital technologies.

Terminology

Digital solutions are not predefined, and there is no standard way of working with them. Depending on the system, steps, data, technology and the team, there are different ways to use digitisation in a process. This aspect of industry 4.0 allows a lot of flexibility in searching for the best solution. On the other hand, it implies that there is no standardised guidance available with clear terminology and definitions. Discussions on AI often resort to self-defined terminologies within companies. A common standard to bridge the gap between IT and GxP terminologies and align them with regulators would aid the discussion going forward.


Acknowledging these challenges and fully taking them into consideration are the first steps in the digitisation journey. In the second phase, the opportunities for improvement need to be assessed to define which (Gen) AI solutions might be best implemented to optimise the efficiency and/or quality of processes and/or products. In a quality environment, these solutions might be related to documentation management, predictive quality (e.g. deviations), authorization management, etc.

At PwC, we have put together a digital quality framework to assess a company’s digital maturity, define a digital strategy, select potential (Gen) AI tools and support their implementation.

Contact us

Jan Debaere

Partner, Health Industries Lead, PwC Belgium

+32 473 92 46 11

Email

Morgane Franck

Manager, Quality Expert, Brussels, PwC Belgium

+32 473 41 23 79

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