All biopharmaceutical companies espouse a belief in scientific, risk-based approaches. However, with respect to deviation management systems (DMSs), the industry is falling short of that promise. By and large, companies still use a small-molecule pharmaceutical compliance model that dates back to the 1980s, based on the strategy that all deviations are created equal and require 30-day closure. Most bioprocessors still hold to a default 30-day rule, even though there is no specific regulatory requirement for that time frame. Major or critical investigations often take 50-60 days or longer, and simpler events can be closed much faster. The 30-day rule is not risk-based, and it can drive the wrong behaviors by promoting a check-the-box mindset and creating pressure to close an investigation without finding the true systemic root cause.
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