Doctors can make the worst patients, and Quality Professionals can
focus so closely on suppliers’ quality that they miss opportunities for
improvement in their own programs. By applying basic quality
principles in the evaluation of suppliers, improved efficiency and
effectiveness will have an impact well beyond the supplier quality
function.
The number of FDA warning letters attributed to inadequate supplier
evaluations has remained high over 2009. In 2008, 45% of Medical
Device Manufacturers that received warning letters concerning supplier
practices were shown to be inadequate in meeting their supplier
evaluation commitments per 21 CFR 820.50. So far in 2009, this figure
is still bordering 40%. While many factors influence such a trend, one
factor that can be easily and effectively controlled is the supplier
audit process. Although it may seem painfully obvious, taking a quality
approach to auditing your suppliers can often be overlooked. There are
numerous considerations that need to be properly managed beyond a basic
procedure, checklist and spreadsheet of vendors.
The following quality fundamentals should be incorporated in your
supplier audit program to maximize the effectiveness of your audit team:
- Define your process.
Supplier audits are the result of many events involving multiple
stakeholders inside and outside your organization. The act of having a
quality auditor on-site at a supplier is but the tip of the iceberg,
with a significant amount of supporting work required before and
after. The steps involved in audit preparation can include audit
justification/prioritization, supplier liaison, legal approval,
supplier history review, auditor coordination, and pre-audit
briefings. Following the audit there is immediate action (if
required), report preparation, content review and corrective action
management through to closure. By mapping this process, steps and
roles may be optimized (e.g. reassigning administrative tasks from
auditors), and supplier audit as a risk management tool can be made
more effective (e.g. defining broader internal action based on poor
supplier audit results).
- Add checkpoints along the way.
Because the audit process is time-sensitive, back-tracking after an
audit has been performed is time-consuming and not always effective –
ask any busy auditor about a supplier audit two weeks ago. Even
changes made prior to an audit can have a major impact on the
availability and efficiency of your audit team. Therefore, the
addition of checkpoints in the audit process will allow you to zero-in
on all of the pre-requisites of a successful audit. Basic questions
such as “Has another division of our company already performed an audit
we can use?” and “Are there any areas [such as special processes] that
require added attention?” will help with auditor coordination, and
produce audits with more ’teeth’.
- Put the audit process in context.
It is important look at the audit process flow in the context of
overall supplier control – i.e. the ‘big picture’. Many companies have
developed an overall risk management strategy which both impacts, and
will be impacted by, the supplier audit process. For example, a risk
management strategy will help determine the higher-priority supplier
audits. Likewise, results of the audit process will have an impact
outside the audit process – like the action required from a major
supplier finding, which could result in a change in risk status, a stop
in production, or a product recall.
- Perform a FMEA on the process.
With a well-defined supplier audit process, a Failure Mode and Effects
Analysis (FMEA) is an excellent way to prepare for exceptions that
invariably occur. This disciplined approach to identifying and
preventing possible failures can save an enormous amount of time spent
in escalation, back-tracking and rework. It can address questions like
“What happens if a supplier refuses an audit?”, “What happens if
inadequate evidence is obtained during the audit?” and “What happens if
a supplier is unresponsive?” In performing a FMEA, you will map the
entire process, showing every step, listing every critical feature.
You will determine possible failure modes for each critical feature –
and their effects (like having to revisit a supplier). Then you will
rate the severity, occurrence and detection of the failure, and take
appropriate preventative action.
- Add measurements and targets.
Another quality fundamental is the use of data to improve decisions and
identify sources of variation. There are many aspects of an audit
program that may be monitored for control and improvement. These
include team optimization (e.g. no ‘dead time’, grouping audits for
reduced travel), on-target audit dates, audit report turnaround, and
corrective action closure. Note that the tracking of such parameters
should allow for exceptions, such as an unusually large or complex
supplier requiring more on-site audit time.
- Don’t inspect quality in.
If supplier audits are viewed in isolation, there can be a tendency to
focus on the finished product, as opposed to the process that created
it. If an audit report is incomplete or poorly written, there is a
natural tendency to opt for greater screening, or ‘inspection’. By
looking further ‘upstream’ in the process, you are more likely to
determine the source of variation, e.g. inadequate auditor preparation,
lack of supplier guidance. This may lead to the addition of a
checkpoint (see above) that will save back-tracking, rework, and
reoccurrence.
- Think CAPA. For an audit
team, the urgency of the next audit creates pressure to quickly fix any
problems that arise and move on. This approach covers the need for
‘containment’, but does not address the broader aspects of Corrective
Action / Preventative Action (CAPA). With a well-defined process and
suitable measurements in place, it becomes easier to identify and
address the real problem source (not just the symptom). It also
provides opportunities to spot potential problems and take action to
prevent them from happening. The process owner must ‘think CAPA’ when
addressing problems and evaluating the process for effectiveness.
By applying all of the fundamentals above, your supplier audit process
will be well-placed to meet the increasing demands of the supplier
quality function. Like other parts of your quality organization, they
should be subject to regular review, and performance against goals. A
more effective process will deliver better performance of your audit
team, better visibility of supply chain risks to your entire operation,
and improved value from the supplier quality function.
About the author
Gerard Pearce is executive vice
president of SQA Services Inc., a Rolling Hills, California-based
company specializing in global supplier quality management. Gerard has
more than 20 years’ experience in combining the fields of quality,
supplier management and technology. He published The Purchasing
Revolution in 1999 and served on the committee of the World Congress of
the International Federation of Purchasing and Supply Management. He is
heavily involved in shaping and implementing the global outsourcing
quality strategy for SQA’s Fortune 500 clients in a variety of
industries, including medical device, pharmaceutical, aerospace and
high-tech. He can be reached at gpearce@sqaservices.com or through
www.sqaservices.com.