A featured contribution from Leadership Perspectives, a curated forum for chemical industry leaders nominated by our subscribers and vetted by the Chemical Industry Review Editorial Board.

Alora Pharmaceuticals

Jeff Brenneman, VP Global Operations Quality

How Pharmaceutical Leaders Build Resilient Operations Beyond Cgmp Compliance

Jeff Brenneman

Jeff Brenneman

Pharmaceutical Quality Authority

Jeff Brenneman is an executive leader in quality and operations with almost three decades of experience in pharmaceutical manufacturing. He leads enterprise quality strategy and governance across a multi-site manufacturing, packaging and distribution network. He has developed quality programs across manufacturing sites to ensure compliant operations, led FDA inspections, and deployed electronic platforms to standardize efficient quality system management.

Today’s Quality Landscape in Pharmaceutical Manufacturing

The FDA’s Quality Management Maturity initiative is designed to connect mature quality practices with fewer manufacturing failures, greater resilience during disruptions and more reliable market supply. As this program continues, it is shifting focus from maintaining minimum Current Good Manufacturing Practice (CGMP) compliance towards continuous quality system improvement.

Pharmaceutical manufacturers are facing evolving regulatory expectations and supply-chain pressure. Modernization of phar maceutical ma nufact u r i ng p r a c t i c e s requires data consistency and organizational readiness in addition to r e g u l a t o r y compliance.

Reliable pharmaceutical supply is not achieved by working around the quality system; it is produced by a mature quality system that detects risk early, enables timely decisions, and creates accountability across sites and suppliers.

Moving from CGMP Compliance to Quality Management Maturity

There are lingering beliefs in the industry that compliance is antithetical to efficiency and continuity. However, weak investigations, inconsistent procedures, delayed escalation and poor supplier visibility can create compliance exposure and supply interruption. Poor investigations lead to repeat failures, batch rejections and shipment delays. 

Procedures that lack proper design can result in more deviations and slow production, and these deficiencies can spread to other systems or products. If suppliers provide deficient starting materials, the impact can manifest downstream interruptions or product quality deficiencies.

Maintaining minimum CGMP compliance without mature quality management can allow systems to fall behind evolving regulatory requirements and best industry practices. A strong organization will anticipate risks through the principles defined in ICH Q9 Quality Risk Management. Companies with multiple sites must have strong corporate oversight and standard policies where cross-site learning and gap identification are commonplace. If one site receives inspection observations, it is critical to assess other sites for similar weaknesses and implement standard improvements throughout the network.

Enterprise Governance without Unnecessary Bureaucracy

Procedures must be designed with clarity and prevent failure mechanisms. Decision rights, flowcharts, and escalation thresholds built into procedures help sites operate with confidence and efficiency. Routine management review should focus on trends, evaluate failure mechanisms, and assess risk. Processes should delineate when site operations can proceed independently or when corporate intervention is required. This relationship should strike the appropriate balance between site and corporate responsibilities to ensure consistency and robust site ownership.

It is the responsibility of executive leadership to ensure the quality management maturity principles are embedded in the entire manufacturing network.

Management reviews should incorporate trend and risk assessment to identify deviation patterns, laboratory turnaround, data integrity issues, effective corrective actions, right-first-time metrics and supply reliability. These leading indicators can effectively determine system health and compliance. When negative trends are revealed, it is important to identify causes and implement corrective actions before failures occur. Examining quality signals will make production processes more reliable and improve customer retention and patient accessibility by delivering quality products on time.

Building Quality beyond Technology

Electronic Quality Management Systems (QMS) and AI alone cannot overcome unclear processes, inconsistent data, weak leadership or poor escalation culture. Some industry professionals believe that electronic QMS or AI are the ideal solutions to remediate poor practices and improve compliance. However, poor procedures and escalation practices paired with weak decision-making skills by untrained or inexperienced leadership will still result in failure mechanisms. Capturing data alone does nothing unless the right signals and metrics can identify problems before they occur.

Strong leadership behaviors incorporate process visibility, personnel accountability, cross-functional ownership and talent stability. Leadership must establish robust systems and a strong culture. Blaming deviations on individuals instead of thoughtfully examining governance systems leads to routine failures. Poor leadership decisions can result in adulterated products released to market, product recalls, patient safety impact, damage to company reputation, lost market share, supply disruption and unnecessary cost.

Questions Executives Should Ask to Establish Operations 

Executives should ask whether the organization is structured to encourage signal identification, risk assessment and process ownership. Good organization alignment will ensure appropriate escalation, risk identification and product quality. They should also ask whether leadership is effective and accountable, empowered to make quality decisions, and possesses critical thinking skills. Inexperienced leaders or poor training programs can cripple an organization.

The next question is whether procedures and systems are designed to maximize compliance and efficiency. If these processes are clear and simple, sites can operate with confidence and identify quality risks before failures occur. Supply chain robustness is another consideration. Starting materials suppliers, internal production capabilities and distribution networks are all critical to product supply reliability.

Finally, executives should ask whether quality signals, metrics and process data are being assessed routinely and accurately. Strong organizations will utilize signals, appropriate data and risk assessment to ensure quality products are supplied to the market reliably and on time.

Maintaining a robust and reliable supply strategy incorporates strong quality practices, continuous improvement, learning from evolving regulations, and applying standard processes across sites. It is the responsibility of executive leadership to ensure the quality management maturity principles are embedded in the entire manufacturing network. ​ 

The articles from these contributors are based on their personal expertise and viewpoints, and do not necessarily reflect the opinions of their employers or affiliated organizations.