CENTRE FOR CLINICAL DIAGNOSTICS Quality Manual Effective Date: 27 May, 2013 Author (QA Manager) Amendment History Version Date Facility Director Author/s Amendment details 1 11/2/2013 H Kramer First version 2 27/5/2013 H Kramer Section 4 updated to include Conflict of Interest reference. NB. The Quality Manual framework is ISO 17025 (R&D). Additional information from ISO 15189 has been included and is referenced at the beginning of each section. 1. INTRODUCTION & DESCRIPTION ISO 15189 (2009), 4.1, 5.1 The University of Queensland Centre for Clinical Research (UQCCR) mission is to improve health through excellence in research, clinical partnerships, mentorship and service. Within the UQCCR, the Centre for Clinical Diagnostics (CCD) has been established to manage and conduct research into oncology and reproductive medicine and the development and optimisation of in vitro diagnostic medical devices to support diagnosis and treatment. CCD receives samples from the UQCCR clinic operating on Level 3 of the UQCCR Building and also from referring practitioners collaborating with the CCD research program. The CCD is located on Level 7 of the UQCCR at the Herston campus of The University of Queensland (UQ). It is fully owned by UQ. All resources, staffing and funding are provided by UQ. Senior management ensures that responsibilities are defined, documented and communicated within the organization and ensures the independence and authority necessary to perform these tasks. An appointed member of management has responsibility and authority that includes quality management system (QMS) oversight, reporting QMS performance to senior management and ensuring the awareness of regulatory and customer requirements throughout the organization. CCD management provides the resources needed to maintain the effectiveness of the QMS and to meet regulatory and customer requirements. Review NLT: May 2014 Page 1 of 12 Quality Manual v2 CENTRE FOR CLINICAL DIAGNOSTICS Appendix 1 contains an organizational chart for CCD. Appendix 2 contains a list of the Position Descriptions for key roles within the Facility. 2. QUALITY POLICY ISO 15189 (2009), 4.2.3 The UQCCR quality policy forms the core of our quality system. We: improve health through excellence in biomarker measurement and IVD development comply with all expectations encompassed within the ISO standards 17025 (R&D) and 15189. apply the quality policy through a quality management system (QMS). The QMS provides a documented formalised framework encompassing all actions and procedures conducted within CCD and the Level 3 Clinic. enhance customer satisfaction through a process of continual improvement and regulatory compliance while ensuring optimal care of our clients, support of our staff and confidentiality of records ensure that all personnel are trained in the QMS and are competent in all relevant procedures are proficient in all testing services offered while promoting a high standard of excellence in support of clinicians, clients and other professionals 3. MANAGEMENT REVIEW ISO 15189, 4.15 Laboratory management reviews the suitability and effectiveness of the quality management system (QMS), including all services and procedures. The results of the review are documented, including goals and action plans, and staff informed. This review occurs at least annually, and more frequently during establishment of the QMS. Laboratory management follows up the findings and ensures actions are taken within an appropriate timeframe. The review also includes information on new or revised regulatory requirements. SOP 014 Management Review 4. STAFF, EDUCATION & TRAINING ISO 15189 (2009), 5.1 Facility management has: • Personnel policies (UQ) and job descriptions available for all staff • Staff professional records, including training • Appropriate oversight of operations • Appropriate training and education programs, including safety and confidentiality The UQ ‘Policy and Procedures Library’ provides comprehensive coverage for all aspects of CCD’s operations. Particular attention is drawn to the policy ‘Conflict of Interest within Responsible Conduct of Research’ (section 4.20.02a of the ‘Policy and Procedures Library’). Review NLT: May 2014 Page 2 of 12 Quality Manual v2 CENTRE FOR CLINICAL DIAGNOSTICS The suitability of education and experience of all personnel employed in any capacity within the CCD and Clinic is confirmed during the employment process. UQCCR maintains a focus on the relevancy and currency of all staff education, training and conduct. Training and education is appropriate to ensure continuous improvement in our services. All staff receive appropriate training in the Quality Management System. UQCCR recognises the benefits of learning to staff, clients and our services. SOP 001 SOP 002 Personnel and Training UQ Policies 5. QUALITY ASSURANCE (QA) ISO 15189 (2009), 4.2, 4.9 QA provides ongoing assurance that the Facility is operating in compliance with the accreditation requirements. It supports and controls a framework of Standard Operating Procedures (SOP) and documents and provides independent oversight of the operations of the Facility. SOP 003 SOP 004 SOP 009 SOP 010 SOP 011 SOP 012 SOP 013 Control of documents Control of records Subcontracting of tests and calibrations Purchasing services and supplies Feedback, including complaints Nonconformances, including corrective and preventive actions Audits These documents are complemented by a comprehensive series of technical procedures prepared by staff, with compliance maintained by QA. QA conducts a routine program of internal audits to ensure ongoing compliance. 6. DOCUMENT CONTROL ISO 15189 (2009), 4.3 Documents are in electronic format, digitally signed and 21 CFR 11 compliant. They are stored in an Electronic Laboratory Notebook maintained on a secure server with restricted access. In some circumstances, paper copies of QMS documents are used. Printed copies of quality system documents are issued from the ELN and have an identical format to electronic documents. All documents that form part of the CCD quality system are uniquely identified and subject to control and are detailed in a master list, including version and issue date. Documents are defined as including policies, procedures, instructions, forms, text books, international standards, reference intervals and software. The document system structure includes general policies as defined by The University of Queensland, Standard Operating Procedures covering processes and administrative topics and Work Instructions/Assay Protocols for all technical operations. Review NLT: May 2014 Page 3 of 12 Quality Manual v2 CENTRE FOR CLINICAL DIAGNOSTICS Documents are reviewed and approved by authorised personnel and are subject to scheduled review. All changes in current practice are reviewed and approved prior to issuing. Only currently authorised versions of documents are available for use. Superceded/expired ‘Master’ documents are identified as such and retained in the electronic or paper archive, whichever is applicable, for a period as defined in the relevant SOP. The document control procedures are defined within the relevant QMS documents. SOP 003 Control of Documents 7. RECORDS, MAINTENANCE & ARCHIVING ISO 15189 (2009), 4.3 All records are uniquely identified and are stored in a manner such that they are readily retrievable. Records may be stored in secure, audited offsite storage. Records are attributable, legible, contemporaneous (recorded as observed), original and accurate. A suitable environment is provided to prevent damage, loss, deterioration or unauthorised access. The retention period for records is defined in the relevant SOP. Records include the following: request forms, results, reports, instrument printouts, laboratory worksheets/books, electronic records, calibration data, QC data (internal and external), audit reports, training records and maintenance records. The CCD Facility has SOPs for the handling, archiving and retention of records. SOP 004 SOP 006 SOP 007 Control of Records Records and Sample Retention Electronic Laboratory Notebook 8. ACCOMMODATION & ENVIRONMENT ISO 15189 (2009), 5.2 The facility and resources are fit for intended use and are maintained in a functional capacity that does not compromise result quality or delivery. The comfort and safety of staff and clients are optimised and clients are protected from recognised hazards. The laboratory environment: • Is suitable for the designated procedures • Does not adversely affect the result outcome • Is monitored and controlled and the environmental conditions recorded • Has effective separation between incompatible activities and measures to prevent cross-contamination • Has appropriate measures to prevent unauthorised access • Has relevant storage space and conditions to ensure sample, consumables and records integrity Review NLT: May 2014 Page 4 of 12 Quality Manual v2 CENTRE FOR CLINICAL DIAGNOSTICS • Is well maintained and clean with provision for disposal according to local regulations • Has established maintenance activities when the absence of such activities could affect product quality WI 0059 WI 0060 Comet Dataloggers Setup Comet Datalogger Alarms 9. EQUIPMENT, SERVICES, PRODUCTION & SUPPLIES ISO 15189 (2009), 4.5, 4.6, 4.7, 5.3; 5.8 The CCD Facility has all the equipment required to conduct the services offered in a high quality reliable manner. In those cases where the Facility needs to use equipment outside its permanent control, laboratory management ensures that the requirements of this International Standard are met. The CCD Facility has procedures for the handling of test and calibration items. These items have unique permanent identifiers and are traceable, where applicable, to national primary standards. Periodic calibration by NATA certified providers is documented. Equipment: • Is installed/commissioned through a compliant, documented and approved Installation Qualification/Operational Qualification (IQ/OQ) process unless determined otherwise through a documented risk assessment process • Is uniquely identified • Is demonstrated fit for purpose • Is included in a documented maintenance and/or calibration program, where appropriate, with all outcomes recorded in facility records. • Is operated by authorised personnel only • Is provided with a Work Instruction for use, maintenance and calibration • including: • Is validated by the manufacturer where appropriate • Maintains the integrity of data • Utilises electronic audit trails where appropriate • Uses unique user names and passwords The CCD Facility has defined its policies and procedures for the selection and use of purchased external services, equipment and consumable supplies. Equipment and supplies should not be used until they have been verified as complying with the quality standards defined by the facility. Suppliers of critical goods are assessed and records of these evaluations approved and maintained. A list of approved suppliers and records of goods received is maintained within the quality management system. Review NLT: May 2014 Page 5 of 12 Quality Manual v2 CENTRE FOR CLINICAL DIAGNOSTICS The facility has an effective documented procedure for evaluating and selecting referral laboratories and consultants. These arrangements are reviewed periodically. SOP 005 SOP 008 SOP 010 Calibration and Maintenance Computerised Systems Purchasing Services and Supplies 10. ANALYSIS/EXAMINATION PROCEDURES ISO 15189 (2009), 5.5 Analysis procedures are fit for purpose and, where developed in-house, are appropriately validated (e.g. Evaluation of Precision Performance of Quantitative Measurement Methods Approved Guideline, EP5-A2, Volume 24, number 25, Clinical and Laboratory Standards Institute), reviewed and approved. The extent of the validation is determined through a documented risk assessment process. It is preferred that procedures selected from external sources are sourced from established/authoritative textbooks, peer-reviewed journals or official guidelines. The level of validation is justified and documented. Manufacturer’s kits have been fully validated by the manufacturer and will be used following verification that results generated by the CCD Facility are comparable with the manufacturer’s expectation. Verification will consist of accuracy and precision testing. There are approved Work Instruction readily available for each procedure. Electronic or hardcopy manuals are acceptable and may, in certain circumstances, obviate the need for a more comprehensive Work Instruction. Biological reference intervals should be established and approved for relevant procedures and should be periodically reviewed for appropriateness. A review of procedures takes place on a periodic basis, usually annually, and the outcome documented and approved by the Facility Manager or delegate. SOP 016 Performance Evaluation of Quantitative Methods 11. SAFETY ISO 15189 (2009), 5.2 The CCD Facility is a safe laboratory environment, in compliance with good practice and all relevant Government regulations and UQ OH&S policies. Safety training, in accordance with UQ procedures, is undertaken by all personnel and is documented in the quality management system (QMS). Samples received for analysis are handled in a manner that ensures safety for the client and personnel. Review NLT: May 2014 Page 6 of 12 Quality Manual v2 CENTRE FOR CLINICAL DIAGNOSTICS Equipment is maintained in a safe operating condition and all dangerous materials are stored and discarded in compliance with UQ policy. Facility waste management procedures for biological non-biological materials are in compliance with UQ policy. SOP 002 UQ Policies 12. RESEARCH & DEVELOPMENT Research and development (R&D) activities in the CCD Facility are conducted in compliance with: • ISO 17025 (R&D), ‘General requirements for the competence of testing and calibration laboratories’ and/or • ISO 15189 – ‘Medical Laboratories – Particular requirements for quality and competence.’ 13. SAMPLE COLLECTION & HANDLING ISO 15189 (2009), 5.4 Primary samples are received from two sources: • UQCCR Clinic Level 3 • External referring clinicians/laboratories CCD sample transport, receipt, storage, sampling and handling procedures are defined with Work Instructions. Risk assessments for all relevant tasks have been prepared and approved and are acknowledged by staff in relevant records. Specimens received from referring clinicians and laboratories remain in the control of their management systems until received at CCD. Samples may only be handled by CCD personnel who have been trained in the CCD quality management system. WI 0040 WI 0061 Sample Receipt, Tracking, Storage, Retention and Disposal FreezerPro Sample Management Software 14. QUALITY CONTROL ISO 15189 (2009), 5.6 The CCD quality control (QC) system consists of internal QC and external proficiency testing, where the latter is applicable. All QC data forms part of the QMS controlled document system and is retained for predetermined periods. Tests selected for internal QC and external proficiency testing should be relevant to the routine testing in the CCD facility and should, if possible, mimic the matrix of true patient samples. Facility management regularly monitors the outcome of all QC testing and, in collaboration with technical staff, uses the outcomes to contribute to continuous improvement of testing procedures, including sample handling. Trend data is maintained so that deviations can be detected early, documented and acted upon. Records of actions are maintained. Review NLT: May 2014 Page 7 of 12 Quality Manual v2 CENTRE FOR CLINICAL DIAGNOSTICS Where an appropriate formal interlaboratory proficiency program is unavailable, CCD will assess and implement, where feasible, an internal measure to provide assurance of the ongoing reliability of the test/procedure. This may include exchange of samples with other laboratories. CCD will determine the uncertainty of measurement, where feasible, using a NATA defined method. This measurement will aid in the identification of key uncertainty components and in the improvement of the robustness of procedures. SOP 015 Measurement Uncertainty 15. LABORATORY DATA ISO 15189 (2009), 4.13 The majority of CCD data are in electronic format either in the Electronic Laboratory Notebook (ELN) which is located on a secure UQCCR server or downloaded from instrumentation. ELN Notebook data are reviewed and approved electronically by CCD personnel whose Position Description contains this responsibility. Where laboratory raw data are downloaded from an instrument to the server, all data transfer, storage, backup and recovery complies with 21 CFR 11, Electronic Records and Signatures. Documentation of 21 CFR 11 compliance is retained within the QMS. This validation need only occur when the system is established or when there is an approved software/server upgrade. There are written procedures for all actions associated with data handling. Paper records are used where no electronic means of data recording/capture is available. In these circumstances, a unique identifier (e.g. project code), date and name are added to the paper, the document scanned to the UQCCR server and then imported into the ELN to the appropriate folder. All computer systems are protected from unauthorised access and any data modification are traceable, attributable and justified. CCD does not operate a Laboratory Information Management System (LIMS). SOP 007 Electronic Laboratory Notebook 16. REPORTING OF RESULTS ISO 15189 (2009), 5.8 The Facility Manager and approved delegate(s) are responsible for the report format and approval. Reports must be legible with no mistakes and be reported to people authorised to receive the information. Each report must have a unique identifier and a copy of the report forms the raw data record for the purposes of record retention. 17. REMEDIAL ACTIONS & COMPLAINTS ISO 15189 (2009), 4.8, 4.9, 4.10, 4.11, 4.12 Review NLT: May 2014 Page 8 of 12 Quality Manual v2 CENTRE FOR CLINICAL DIAGNOSTICS Nonconformances occur when outcomes do not conform to the QMS requirements. CCD has a formal process for handling nonconformances. As soon as one is detected, the procedure or action should be halted and immediately investigated and reports withheld as necessary. The response to this situation consists of two levels: the corrective action to rectify the immediate situation and the preventive action to identify and implement improvements to reduce or eliminate the risk of a recurrence of the event. Personnel responsible for the resolution of the problem are designated and all actions documented. Implemented improvements are verified and monitored by management to confirm that the desired outcome has been achieved. A periodic review of corrective and preventive actions is conducted to monitor trends in and causes of nonconformances. This review, accompanied by a systematic review of operational procedures, assists in identifying further actions that will contribute to continual improvement. The laboratory has a policy and procedure for the resolution of complaints. Records of the complaint and the consequent action are maintained. SOP 011 SOP 012 Feedback, including Complaints Nonconformances 18. COMMUNICATION ISO 15189 (2009), 4.1.6 Forming a proactive relationship with staff, clients, clinicians and suppliers produces more sustainable outcomes. Communication within CCD is supported by the following: • Research seminars • Training (internal and external) • Mentoring • Team meetings • Reports • Newsletters • Email Communication is essential to ensuring the effectiveness of the quality management system (QMS). Engagement of staff, understanding the gap in their knowledge of the QMS and targeting communication and education to address this maximises the integration of the QMS into the routine work, its acceptance and the rate of improvement. SOP 001 Personnel and Training 19. INTERNAL AUDITS ISO 15189 (2009), 4.14 Internal audits are conducted on a regular basis to ensure compliance with the QMS requirements. The main elements of the QMS are subject to audit once every twelve months. The audits are formally planned and conducted by the independent quality assurance staff. Personnel must not audit their own activities. Deficiencies or opportunities for improvement Review NLT: May 2014 Page 9 of 12 Quality Manual v2 CENTRE FOR CLINICAL DIAGNOSTICS are documented and appropriate corrective and preventive actions implemented. Internal audit reports are submitted to management for review. SOP 013 Internal Audits 20. ETHICS ISO 15189 (2009), Appendix C The patient’s welfare and interest always take precedence. They are treated fairly and without discrimination. Information collected from the patient should be sufficient to enable proper identification with the patient aware of the information collected and its purpose. Unnecessary personal information is not to be collected. All procedures carried out on the patient require consent. In the case of clinical trials, there should be full compliance with the National Statement on Ethical Conduct in Human Research (2009). Confidentiality of patient data is very important. The laboratory ensures results are communicated appropriately and that reasonable safeguards are taken to prevent unauthorized access to records. Review NLT: May 2014 Page 10 of 12 Quality Manual v2 CENTRE FOR CLINICAL DIAGNOSTICS APPENDIX 1: CCD Organisational Chart UQCCR Director UQCCR Deputy Director CCD Quality Manager UQCCR Business Manager CCD Facility Manager Facility Technical Staff * Research Staff Clinic Supervisor Facility Support Staff # Research Students * Research Officers, Research Assistants #Laboratory Coordinators, Level 2 staff Review NLT: May 2014 Page 11 of 12 Quality Manual v2 Clinic Level 3 CENTRE FOR CLINICAL DIAGNOSTICS APPENDIX 2: Key Positions Position Descriptions for the following key positions are maintained in the CCD quality management system: • • • • • • • • • • UQCCR Director UQCCR Deputy Director CCD Facility Manager Postdoctoral Research Scholar Senior Research Officer Research Officer Senior Research Assistant Research Assistant Laboratory Coordinator CCD Quality Manager Review NLT: May 2014 Page 12 of 12 Quality Manual v2
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