01
Network, capacity & capital strategy
Deciding what capability the organisation needs, where, and whether to build it, buy it or contract it — including capacity, redundancy and how much resilience the network carries against a site being lost.
These decisions set the constraints every other pillar operates inside for decades. Capacity that is technically available but concentrated in one site is a supply risk that no amount of downstream quality work can offset.
HOW IT FAILS
- Capacity is planned against forecast demand without modelling what a single-site loss would do to supply.
- Make-versus-buy is decided on unit cost, omitting the oversight burden and the knowledge that leaves with the work.
- Capital cases assume a regulatory timeline that has never been tested against the authorities involved.
WHAT CONTAINS IT
- Network modelling that includes loss-of-site and demand-surge scenarios, not only expected demand.
- Make-versus-buy assessment covering oversight cost, knowledge retention and regulatory consequence.
- Regulatory feasibility confirmed as an input to the capital case rather than a consequence of it.
EVIDENCE IT OPERATES
- Capacity and network models with the scenarios evaluated.
- Make-versus-buy analyses including quality and regulatory factors.
- Capital approval records with the assumptions stated and later reviewed.
02
Project governance & controls
Running the project itself: scope, schedule, cost, risk, contracts, interface management, change control and the eventual test of whether the promised benefits arrived.
Capital projects fail at the seams — between disciplines, between contractors, and between the project and the operation that inherits it. Governance is what makes those seams somebody’s explicit responsibility.
HOW IT FAILS
- Schedule pressure converts quality-critical activities into parallel ones, and qualification absorbs the compression.
- Interface responsibilities between contractors are assumed rather than assigned, so gaps appear at the boundaries.
- Benefits realisation is never assessed, so the same optimistic assumptions are reused on the next project.
WHAT CONTAINS IT
- Stage gates with quality and regulatory criteria that cannot be waived by schedule alone.
- An interface register naming the owner of every boundary between parties and disciplines.
- Post-implementation review against the benefits and assumptions the case was approved on.
EVIDENCE IT OPERATES
- Stage-gate decisions with the criteria applied and any exceptions justified.
- Interface and project risk registers maintained through execution.
- Post-implementation review comparing outcome to business case.
03
Facility & process design
Designing the physical environment: material and personnel flows, segregation, cleanliness zoning, utilities, containment, and whether the result can actually be maintained and cleaned once it is running.
Flow and segregation decisions determine the contamination-control strategy for the life of the facility. A cross-flow designed in is a permanent procedural burden, mitigated forever by people rather than by geometry.
HOW IT FAILS
- Flows are designed for construction efficiency, leaving crossovers that operations must control procedurally.
- Maintainability is not a design criterion, so routine maintenance requires entering classified areas or shutting production.
- User requirements are written by engineering rather than by the people who will operate and clean the space.
WHAT CONTAINS IT
- User requirements authored with operations, quality and maintenance, and traced through design.
- Flow and segregation reviewed against the contamination-control strategy, not only against area classification.
- Maintainability and cleanability assessed as explicit design criteria with sign-off.
EVIDENCE IT OPERATES
- User requirement specifications with cross-functional approval.
- Flow, zoning and segregation drawings with the design rationale.
- Design review records covering maintainability, cleanability and containment.
04
Engineering disciplines & design integration
The coordination of process, mechanical, electrical, civil, structural, architectural and instrumentation design into one buildable, consistent set of documents.
Each discipline can be individually correct while the combination is not. Clashes discovered on site are resolved under time pressure by whoever is present, and the as-built result rarely matches anyone’s intent.
HOW IT FAILS
- Discipline models are coordinated for physical clash but not for functional consequence, so a compliant routing defeats a cleaning requirement.
- Late design changes propagate to construction without returning to the disciplines that depended on the original.
- Instrumentation and control design lags process design, so critical parameters have no means of measurement.
WHAT CONTAINS IT
- Formal multi-discipline design review at defined maturity points, including quality where GMP impact exists.
- Change management that re-checks dependent disciplines rather than only the one changed.
- Instrumentation design driven by the control strategy, with critical parameters traced to a measurement.
EVIDENCE IT OPERATES
- Coordinated design deliverables with review and approval records.
- Design change records showing dependency re-assessment.
- Traceability from critical process parameters to instruments and their qualification.
05
Procurement, fabrication & vendor management
Buying the equipment and services: specifications, bid evaluation, vendor documentation, factory acceptance testing, expediting, inspection, logistics and acceptance on site.
Most of the quality of a capital asset is determined by the specification it was bought against and the testing done before it shipped. A deficiency found at site acceptance is orders of magnitude more expensive than the same deficiency found at the factory.
HOW IT FAILS
- Factory acceptance testing is witnessed as a formality, so equipment ships with known deficiencies recorded as punch items.
- Vendor documentation arrives incomplete and is chased after installation, delaying qualification.
- Specifications describe the equipment but not the GMP-critical aspects it must satisfy.
WHAT CONTAINS IT
- Specifications that state the regulated requirements, not only the engineering ones.
- Factory acceptance testing against pre-approved protocols, with leverage retained until deficiencies close.
- Vendor documentation defined as a deliverable with acceptance criteria and payment linkage.
EVIDENCE IT OPERATES
- Specifications and bid evaluations including quality criteria.
- Factory and site acceptance test protocols and results.
- Vendor documentation packages assessed for completeness before qualification.
06
Construction, installation & field quality
Physical execution and the quality control around it: installation to specification, field inspection, welding and materials verification, field change handling, and the as-built record of what was actually built.
Qualification verifies what exists, not what was drawn. Where the as-built record is unreliable, every subsequent change and investigation starts from a drawing that does not describe the plant.
HOW IT FAILS
- Field changes are made to solve an installation problem and captured only as redlines that are never incorporated.
- Material traceability for product-contact components is incomplete, and cannot be reconstructed later.
- Construction quality records are held by the contractor and not transferred in a usable form.
WHAT CONTAINS IT
- Field change control with the same rigour as design change, including quality assessment where GMP-relevant.
- Material traceability maintained for product-contact and critical components at installation.
- As-built documentation defined as a contractual deliverable, verified before turnover.
EVIDENCE IT OPERATES
- Installation and field inspection records, including weld and material certification.
- Field change records with assessment and incorporation into drawings.
- Verified as-built documentation handed over with the asset.
07
Systems completion & turnover
Bringing the asset to a defined, verified completion state: system boundaries, mechanical completion, punch listing, documentation dossiers, safe energisation and the controlled handover to the next party.
Turnover is the moment accountability moves. Where completion is declared with open items and an incomplete dossier, qualification begins on an asset nobody can fully describe, and the gaps surface as deviations later.
HOW IT FAILS
- Mechanical completion is declared against schedule pressure with significant punch items open and no closure plan.
- System boundaries are drawn differently by the project and by the qualification team, so scope falls between them.
- Turnover dossiers are assembled from what exists rather than against a defined required content list.
WHAT CONTAINS IT
- Defined, agreed completion criteria per system, with categorised punch items and closure before handover.
- A single system boundary definition used by construction, commissioning and qualification alike.
- A required turnover dossier content list agreed before completion, verified at handover.
EVIDENCE IT OPERATES
- Mechanical completion certificates with punch-list status.
- System boundary definitions shared across project and qualification.
- Turnover dossiers verified against the agreed content list.
08
Commissioning & technical startup
Making the installed asset work: functional testing, loop checks, balancing, control sequence verification, alarm testing, utility startup and the reliability run that shows it holds.
Commissioning is where engineering verification and regulated qualification meet, and the science- and risk-based approach expects the two to be leveraged rather than duplicated. Done well it removes rework from qualification; done as a formality it guarantees it.
HOW IT FAILS
- Commissioning and qualification testing duplicate each other because commissioning was not executed under conditions that allow leverage.
- Alarm and interlock testing covers the expected path and not the failure conditions the alarm exists for.
- Startup proceeds with temporary configurations that are never formally removed or documented.
WHAT CONTAINS IT
- Commissioning executed under documented, reviewable conditions so verified results can be leveraged into qualification.
- Functional testing that includes failure modes, interlocks and recovery, not only normal operation.
- A register of temporary configurations with mandatory closure before qualification.
EVIDENCE IT OPERATES
- Commissioning protocols and results, with the leverage decision documented.
- Loop check, alarm and interlock test records including failure-condition testing.
- Temporary configuration register closed out before handover.
09
Asset management, maintenance & reliability
Keeping the asset fit for use across its life: criticality assessment, preventive and predictive maintenance, spares, the calibration interface, and managing equipment as it becomes obsolete.
Qualification proves an asset was fit at a point in time; maintenance is what keeps that true. A validated state is not preserved by documentation — it is preserved by the work that keeps the equipment behaving as qualified.
HOW IT FAILS
- Maintenance intervals are inherited from the vendor manual without reference to criticality or observed failure behaviour.
- Deferred maintenance accumulates on equipment that is running, and the backlog is invisible to quality.
- Obsolescence is discovered when a part cannot be sourced during a breakdown.
WHAT CONTAINS IT
- Criticality-based maintenance strategy, with GMP-critical equipment identified and treated accordingly.
- Deferral of maintenance on critical equipment visible to and assessed by quality.
- Obsolescence monitoring with planned replacement ahead of end-of-support.
EVIDENCE IT OPERATES
- Asset register with criticality and maintenance strategy per item.
- Maintenance completion and deferral records with quality assessment where critical.
- Calibration records and obsolescence plans for critical instruments and systems.
10
Brownfield change, shutdowns & decommissioning
Changing a facility that is already operating: tie-ins to live systems, temporary controls, shutdown planning, dealing with legacy conditions, and the safe retirement of equipment, areas and records.
Brownfield work happens next to product, and the risk is to the operation continuing around it. Decommissioning carries a quieter risk: records and materials disposed of before their retention obligations were checked.
HOW IT FAILS
- Temporary controls put in place for a tie-in are never formally removed, becoming permanent undocumented configuration.
- Impact on adjacent operating areas — pressure cascades, utilities, traffic — is assessed for safety but not for product quality.
- Decommissioning disposes of equipment, samples or records still subject to retention or a pending investigation.
WHAT CONTAINS IT
- Temporary change control with mandatory expiry and verified restoration.
- Impact assessment covering adjacent operating areas and their contamination-control assumptions.
- Decommissioning checklists covering record retention, sample retention and open investigations before disposal.
EVIDENCE IT OPERATES
- Shutdown and tie-in plans with quality impact assessment.
- Temporary change records with expiry and closure verification.
- Decommissioning records including retention and disposal decisions.