Staff interviews and process observation: identifying gaps between SOPs and actual practice

The most dangerous gaps are invisible in documents

A binder can look perfect. The regulatory files can be complete, the delegation log current, the training records signed and dated. And yet the site can be deeply out of compliance -- not because anyone falsified records, but because the way people actually do their work has quietly drifted from the way the procedures say they should do it.

I call this phenomenon "procedural drift," and it is, in my experience, the single most common source of inspection findings at clinical research sites. It does not happen because staff are careless or defiant. It happens because procedures are written in one context -- typically by someone sitting at a desk, thinking carefully about what the ideal process should be -- and executed in another context entirely, where the investigator is running behind, the participant is anxious, the phone is ringing, and the coordinator has three studies competing for attention at the same moment. Over weeks and months, small practical adaptations accumulate. A step gets reordered because it is more efficient that way. A form gets supplemented with an informal tracking tool because the official system does not quite fit the workflow. A verbal confirmation replaces a documented one because everyone trusts each other and "we always do it this way."

None of these adaptations are visible in the document review you learned in the gap analysis lesson. They are visible only when you watch people work and ask them how they work. That is what this lesson teaches: how to see what documents cannot show you.

The most dangerous gaps are invisible in documents

The most dangerous gaps are invisible in documents

What you will learn

Staff interviews and process observation: identifying gaps between SOPs and actual practice

The most dangerous gaps are invisible in documents

What you will learn