
The RC's role in deviation prevention, detection, and correction at the portfolio level
Addresses how the RC manages regulatory deviations across the portfolio — building prevention systems, detecting cross-study patterns, and implementing CAPA for systemic issues
Avoidance first
ICH E6(R3) Principle 6, Section 6.3, is unambiguous about the order of operations: strategies should be implemented to "avoid, detect, address, and prevent recurrence of serious noncompliance." Note the sequence. Avoidance comes first. Detection second. Correction third. And prevention of recurrence -- the most intellectually demanding step -- comes last. This is not an arbitrary list. It is a hierarchy. The regulatory coordinator who waits for deviations to occur and then documents them competently is practicing quality control. The one who builds systems that make deviations structurally unlikely is practicing quality management.