Spring 2017 - Current Topic
FINDING THE GOOD IN GOOD SCIENCE
Note: This document expresses Dr. Jenke’s personal views and opinions and is not a position established and supported by Triad Scientific Solutions, LLC. This document is not professional advice and does not constitute a professional service provided by either Dr. Jenke or Triad Scientific Solutions.
When members of the E&L community gather to develop standards, guidelines and best demonstrated practice recommendations, there are three principles they should obey:
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The standards must be based on “good science”,
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The standards must be effective and efficient, and
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The standards must fit every conceivable circumstance well.
It is the inability to achieve these principles that makes the generation of standards, guidelines and recommendations so frustratingly challenging.
Consider the last principle, for example. It is intuitively obvious in a diverse field such as pharmaceuticals that this principle is impossible to achieve as it is clear that a rigorous standard (which is specified set of tests coupled to a specified set of acceptable test results) cannot fit all the diverse circumstances equally well. It is the same problem as trying to design a glove that fits every human being. If the underlying purpose of the glove is “to keep one’s hands warm”, then a standardized glove can be designed that will address this requirement, to some degree, for most people. However, because the glove must keep everybody’s hands warm, it is logical that there will be design tradeoffs which will mean that while it keeps everyone’s hands warm, it does not keep everyone’s hands as warm as they would personally like it. Furthermore, there may be other trade-offs, such as “these gloves are not very sexy”, or “these gloves do not match my coat” or “these gloves make my hands itch”.
While the challenges in making standards that are generally applicable in the greatest number of circumstances are considerable, this is not the point that I want to address in this discussion. Rather, I want to address the challenges associated with good science.
Good science suffers from with the same problem as designing a standardized glove. As good scientists, we learned and we understand that there are very few universal scientific truths; rather, a scientific truth is a truth only under the rigorously defined set of circumstances upon which it is based. When we perform an experiment and draw a conclusion from that experiment, we understand the conclusion is only perfectly valid for the set of defined experimental circumstances we started out with. Extension of that same conclusion to other circumstances involves a certain measure of risk, specifically the risk that in changing the circumstances we have invalidated (knowingly or unknowingly) some fundamental principle that defines the applicability of our conclusions. Thus, we understand that there is an inherent trade-off when we make scientific generalizations and put them into standards, guidances and recommendations. That is, we sacrifice some of the good in good science for the sake of providing a direction that is generally right in the greatest number of circumstances.
The challenge we face as practitioners of good science is not in recognizing good science per say but recognizing the boundaries that differentiate between good science properly applied and good science improperly applied. When we are tempted to use a standard, or leverage a “rule of thumb” or “do this because everybody else is doing it”, as good scientists we must ask ourselves “am I taking a good idea in certain circumstances and applying it to the wrong circumstances?”. If the answer is yes, then surely this is as bad as using “bad” science in the first place.
Let me illustrate this with an example. I use this as an example not because it a particularly bad practice but because it effectively illustrates my point. The following, taken from the PQRI OINDP Best Practice recommendations, is well known and commonly applied in the E&L community.
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The Working Group recommends that analytical uncertainty be evaluated in order to establish a Final AET for any technique/method used for detecting and identifying unknown extractables/leachables.
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The Working Group proposes and recommends that analytical uncertainty in the estimated AET be defined as one (1) standard deviation in an appropriately constituted and acquired Response Factor database OR a factor of 50% of the estimated AET, whichever is greater.
The question I would ask you to consider is “where is the good science and the not so good science in these recommendations?”
Here is my answer. It is well known that response factors will vary among the universe of compounds that could be extractables and leachables. Thus, it is good science that a general concept such as the AET, which presumably is applicable to all possible extractables/leachables, take this variation into account. Furthermore, we all understand that basing actions on relevant and sufficient data is the cornerstone of good science, and thus that the requirement to consider “an appropriately constituted and acquired Response Factor database” is a requirement to do good science. However, it must be obvious that the direction to universally “use a factor of 50%” is not necessarily good science. While the derivation of the 50% is itself good science, as it was based on a response factor database (which is somewhat small in the context of the databases available today), it is obvious that the 50% is only relevant for the compounds in that database and the analytical method with which the data was generated. Universal and unquestioned application of the factor of 2 rule to compounds that were not in the original database and to analytical methods other than the method used to generate the data is not the best science; rather, it is poor science, not because the science itself is bad but because the good science aspects are being applied out of context.
To a good scientist, arguments such as “it is better than nothing” or “everybody else is doing it” are inexcusable. Certainly, the idea that “it is better than nothing” has to be examined objectively and harshly. The improper application of science is not guaranteed to be better than doing nothing because it is not the case that the improper application of science will always make things better. In fact, the history of improper application of good science is littered with examples of bad outcomes derived from applying good sciences incorrectly.
Listen, nobody said doing good science was easy. We understand that part of the driving force for recommending that the factor of 2 be universally applied is that back then few people could access a database. Thus, it was nearly impossible to practice the good science required in the recommendation and people, rather than do nothing, gravitated to the other part of the recommendation. However, today, it is virtually impossible to run into a reputable E&L laboratory that is not eager to talk about their database. Thus, in this case, our ability to do good science has finally caught up with our responsibility to do good science. It is proper that we accept that responsibility and be held accountable for meeting that responsibility.
This is true not only to adjusting the AET for analytical uncertainty but in numerous other places where our current capabilities enable our ability and address our responsibility to practice and preach a higher degree of good science than has ever been possible. Currently applied recommendations, standards, guidelines and practices must be adjusted, as appropriate, to leverage this new and higher degree of good science and new recommendations, standards and guidelines must be drafted to reflect this new and higher degree of science. We aspire to better science because we are capable of better science. More importantly, if we are going to talk the talk, we best start walking the walk.
TRIAD 2024
January, 2024
I opened my mail the other day and found one of those calendars one gets for supporting various charitable organizations. Seeing the date (2024) made me pause and think “where has all that time gone?”
Seven years ago, I started Triad Scientific Solutions LLC Solutions to pursue “other professional opportunities” upon my retirement from Baxter Healthcare Corporation. Triad was launched to “provide the pharmaceutical, cosmetic, food and related industries with integrated, science-based, and practical solutions to suitability for use challenges for packaging, manufacturing components and systems, and administration devices, to support clients in their efforts to secure regulatory approval for pharmaceutical drug products and medical devices, and to afford me the means to remain active in setting standards and best practices for extractables and leachables.
After seven years, I find myself considering the question “Has Triad been a success?”. I guess it depends on the unit of measure. Since 2024 finds Triad as an ongoing concern, I suppose it is a success from the commercial perspective. As I still (for better or worst) actively publish and support national and international efforts to develop and standardize E&L practice, I suppose Triad has been a success in terms of “keeping me in the game”.
But what about the fulfilling the mission of providing “solutions to challenges”? Let’s be honest, in this game you win some and you lose some. Often enough, clients share with the me good news concerning the ultimate outcome of our collaborations, such as “We are off hold and couldn't have received better news … An inordinate amount of hard work, grit, and ingenuity has led to this moment”. My personal favorites include:
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I would be lucky indeed to have the good fortune of working with you all in the future.
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You saved the day!
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Dennis, I have to say I am impressed. You are a brilliant man.
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Your testimony was frequently cited in the Judge’s decision.
Yes, everybody loves to celebrate their wins. But what about the “you lose some” from above? Well, there have been times where the path to success was a little longer and more stressful than one would have liked. There have been collaborations that started with bad news like “I can’t do anything with what you currently have and the only path forward is to do it right the second time”. There have been studies that looked so good on paper that produced results that surprised everyone (and not necessarily in a good way), including the expert who was hired to make sure these kinds of things did not happen. There have been submissions that seemed so solid when they were submitted but which came back with feedback that can only be described as “disappointing, unexpected, and illogical” (as if any of that really matters). There have been the “Hail Mary” attempts that have fallen to the turf uncaught. However, I cannot think of a single collaboration that has ended (eventually) in a failure to achieve the desired objective because “Dennis, you screwed up and led us down the wrong path”.
In the final analysis, it has been a humbling seven years. I recognize that the successes were never a one man show and that I owe a debt of gratitude to those have walked alongside me, helping to carry the load and often pointing the way. I want to thank the growing number of past and current clients who have come to me with their issues, challenged me with their projects, and trusted me with their products and I celebrate the successes that we have had. I apologize that there is not always an easy and obvious answer and that the solution is not always simple but I note that there has always been, and there will always be, a path forward. Moreover, I thank those many professionals, talented, hard-working, and proud, who have labored with me (even if they were “on the other side”) to ensure that safe and effective drugs and medical devices are readily available to patients in need.
To my friends, colleagues and all who continue to selflessly give their time and talent in service to our profession and in the pursuit of “the greater good”, I wish you boundless energy, uncommon insight, the wisdom of Solomon, an infinite budget, a thick skin, and continued success.
Lastly, I look forward to new collaborations and working with new partners to achieve the worthy goal of sustaining and saving lives. To potential future clients I would say that “help is only a phone call away”, although to be perfectly honest I answer e-mails much more quickly than I answer the phone. If you seek a partner whose commitment to the patient is as strong as your own, who sees “good science practically applied” as two sides of the same coin, who understands that “your emergency is my emergency”, and who believes that collaboration and mutual respect is always the surest path to success, then I do hope you will contact me.
With humility, regards, respect, and gratitude and yours in science and in practice,
Dennis Jenke
Chief Executive Scientist
Triad Scientific Solutions, LLC