Transcript
Page 1: What is good evidence  - Let's Test 2013

© 2013 Congruent Compliance LLC 1

What is Good Evidence?

May 2013

Page 2: What is good evidence  - Let's Test 2013

© 2013 Congruent Compliance LLC 2

Griffin JonesConsultantAgile / Testing / Regulatory

May 2013

This Presentation Covers …• Types of Evidence• Qualities of Evidence• Traps and Anti-Patterns

Why I Care, and Why You Should• Civil and Criminal Courts• Credible and Persuasive Story-of-Testing

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© 2013 Congruent Compliance LLC 3May 2013

TYPES OF EVIDENCESources• FDA’s 21 CFR Part 11 – Electronic Records• FDA’s Good Manufacturing Practices• (Adjust for your context)

Records versus Testimony• Speaks for Itself • Cross-Examination

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QUALITIES …Clear• To Whom?

Objective• To What Degree?

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… QUALITIES …Authentic• Originals or Copies?• Resistant to Falsification?

Integrity• Protected from Damage / Deterioration?• Can not be Readily Repudiated?

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Readable• Human and Machine?

Changes• Do Not Obscure Previous Information?• Single line-out, initial, date, reason?

… QUALITIES …

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… QUALITIES …Attributable• Do we know the Specific Person?

Contemporary• Created At-The-Moment?• Are Not Recollections?

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… QUALITIES …Audit Trail• Is there a Chain-of-Custody?• Is there a Revision History?

Retrievable• Is this stored where I can Access it?

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… QUALITIES3rd Party Review / Reconstruction• Minimal Outside Assistance?• Reach the Same Results & Conclusions?

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TRAPS, THREATS AND ANTI-PATTERNS

Deficient Qualities • Leads to Feebleness

Feebleness• Leads to Unpersuasive Stories• Maybe a Systemic Risk smell?

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“PASS-AS EXPECTED”CHECKBOXES

Fear potential False-Positives• The danger of the Green-Bar• Falsification versus Confirmation

What you Intended to do• Not what you Actually Did

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Shuts-down Conversation• Discourages feedback • Promotes Shallow Agreement • Lulls your mind into a False Sense of

SecurityStyled Ceremony and Ritual• To provoke a behavior, not inform a

decision

LULLABY LANGUAGE

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… VERSUS LEAN’S GENCHI GENBUTU

“… It’s Lies! All Lies!”• Metrics and reports are just maps …• Get out of your office• Go observe where the work happens• Take your own measurements

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EFFICIENCY AND TIME PRESSURE

Biasing and Priming the Subject• Over-Scripting over-focuses attention• The “Moon-Walking Bear” problem• Target Lock-On

Unringing the Bell• The button story and pixel-drop out

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Recognize the Different Qualities• Clear, Objective, Authentic, Integrity,

Readable, Changes, Attributable, Contemporary, Audit Trail, Retrievable, Reconstructable

How is your evidence deficient?

SUMMARY … A

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Recognize the Traps• Pass-As-Expected• Lullaby Language• Moon-Walking BearGo Observe the Work

SUMMARY… B

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QUESTIONS AND STORIES

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Thank you for attending this session. Please fill out the evaluation form.

Griffin Jones

[email protected]

May 2013


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