A Cautionary Tale: The Schering-Plough Compliance Breakdown
In 2003, the Schering-Plough Corporation (now merged with Merck & Co.)—a global 33,500-employee pharmaceutical company received an FDA consent decree after multiple plant inspections revealed serious and repeated violations of Good Manufacturing Practices (GMP) and FDA 21 CFR Part 11.
Although most of the FDA enforcement was grounded in 21 CFR Part 211 (cGMP), many of the underlying data integrity violations involved 21 CFR Part 11 non-compliance, including:
After years of unsuccessful remediation efforts, the FDA concluded that Schering-Plough could not reliably comply with cGMP and 21 CFR Part 11 on its own. In May 2002, the FDA and the Department of Justice filed a Consent Decree of Permanent Injunction with a record-setting $500 million fine, highlighting the steep financial cost of major compliance failures.
In the Life Sciences and Pharmaceuticals, Compliance Isn’t Optional—It’s Everything
Every step in the development of a drug, device, or biologic must be documented, controlled, and validated. Regulatory compliance requires non-repudiated data integrity, traceability, version control, document audit trails, approval processes, record retention, and digital signatures. And yet, many organizations maintain their engineering drawings and documents in Windows or SharePoint folders, relying on manual methods for document access, version control, and approval routing. With no system to drive and enforce these document management best practices, the result is rampant duplicates, costly mistakes, wasted time, no traceability, and ultimately compliance challenges and fines.
It’s a dangerous disconnect—and one that forward-thinking firms like Merck have taken bold steps to resolve.
The Hidden Cost of Document Chaos
If your plant, facility, or equipment documentation lives in a complex, decentralized patchwork of folders and file shares, you're not alone. Most life sciences organizations struggle with similar issues:
The consequences? Wasted time, failed audits, costly rework, and even safety risks.
Merck’s former Associate Director of Supply Chain, Ray Kastle, knows this pain all too well. In fact, it was a near-miss excavation incident in 2019 where outdated drawings nearly led workers to dig into live power lines—that finally secured funding for an Engineering Document Management System (EDMS). As Kastle put it: “It would’ve resulted in digging up power lines, which we consider a bad thing.”
Why Pharmaceuticals and Life Sciences Need a Purpose-Built EDMS
While many organizations utilize general document repositories, these platforms rarely meet the stringent requirements of engineering and GxP environments. What’s required is an Engineering Document Management System (EDMS) designed from the ground up that provides:
As John Niziolek of IPS explained in the EDM for Simplified Compliance & Validation webinar, “Document management is the foundational aspect of all compliance in life sciences. Anything you do must be documented, validated, and tested with a traceable audit trail.”
Inside Merck’s Journey: From Legacy Frustration to Validated Control and Increased Confidence
Before adopting Adept from Synergis Software, Merck was running on a legacy platform that was, as Kastle described it, “broken from day one.” It lacked vendor support, couldn’t run on Windows 10, and was so unreliable that users only opened it when absolutely necessary. Here’s how Merck turned it around:
The implementation wasn’t without its lessons. Data migration revealed 20-year-old file formats that even AutoCAD had forgotten existed. Configuration needed iteration. Business users had to be more involved in the process. But the outcome was clear: “Now I have a validated system,” Kastle said. “We have version control. We have a centralized source of truth.”
Top 10 Must-Have EDMS Capabilities for Pharmaceuticals and Life Sciences
Whether you're evaluating platforms or justifying a switch, here are the 10 top features to prioritize:
With these features built in, an EDMS is more than a passive repository of documents; it becomes a proactive compliance tool.
The Bottom Line
If Schering-Plough had used a validated EDMS like Adept back in 2002, it might have:
Adept isn’t just a document management system—it’s a strategic enabler of digital transformation, operational excellence, and regulatory resilience.
The ROI of Getting Document Management Right
An EDMS is more than a compliance requirement—it’s a strategic enabler. Consider these returns: