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Describing writing actions in biopharmaceutical regulatory submission documents

4/3/2025

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originally posted to LinkedIn July 2023

Been a bit since I’ve posted an article here on LinkedIn. My wheels are still turning on thoughts about writing in the biopharmaceutical space. Perhaps the wheels are turning just a little slower. But, at least the wheels still turn!!

Purpose of this article is to share some thoughts on writing actions that should happen within biopharmaceutical research reports and keystone regulatory submission documents. These are the actions that enable a document to be considered a high-quality communication platform. For each action, I present the associated parameter that describes the action.

Please take 5 minutes to read through this list and if you have further time, please share your comments on the merits of what I have compiled as descriptors of writing actions.

Analyze
  • Take apart some complex factor/phenomenon to understand the important elements, identify dependencies, establish trends, or make predictions.
Argue
  • Take a position or make a claim and support it with data, evidence, and logical reasoning.
Assess
  • Form a judgment based on evidence as to whether an interpretation or action is logically justified.
Compare
  • Discuss two or more elements of information to assess the degree of agreement or disagreement in their design, execution, or results.
Be concise
  • Communicate efficiently, avoiding unnecessary repetition, wordiness, or ambiguity.
Critically analyze
  • Discuss strengths and weaknesses of current understanding, taking positions on the reliability, strength, limitations, and quality of the supporting data. A critical analysis might systematically assess an explanation, theory, argument, data set, study, or comprehensive set of studies.
Describe
  • Identify key features, qualities, actions, and decision-making so a reader has a good understanding of what was done and why.
Discuss
  • Argue for what is most important or relevant to the case at hand, highlighting strengths and weaknesses, addressing counter arguments, or presenting alternative interpretations.
Evaluate
  • Assess the quality of data based on adequate study design, study execution, robustness or consistency of findings, reliability, usefulness, significance, or relevance to real world application.
Integrate
  • Compare results from two or more research studies to discuss common or divergent patterns in the data.
Interpret
  • Form a position on how to understand research results based on statistical and logical analysis.
Narrate
  • Comment on important understandings regarding conduct of research and output of research. Narration might focus on critical data points, specific cases, outliers, expected or unexpected findings, or unexplained results.
Overview
  • Provide a high-level introduction to document content at the section and subsection to help a reader orient to the most important understandings. Overviews establish purpose, scope, and sequence for a section or subsection.
Rationalize
  • State the logic motivating interpretations, decisions, or actions.
Summarize
  • Present findings in a discrete manner with a focus main points, key arguments, and significant data.
Synthesize
  • Pull together information from various sources to integrate into a comprehensive whole. Draw connections between ideas, and communicate complex information in a clear and coherent manner to build a logical argument or to establish a new conceptual understanding.
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Workshop Date Changed to October 29-31

8/9/2019

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The Optimizing Medical Writing for the Regulatory Reader Workshop will now be held 29-31 October in Copenhagen. More information on this three-day workshop can be found at the Atrium website: https://www.atriumcph.com/course/Optimizing-Medical-Writing-for-the-Regulatory-Reader/56871
Watch for the full program announcement from Atrium. In interim, here’s the “thumbnail” overview of our course:
Day 1
  • Explore how technology is impacting document design in 2019 and beyond
  • Describe the reading persona for the decision-making regulatory reader
  • Characterize and consider meaningful document quality standards that impact communication performance
  • Recognize and analyze organization patterns and strategies to use in regulatory documents at the report and summary level
Day 2
  • Characterize writing strategies for information design in reports, briefing books, and summary documents
  • Consider best practice strategic review and how to get it from your teams
  • Apply review techniques to be a surrogate for the end-user
Day 3
  • Consider the medical writer in managing statistical outputs
  • Discuss how tools and resources can help economize writing and optimize communication quality
  • Examine and discuss text examples at the report and summary level of writing
  • Consider the medical writer in project management
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New Public Workshop Announced

4/17/2019

3 Comments

 
I will be co-facilitating Optimizing Medical Writing for the Regulatory Reader in Copenhagen in August. This will be a three-day public workshop that will allow attendees time to dive deep into the topic with expanded discussions and group exercises using case study documents. More details can be found on my LinkedIn page or on Atrium's registration page.
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Document Review

3/7/2019

4 Comments

 
Document review in pharma and medical device enterprises is a system of diverse and complex functions that requires proficiency in technology, process discipline, and most importantly intellectual capital.

In terms of technology, there is the management and optimization of the review platform capabilities, the appropriate use of technology assisted review, and effective data security controls throughout the documentation life cycle.

As we think of process discipline, there is the need for various robust policies and procedures and a commitment at a senior level to execute those policies and procedures consistently and effectively. Additionally,  there is the need to carefully consider the right time/correct role deployment of people during the various reviews.

As for intellectual capital, I mean there is effective knowledge transfer; knowledge retention; learning, training, technological, statistical, and linguistic acumen applied to every round of review. In essence, the careful curation of document review expertise.

Taking a hard look at review, there are a lot of moving parts and as time lines are reduced and the scale and complexity of document platforms rise, the need for a well-functioning environment rises exponentially and perhaps even geometrically.

From my perspective, this means, the value of organizational competence in document review as denoted by process maturity far exceeds the value of the component parts (people, process, technology). In short, the best technology (if one exists) and the “best” people may be utilized, but if the organizational vision within which they operate is deficient, the result will most likely be sub-optimal. It is process maturity that provides the framework in which the contribution of people and technology can excel or be inhibited.

When it comes to document review in pharma and medical device, I keep thinking about Peter Senge's comment: “Organizations break down, despite individual brilliance and innovative products, because they are unable to pull their diverse functions and talents into a productive whole.”

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Why Things Are This Way: The Excessive Use of Passive Voice in Science Writing

5/2/2016

2 Comments

 
It has been some time since I last posted here on the McCulley/Cuppan blog. Just like some other things in my life, I simply got out of the habit. So, like my physical workouts, I am looking to make blog posts a more regular part of my life.

With that said, onto the question I want to consider in this post--why are most research documents that cross my computer screen written in the passive voice? Literally,  many, if not all of the clinical research reports, much of the regulatory documentation, and painfully all of the clinical research protocols are written in the passive voice.

Why do I even bring this topic up? Well, some researchers in the academic community feel that the use of the passive voice (verbs that do not indicate who or what is doing the action) can lead to writing where the sources or agents of action are not clear. This is my big criticism of protocols, a class of documents centered on characterizing events and agents. 

These writing researchers also comment that repeated use of the passive voice results in texts, which are “flat and tedious” to read. From my very subjective perspective, I have to agree with that last comment as I have certainly seen my share of documents that fit this description. 

It is worth noting here too that reading research shows most readers prefer active voice, especially readers for whom English is not their mother tongue.

The point of this blog is not a grammar lesson (trust me I’d never do that as I almost fall asleep from boredom when someone mentions the word grammar.) But just to be sure we are all on the same page by what I mean with ‘passive voice’ versus ‘active voice’; here is my explanation in a nutshell:
  • In the active voice, the agent performing the action is the grammatical subject of the sentence and the recipient of the action is the grammatical object.
  • The passive voice switches this around, making the recipient of the action the grammatical subject and the agent the object if the agent is even included.


Passive sentences that I read by the truck load contain phrases such as these:
  • The three arms in the study will be…..
  • Training on diary completion will be provided to patients…..


The worst abuse of passive voice is the heavy use of state-of-being verbs combined with past tense: (is, was, be) + (past tense) like the following examples:
  • PDGF and its receptor (PDGFR) have been implicated in the pathobiology of pulmonary hypertension in animal studies……….
  • Wonderdrug has been shown to be an effective treatment in XX disease.
  • The molecular constructs most effective for PI3K/AKT/MTOR pathway inhibition were shown to be.......
  • Mortality at 24 weeks after first dose was to be ascertained for………
Unfortunately, it is way too common in protocol writing for the author to utilize passive voice and fail to explicitly mention who will perform the act. Often the all-important agent is missing from the discussion and the reader must interpret who is the agent of a specified task. In numerous instances this will not be problematic, but in other cases it can cause confusion that leads to inquiries or missed tasks.

So back to the point of this discussion. I ask this question about the habitual use of the passive voice because many science journals, like Nature, and most of the leading style guides recommend the active voice over the passive voice. So if the top-flight journals like Nature and the leading style guides like the Chicago Manual of Style recommend writing in the active voice, then why do people working in pharmaceutical and medical device companies still demand passive voice as the default style pathway?

When I ask people in the workshops I teach at various pharmaceutical and medical device companies why they slavishly write in passive voice, the answers range from: “I did not know that is the style I was using.” to “This is the way science must be written.” Ignorance is never an acceptable excuse, but to invoke the need to meet some mythical style-standard is absurd. The slavish use of the passive voice in science writing is a self-maintained and mutually-committed act drawn from a fairy tale. I use the term fairy tale here with careful consideration. Fairy tales are about imaginary worlds. Hereto we have a situation where people imagine what readers want and prefer and routinely invoke the imaginary in defense of their personal or organizational belief system about high quality scientific writing.

From my perspective, the two leading reasons that the passive writing style is so broadly applied are:
  1. Many writers have only read documents written in this style and are formally and informally conditioned to replicate the style. A prevalent form of conditioning is teachers in the sciences, at levels of the academic system, who demand their students write applying the passive voice style.
  2. The power of precedence—what we did previously was accepted or published; therefore it had to be good. So make this document look, taste and smell like the previous ones.
The bottom line is writing in this style is a habit and a bad habit at that.

I am working my way through some papers addressing the psychological mechanisms that form and maintain habits in work groups and organizations. Now I am looking for references related to the meaningful steps necessary to mitigate or eliminate these habits. When and if I find an effective elixir for this bad writing habit, I will let you know.
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    Author

    Gregory Cuppan is the Managing Principal of McCulley/Cuppan Inc., a group he co-founded. Mr. Cuppan has spent 30+ years working in the life sciences with 20+ years providing consulting and training services to pharmaceutical and medical device companies and other life science enterprises.

    View my profile on LinkedIn

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