Академический Документы
Профессиональный Документы
Культура Документы
IN VALIDATION
• Separate department
• Identified part of validation
• Functional part of validation
• Identified part of QA
• Functional part of QA
• Other
CHANGE MANAGEMENT PROBLEMS
PLEASE PARTICIPATE
CHANGE MANAGEMENT STRATEGY AND
APPROACH
• Lifecycle approach
• Science and technical basis
• Uniform approach to all validation /
qualification
• Documentation consistency
• Infrastructure – Organization structure,
approval committee, quality system
management, culture
LIFECYCLE APPROACH
• FDA Guidance
• Application to equipment, facilities, systems,
others
– Manufacturing process validation
– Other processes: Cleaning, packaging, analytical
– Equipment “processes:” Purified Water, HVAC
– Equipment
– Quality systems
• Stage expectations
LIFECYCLE APPROACH TO PROCESS VALIDATION
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VALIDATION PRINCIPLES
• Validation is confirmation.
• Successful performance is assumed
• Scientific and technical basis -- statistical data treatment
• Validated processes, equipment, utilities, computer systems,
others
• Three validation stages Process improvements
• Minimize variation and variation control plan
• Appropriate for associated risk
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PROCESS VALIDATION AND QUALIFICTION
Process Validation – Process Qualification
PV -- PQ -- PPQ
Qualification Qualification
Equipment #1 HVAC
Utilities
Equipment #2 Facilities
Computers
Equipment #3
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LIFECYCLE APPROACH TO PROCESS VALIDATION
FDA, 2011
Definition: Collection and evaluation of data, from the process design stage
throughout commercial production, which establishes scientific evidence
that a process is capable of consistently delivering quality products.
Process validation involves a series of activities over the lifecycle of the
product and process.
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LIFECYCLE APPROACH RESPONSIBILITIES
NEW PARADIGM
INTEGRATED ORGANIZATIONAL APPROACH
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STAGE 1: QUALITY BY DESIGN (QbD)
Quality target product profile (QTTP)
Critical quality attributes (CQA)
Critical material attributes (CMA)
Critical process parameters (CPP)
Design space
Scale-up and technology transfer
Identify input variables
Input variable control strategy
Continuous improvement
Other considerations: PAT, risk analysis
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STAGE 2: DEMONSTRATION
Process Performance Qualification (PPQ)
• Confirm the process design and development work
• Demonstrate that the commercial manufacturing
process performs as expected.
• Based on sound science and experience.
• Higher level of testing and sampling.
• Process is reproducible and will consistently deliver
quality products.
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STAGE 3: MONITORING AND MAINTENANCE
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VALIDATION PHILOSOPHY
• Validation is confirmation.
• Acceptable (passing) results are expected.
• Validation is not
– R&D
– Final stage of development process
– Optimization
– Fine-tuning
– Debugging
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VALIDATION HISTORY AND EVOLUTION
1978
GMP includes Validation.
1987
Development VALIDATION Control
2008-2011
Lifecycle approach
UNDERSTANDING PQ MONITORING
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VALIDATION CHANGE INITIATION
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VALIDATION INITIATION OUTLINE / TEMPLATE
• Objective of validation
• Why needed?
• Impact of validation
– Risk analysis
• Why acceptable?
– Compliance to internal requirements, policies, engineering standards, etc.
– Regulatory impact (Prior approval, CBE, CBE30, etc.)
– Other systems or product impacted
– Procedure changes or other document changes
– Notifications to affected groups (internal, external, labs)
• Validation Plan -- Approach to accomplish validation
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VALIDATION INITIATION -- PROBLEMS
• Inconsistent content
– Form with standardized information needed – outline sections
• Poorly written
– Inadequate information
• Prematurely written
– Written to meet business goals
– Written to demonstrate future intent
• Amendments necessary -- changes usually required
Validation initiations should be submitted for approval only after
objective and scope of validation is determined and work
details (risk/testing/sampling) determined.
Amendments are a planning failure regardless of justification.
HAVE MODEL DOCUMENTS AVAILABLE
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VALIDATION INITIATION SUMMARY
• Establish template for all validation /
qualification
• Minimize writing
• Simple words, simple sentences
• Clear and concise.
• Provide details in Validation Plan
• Checklist for specific types of validation
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CHECKLIST EXAMPLE: PRODUCT / PROCESS DESIGN INFORMATION
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CHECKLIST EXAMPLE: EQUIPMENT
• Introduction
• Technical information
• Validation strategy and testing
• Validation documentation
• References
VALIDATION PLAN
MOST IMPORTANT DOCUMENT
OUTLINE
• Introduction
• Technical information
– Validation pre-work references
• Validation strategy and testing
• Validation documentation
– List of required protocols, reports, procedures, etc.
– Validation post-work requirements
– Administrative benefit
• References
– List of reports and scientific references (including Stage 1 reports)
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VALIDATION DOCUMENT CONTINUUM
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VALIDATION PLAN
INTRODUCTION
• Overview describing validation / product / process /
equipment / etc. (consistent with request)
• Requirements to complete validation
– Conformance to regulations and internal policy
– Impact of change to maintain the validated state
– Impact on regulatory submission
– Impact of change on procedures, drawings, other documents
– Notifications to other areas internal and external (e.g., environmental
agency, internal test labs) impacted by validation
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VALIDATION PLAN
TECHNICAL INFORMATION
• Basic product / process / equipment description
– Formula
– Process
– Specifications
– Include non-technical description information
• Technical aspects of validation / qualification
• Reference to technical reports from Stage 1
• Total validation approach
– Experimental studies
– Past data (retrospective data)
– Validation protocols
– Other work
– New procedures
• Number of lots – related to impact of change and risk
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VALIDATION PLAN
VALIDATION STRATEGY AND TESTING
• Prospective validation only
• Types of testing -- general
– Regulatory specifications
– Internal controls
– Process tests
• Tests and rationale – general
– Address changes – based on risk analysis
• Sampling and rationale – general
– Exceed routine QA testing – based on impact and risk analysis
• Data treatment – general
– Statistical data treatment and confidence limits
• Acceptance criteria – general
• Post-validation testing (Stage 3)
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VALIDATION SAMPLING
What is routine QA sampling?
Impact of change
• High impact
• Medium impact
• Low impact
• No impact
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VALIDATION POST-WORK
Activities to be done post-validation
• New drawings and drawing updates
• Calibration changes
• Preventive maintenance changes
• Operations manual changes
• SOP changes
• Others
VALIDATION PLAN
VALIDATION DOCUMENTATION
List all documents required to complete validation
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VALIDATION PLAN
REFERENCES
• R&D Reports
– R&D reports
– QbD required documents
• Development and analytical reports
• Published literature
Scientific and technical support to validation plan
Report copies should be stored in validation area or
readily accessible (within 30 minutes)
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VALIDATION DOCUMENT APPROVAL
VALIDATION APPROVAL COMMITTEE (VAC)
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INFRASTRUCTURE
• Documentation format
• Document up authors – training
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VALIDATION DOCUMENT APPROVAL
Technical validation
• Scientific and technical principles
• Consistent approach
• Supports objective of validation
• Supports routine manufacturing in type of testing and
sampling
• Support routine manufacturing in duration of sampling and
testing
• Results and discussion support data
• Correct technical conclusions
• Equipment testing support entire operating range used in
manufacturing
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VALIDATION APPROVAL COMMITTEE
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OTHER APPLICATIONS
• Other processes
• Equipment “processes”
• Equipment / facilities/utilities/control
systems, etc. qualifications
• Quality systems.
MANAGEMENT RESPONSIBILITY
VALIDATION QUALITY SYSTEM
LIFECYCLE APPROACH
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QbD and VALIDATION QUALITY SYSTEM
Objectives
• Validation business process performance excellence
Validation quality system attributes
• Business process performance attributes
Validation quality system parameters
• Business process performance
Variation and control
• Business system procedures and training
Risk management
• Highest risk activities prioritized
Validation quality system improvement
• Improvements based on evaluation activities
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VALIDATION QUALITY SYSTEM BUSINESS PROCESS
PROJECT INITIATION, DESIGN, AND DEVELOPMENT BY SITE FUNCTION (STAGE 1)
1. Validation provides information on future needs in support of PQ
2. Validation receives / accesses recommended documents
PROCESS QUALIFICATON (PQ – STAGE 2)
3. Validation initiation – Sources of requests
4. VAC approval
5. Protocol written
6. VAC approval
7. Test results and post-validation recommendations
8. VAC approval
9. Validation administrative closure
10. Document storage
POST VALIDATION (STAGE 3)
11. Post-validation protocol initiation
12. VAC approval
13. Test results
14. VAC approval
15. Validation administrative closure
16. Document storage
17. Monitor validated process, EFU, etc. performance
18. Validation reviews – Deviations, CAPA, etc.
IMPROVEMENT PROJECTS
19. Initiate validation improvement project
20. Complete validation improvement project including implementation
21. Complete validation change project
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VALIDATION QUALITY SYSTEM BY DESIGN
LIFECYCLE APPROACH
INITIATION, DESIGN, AND DEVELOPMENT
1. Objective
2. Attributes and parameters
3. Variation and control of variation
4. Risk analysis
5. Monitoring
PROCESS QUALIFICATION
1. Objective
2. Attributes and parameters
3. Variation and control of variation
4. Risk analysis
5. Monitoring
POST VALIDATION
1. Objective
2. Attributes and parameters
3. Variation and control of variation
4. Risk analysis
5. Monitoring
IMPROVEMENT PROJECTS
1. Objectives
2. Performance and implementation,
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QbD APPROACH TO VALIDATION QUALITY SYSTEM –
BUSINESS PROCESS
Objectives
– What are the goals of each process step?
Attributes
– What makes a process step successful?
Parameters
– What factors significantly influence the success of the process step?
Variation and control of variation
– What variation in performance is expected and how is it controlled?
Risk management
– What are highest risk activities?
– Prioritization, evaluation, and review highest level for highest risk
Evaluation
– Review performance of validation quality system and subsystems
– Review performance of validatd processes, EFU, etc.
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VALIDATION QUALITY SYSTEM -- PROBLEM EXAMPLES
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VALIDATION QUALITY SYSTEM –
CORRECTIVE ACTION PROJECTS
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PROBLEM SOLVING APPROACHES
“No change” evaluations
• Example: Motor “like-for-like changes”
• Multiple problem examples
• Must check installation
– Emergency changes
• No records – “We always do it this way.”
Paul L. Pluta, PhD
Editor-in-Chief
Journal of Validation Technology
Journal of GXP Compliance
Associate Professor of Biopharmaceutics
University of Illinois at Chicago (UIC)
College of Pharmacy, Chicago, IL, USA
Industry experience
Contact: ppluta@uic.edu