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4/3/2015 1
This presentation is compiled from freely available
resources like the website of EU, specifically
“EU GMP Guide-Annex 15
Qualification & Validation”
“Drug Regulations” is a non profit organization
which provides free online resource to the
Pharmaceutical Professional.
Visit http://www.drugregulations.org for latest
information from the world of Pharmaceuticals.
4/3/2015 2
Drug Regulations : Online
Resource for Latest Information
 Updated version of Annex 15
◦ Qualification and Validation
 Draft released in February 2014
 Final version released on the 30th of March ,
2015
 Will be effective on 01 October 2015
4/3/2015 3
 May be used as supplementary optional guidance for
active substances without introduction of additional
requirements to EudraLex, Volume 4, Part II.
 Retrospective validation is no longer an acceptable
approach
 The term “validation” has been replaced with
“qualification and validation” to reflect the true intent
of the Annex 15 in several instances
4/3/2015 4
 An “equivalent document” to a VMP may be
used for qualification and validation planning
 VMP no longer needs to include
◦ Protocol and report templates,
◦ scheduling and planning information
◦ Confirmation of materials and suppliers used
4/3/2015 5
 For large and complex projects separate
validation plans may be used
 The importance of Quality Risk Management is
evident
 Risk assessment to be repeated if further
knowledge and understanding is gained from any
changes during the project phase or during
commercial production,
4/3/2015 6
 Data integrity is also mentioned were
“appropriate checks” needs to be built into
qualification and validation tasks “to ensure
the integrity of all data obtained”.
4/3/2015 7
 Current version of Annex 15 of the EU Guide
to GMP
◦ Originally published in September 2001
◦ Significant changes in the GMP environment
◦ Advancements in manufacturing technology and
continuous manufacture processes.
4/3/2015 8
◦ Many changes to other Chapters and Annexes which have
an impact on Annex 15
◦ Current version of the US FDA Guide on Process Validation,
◦ Approaches in ASTM E2500-07 “Standard Guide for
Specification, Design, and Verification of Pharmaceutical
and Biopharmaceutical Manufacturing Systems and
Equipment “
 All the above has justified the change
4/3/2015 9
 This revision to Annex 15 takes into account
◦ Changes to Other sections of the EudraLex, Volume 4,
Part I
◦ Relationship to Part II
◦ Annex 11
◦ ICH Q8, Q9, Q10 and Q11
◦ QWP guidance on process validation
◦ Changes in manufacturing technology
4/3/2015 10
 Annex describes
 Principles of Qualification and Validation
 Applicable to
◦ Facilities
◦ Equipment
◦ Utilities and processes
◦ Manufacture of medicinal products
 May also be used as supplementary optional guidance for active
substances without introduction of additional requirements to
EudraLex, Volume 4, Part II
4/3/2015 11
 Qualification & Validation
◦ GMP requirement
◦ Control critical aspects of particular operations
◦ Applicable over the life cycle of product and process
◦ Document any planned changes to the facilities,
equipment, utilities and processes, which may affect
the quality of the product, and the impact on the
validated status or control strategy assessed.
4/3/2015 12
 Qualification & Validation
◦ Validate computerised systems :Annex 11.
◦ Use concepts and guidance of ICH Q8, Q9,
Q10 and Q11
4/3/2015 13
 Qualification & Validation
◦ Apply quality risk management approach throughout
the lifecycle
◦ Determine scope and extent of qualification and
validation on risk assessment of the facilities,
equipment, utilities and processes.
◦ Document the risk assessment
◦ Retrospective validation is no longer considered an
acceptable approach.
4/3/2015 14
 Qualification & Validation
◦ Data obtained from sources outside of the
manufacturers own programmes
 May be used
 Justify this approach
 Adequate assurance that controls were in place
throughout the acquisition of such data.
4/3/2015 15
 Qualification & Validation
◦ Plan all activities
◦ Implement the life cycle approach
◦ Consider
 Facilities
 Equipment
 Utilities
 Process
 Product
4/3/2015 16
 Qualification & Validation
◦ Performed by suitably trained personnel
◦ Follow approved procedures
◦ Qualification/validation personnel should report as defined in
the pharmaceutical quality system
◦ Not essential to be a quality management or a quality
assurance function.
◦ Appropriate quality oversight over the whole validation life
cycle is essential
4/3/2015 17
 Qualification & Validation
◦ Define key elements of the site qualification and
validation
◦ Document in a validation master plan (VMP) or
equivalent document.
4/3/2015 18
 Qualification & Validation
◦ VMP or equivalent document
◦ Define qualification/validation system
◦ Include or reference information on at least the
following:
4/3/2015 19
 Qualification & Validation
 Include or reference information on at least the following:
◦ Qualification and Validation policy
◦ Organisational structure
◦ Roles and responsibilities for qualification and validation
activities
4/3/2015 20
 Qualification & Validation
 Include or reference information on at least the following:
◦ Summary of the facilities, equipment, systems, processes on site
◦ Qualification and validation status
◦ Change control and deviation management for qualification and
validation
◦ Guidance on developing acceptance criteria
◦ References to existing documents
◦ Strategy, including requalification, where applicable
4/3/2015 21
 Qualification & Validation
◦ For large and complex projects,
◦ Added importance to planning
◦ Separate validation plans may enhance clarity
4/3/2015 22
 Qualification & Validation
◦ Use quality risk management approach
◦ Repeat Risk assessment with increased knowledge & Changes
 Project Phase
 Commercial Phase
◦ Document the way in which risk assessments are used
4/3/2015 23
 Qualification & Validation
◦ Incorporate appropriate checks
◦ Ensure the integrity of all data obtained
4/3/2015 24
 Good Documentation Practices
 Important to support knowledge management
 Implement throughout the product lifecycle
 All documents should be approved and authorised by appropriate
personnel as defined in the pharmaceutical quality system.
 Define the inter-relationship between documents in complex validation
projects
 Prepare validation protocols which defines the critical systems,
attributes and parameters and the associated acceptance criteria.
4/3/2015 25
 Good Documentation Practices
 Documents may be combined together, where
appropriate
 e.g. installation qualification (IQ) and operational
qualification (OQ).
4/3/2015 26
 Good Documentation Practices
 Any significant changes to the approved protocol during
execution
 Acceptance criteria
 Operating parameters
 Document as a deviation
 Justify scientifically
4/3/2015 27
 Good Documentation Practices
 Record results not meeting pre-defined acceptance criteria
as a deviation
 Investigate all devotions
 Discuss any implications for the validation in the report
4/3/2015 28
 Good Documentation Practices
 Each stage should have a formal release before proceeding to next
stage
 Release should be authorised by relevant responsible personnel
 Release may be a part of validation report or as a separate summary
document
 Conditional approval to proceed to the next qualification stage
possible when
 Certain acceptance criteria or deviations have not been fully addressed
 There is a documented assessment that there is no significant impact on
the next activity.
4/3/2015 29
 Qualification activities
 Consider all stages
 Initial development of the user requirements
specification through to End of use of the
equipment, facility, utility or system.
4/3/2015 30
 The main stages and some suggested criteria
which could be included in each stage are
indicated in subsequent slides:
 although this depends on individual project
circumstances and may be different
4/3/2015 31
 User requirements specification (URS)
 Define specification in a URS and/or a functional specification for
 Equipment
 Facilities
 Utilities or systems
 The essential elements of quality need to be built in at this stage
 GMP risks if any should be mitigated to an acceptable level.
 URS should be a point of reference throughout the validation life
cycle.
4/3/2015 32
 Design qualification (DQ)
 The next element in the qualification of equipment,
facilities, utilities, or systems
 Demonstrate compliance of the design with GMP
 Document compliance
 Verify requirements of the user requirements
specification during the design qualification.
4/3/2015 33
 Factory acceptance testing (FAT) /Site acceptance
testing (SAT)
 Equipment may be evaluated at the vendor prior to
delivery.
 Confirm compliance with URS/functional specification
prior to installation at the vendor site
4/3/2015 34
 Factory acceptance testing (FAT) /Site acceptance
testing (SAT)
 Documentation review & some tests could be
performed at the FAT or other stages
 These tests need not be repeated on site at IQ/OQ if
functionality is not affected by transport and
installation.
4/3/2015 35
 Factory acceptance testing (FAT) /Site acceptance
testing (SAT)
 FAT may be supplemented by the execution of a SAT
following the receipt of equipment at the
manufacturing site.
4/3/2015 36
 Installation qualification (IQ)
 Perform IQ on
 Equipment
 Facilities
 Utilities
 Systems.
4/3/2015 37
 Installation qualification (IQ)
 IQ should include, but is not limited to the following:
 Verification of the correct installation of components,
instrumentation, equipment, pipe work and services against the
engineering drawings and specifications;
 Verification of the correct installation against pre-defined criteria;
 Collection and collation of supplier operating and working
instructions and maintenance requirements;
 Calibration of instrumentation
 Verification of the materials of construction.
4/3/2015 38
 Operational qualification (OQ)
 OQ normally follows IQ
 May be performed as a combined
Installation/Operation Qualification (IOQ).
 Depends on the complexity of the equipment
4/3/2015 39
 Operational qualification (OQ)
 OQ should include but is not limited to the
following:
 Tests that have been developed from the knowledge of
processes, systems and equipment to ensure the
system is operating as designed;
 Tests to confirm upper and lower operating limits, and
/or “worst case” conditions.
4/3/2015 40
 Performance qualification (PQ)
 PQ should normally follow the successful
completion of IQ and OQ.
 Could also be performed in conjunction with OQ or
Process Validation.
4/3/2015 41
 Performance qualification (PQ)
 PQ should include, but is not limited to the following:
 Tests using
 Production materials,
 Qualified substitutes or
 Simulated product proven to have equivalent behaviour
 Normal operating conditions
 Worst case batch sizes.
 Justify the frequency of sampling used to confirm process
control
4/3/2015 42
 Performance qualification (PQ)
 PQ should include, but is not limited to the
following:
 Tests should cover the operating range of the intended
process
 No need for this if documented evidence from the
development phases confirming the operational ranges is
available.
4/3/2015 43
 RE-QUALIFICATION
 Evaluate at an appropriate frequency to confirm that
following remain in a state of control
 Equipment
 Facilities
 Utilities
 Systems
4/3/2015 44
 RE-QUALIFICATION
 Justify requalification period
 Define criteria for reevaluation
 Assess the possibility of small changes over time
4/3/2015 45
 General Principles
 Applicable to the manufacture of all pharmaceutical
dosage forms.
 Initial validation of new processes
 Subsequent validation of modified processes
 Site transfers and ongoing process verification
4/3/2015 46
 General Principles
 Robust product development process required to
enable successful process validation
 This guidance should be used in conjunction with the
current EMA guideline on Process Validation for Finished
Products.
4/3/2015 47
 General Principles
 Guideline on Process Validation for Finished Products (LINK)
 Guidance on information and data to be provided in the
regulatory submission only.
 However GMP requirements for process validation continue
throughout the lifecycle of the process
 Apply this approach to link product and process
development.
4/3/2015 48
 General Principles
 Manufacturing processes may be developed using a
 Traditional approach
 Continuous verification approach
4/3/2015 49
 General Principles
 Before any product is released to the market &
irrespective of the approach used
 Processes must be shown to be robust
 Ensure consistent product quality
4/3/2015 50
 General Principles
 Traditional approach
 Only prospective validation programme prior to
certification of the product.
 Retrospective validation is no longer an acceptable
approach.
4/3/2015 51
 General Principles
 New products
 Cover all intended marketed strengths
 Cover all sites of manufacture
 Bracketing could be used. Justify based on
 Extensive process knowledge from the development stage
 An appropriate ongoing verification programme
4/3/2015 52
 General Principles
 Site Transfer
 Transferred from one site to another
 Within the same site,
4/3/2015 53
 General Principles
 Site Transfer
 Number of validation batches could be reduced by the use of a
bracketing approach. Justify based on
 Existing product knowledge,
 Content of the previous validation
 Use bracketing for
 Different strengths
 Batch sizes
 Pack sizes
 Container types
4/3/2015 54
 General Principles
 Site Transfer of Legacy products
 Manufacturing process and controls must comply with
the marketing authorisation
 Meet current standards for marketing authorisation for
that product type.
 If necessary, variations to the marketing authorisation
should be submitted.
4/3/2015 55
 General Principles
 Attributes and parameters
 Important for ensuring the validated state and
acceptable product quality
 Process validation should establish whether these can
be consistently met by the process
 Document the basis for identifying criticality of
parameters & attributes
4/3/2015 56
 General Principles
 Process validation batches
 Same size as the intended commercial scale
batches
 Justify use of any other batch sizes
4/3/2015 57
 General Principles
 Development studies & Process knowledge
 Basis of all validation activities
 For all products
 Irrespective of validation
 Should be accessible to the manufacturing site,
 Other wise justify
4/3/2015 58
 General Principles
 Process validation batches
 Production personnel
 Development personnel
 Other site transfer personnel
 Use only trained personnel
 Manufacture in accordance with GMP
 Use approved documentation
 Production personnel should facilitate product
understanding
4/3/2015 59
 General Principles
 Qualify suppliers of critical starting and packaging
materials prior to manufacture
 Otherwise
 Justify based on of quality risk management
principles
 Document justification
4/3/2015 60
 General Principles
 Design Space & Mathematical Models
 Could be used for Process control strategy
 Following should be available
 Underlying process knowledge
 Development of any mathematical models
 Justification
4/3/2015 61
 General Principles
 Release of Validation batches to the Market
 Pre-define
 Manufacture should fully comply with
 GMP
 Validation acceptance criteria
 Continuous process verification criteria (if used)
 Marketing authorisation
 Clinical trial authorisation.
4/3/2015 62
 General Principles
 Investigational medicinal products (IMP),
 Refer to Annex 13.
4/3/2015 63
 Concurrent validation
 Routine production starts before completion of validation
 Concurrent validation can be used under exceptional
circumstances
 A strong benefit-risk ratio for the patient required
 Justify decision to carry out concurrent validation
 Document the decision in the VMP for visibility
 Decision should be approved by authorised personnel
4/3/2015 64
 Concurrent validation
 Have sufficient data to support a conclusion that
 Any given batch of product is uniform
 Meets the defined acceptance criteria.
 Document the results and conclusion formally
 Document should be available to the Qualified Person
prior to certification of the batch
4/3/2015 65
 Traditional process validation
 Number of batches of the finished product are
manufactured under routine conditions to confirm
reproducibility.
4/3/2015 66
 Traditional process validation
 Number of batches manufactured & Number of
samples taken
 Use Quality Risk Management principles
 Allow the normal range of variation and trends to be
established
 Provide sufficient data for evaluation.
4/3/2015 67
 Traditional process validation
 Number of batches manufactured & Number of
samples taken
 Determine and justify the number of batches necessary to
demonstrate a high level of assurance that the process is
capable of consistently delivering quality product.
4/3/2015 68
 Traditional process validation
 Generally acceptable
 Without prejudice to earlier requirement
 Minimum of three consecutive batches manufactured
under routine conditions could constitute a validation
of the process
4/3/2015 69
 Traditional process validation
 Generally acceptable
 Alternative number of batches may be justified based
on
 Whether standard methods of manufacture are used
 Whether similar products or processes are already
used at the site.
4/3/2015 70
 Traditional process validation
 Generally acceptable
 Supplement an initial validation exercise with three
batches with further data obtained from subsequent
batches as part of an on-going process verification
exercise.
4/3/2015 71
 Traditional process validation
 Process validation protocol should be prepared
which defines
 Critical process parameters (CPP),
 Critical quality attributes (CQA)
 Associated acceptance criteria
 Base this on development data or documented
process knowledge.
4/3/2015 72
 Traditional process validation
 Process validation protocols should include, but are
not limited to the following:
1. A short description of the process and a reference to
the respective Master Batch Record;
2. Functions and responsibilities;
3. Summary of the CQAs to be investigated;
4. Summary of CPPs and their associated limits;
4/3/2015 73
 Traditional process validation
 Process validation protocols should include, but are not limited
to the following:
4. Summary of other (non-critical) attributes and parameters which
will be investigated or monitored during the validation activity,
and the reasons for their inclusion;
5. List of the equipment/facilities to be used (including
measuring/monitoring/recording equipment) together with the
calibration status;
6. List of analytical methods and method validation, as appropriate
4/3/2015 74
 Traditional process validation
 Process validation protocols should include, but are not
limited to the following:
7. Proposed in-process controls with acceptance criteria and
the reason(s) why each in-process control is selected;
8. Additional testing to be carried out with acceptance criteria;
9. Sampling plan and the rationale behind it;
10. Methods for recording and evaluating results;
11. Process for release and certification of batches (if applicable)
4/3/2015 75
 Continuous process verification
 Can be used as an alternate approach for traditional
process validation for
 Products developed by a quality by design approach
 Scientifically established control strategy during
development
 A strategy which provides a high degree of assurance
of product quality
4/3/2015 76
 Continuous process verification
 Define the method by which the process will be verified
 Put in place a science based control strategy for the
required attributes to confirm product realisation for
 Incoming materials
 Critical quality attributes
 Critical process parameters
4/3/2015 77
 Continuous process verification
 Put in place a science based control strategy for the
required attributes to confirm product realisation
 Include regular evaluation of the control strategy.
 Process Analytical Technology and multivariate
statistical process control may be used as tools.
4/3/2015 78
 Continuous process verification
 Determine and justify the number of batches necessary
to demonstrate a high level of assurance that the
process is capable of consistently delivering quality product.
 The general principles presented earlier still apply.
4/3/2015 79
 Hybrid approach
 A hybrid of the traditional approach and continuous
process verification approach
 Could be used where there is
 Substantial amount of product and process knowledge
 Understanding which has been gained from manufacturing
experience and historical batch data.
4/3/2015 80
 Hybrid approach
 Could be used
 Even if the product was initially validated using a traditional
approach
 For any validation activities after changes
 During ongoing process verification
4/3/2015 81
 Ongoing Process Verification during Lifecycle
 Applicable to all three approaches to process validation
mentioned earlier, i.e.
 Traditional,
 Continuous or
 Hybrid.
4/3/2015 82
 Ongoing Process Verification during Lifecycle
 Monitor product quality
 Ensure that a state of control is maintained
throughout the product lifecycle
 Evaluate relevant process trends
4/3/2015 83
 Ongoing Process Verification during Lifecycle
 Periodically review extent and frequency of
ongoing process verification.
 Any point during the life cycle appropriate to
modify the requirements taking into account the
current level of process understanding and
process performance.
4/3/2015 84
 Ongoing Process Verification during Lifecycle
 Conduct under an approved protocol or equivalent
documents
 Prepare a corresponding report
 Document the results obtained
 Use Statistical tools to support any conclusions of
variability and capability of a process
 Ensure a state of control
4/3/2015 85
 Ongoing Process Verification during Lifecycle
 Use throughout the product lifecycle
 Support the validated status of the product as
documented in the Product Quality Review.
 Consider
 Incremental changes over time
 Need for any additional actions,
 e.g. enhanced sampling, should be assessed.
4/3/2015 86
 Applicable to
 Finished medicinal products
 Investigational medicinal products
 Bulk product
 Samples
 Above should be transported as defined in the
 Marketing authorisation
 the approved label
 product specification file
 As justified by the manufacturer
4/3/2015 87
 Challenging due to the variable factors involved
 Define transportation routes clearly
 Consider seasonal and other variations during
verification
4/3/2015 88
 Perform a risk assessment
 Consider
 Impact of variables
 Transportation process
 Conditions which are continuously controlled or monitored,
 Delays during transportation
 Failure of monitoring devices
 Topping up liquid nitrogen
 Product susceptibility
 Any other relevant factors
4/3/2015 89
 Variable conditions are expected during
transportation
 Therefore perform continuous monitoring &
recording of critical environmental conditions
 Justify if this is not done
 Document the justification
4/3/2015 90
 Qualify primary and secondary packaging
equipment for finished and bulk products
 Variation in equipment processing parameters
 These have significant impact on the integrity and
correct functioning of the pack,
 Blister strips, sachets and sterile components,
therefore
4/3/2015 91
 Qualify primary packing equipment
 Qualify the minimum and maximum operating
ranges defined for the critical process parameters
 Temperature
 Machine speed
 Sealing pressure
 Any other factors
4/3/2015 92
 Perform qualification using the qualification steps
described earlier following
 Seam
 Water
 Air
 Other gases
4/3/2015 93
 Qualification
 Should reflect any seasonal variations
 Intended use of the utility
4/3/2015 94
 Perform a risk assessment if there could
be direct or indirect contact with the
product,
 Heating, ventilation and air-conditioning
(HVAC) systems
 Through heat exchangers
 Mitigate any risks of failure
4/3/2015 95
 Validate all analytical test methods used in
 Qualification
 Validation
 Cleaning exercises
 Validate with an appropriate detection and
quantification limit
 as defined in Chapter 6 of the EudraLex,
Volume 4, Part I.
4/3/2015 96
 Microbial testing of product
 Validate method to confirm that the product does
not influence the recovery of microorganisms.
4/3/2015 97
 Microbial testing of surfaces in clean
rooms
 Perform validation to confirm that
sanitising agents do not influence the
recovery of microorganisms.
4/3/2015 98
 Perform cleaning validation
 Confirm the effectiveness of all cleaning procedure for
all product contact equipment.
 Simulating agents may be used with appropriate
scientific justification.
 Similar types of equipment may be grouped together
 Provide a justification of the specific equipment
selected for cleaning validation
4/3/2015 99
 Visual check for cleanliness is an
important part of the acceptance criteria
 Do not use this criterion alone
 Do not repeat cleaning and retesting
until acceptable residue results are
obtained
 not considered an acceptable approach
4/3/2015
10
0
 Programme may take some time to complete
 Validation with verification after each batch
may be required for some products,
 e.g. investigational medicinal products.
 Collect sufficient data from verification to
support a conclusion that the equipment is
clean and available for further use.
4/3/2015 101
 Validation should consider
 Level of automation in the cleaning
process.
 Automatic process
 Validate the specified normal operating
range of the utilities and equipment
4/3/2015 102
 Perform assessment of all cleaning processes
 Determine variable factors which influence
cleaning effectiveness and performance
 Operators
 Level of detail in procedures such as rinsing
times etc.
 Use worst case situations for cleaning
validation studies identified
4/3/2015 103
 Limits for the carryover of product residues
should be based on a toxicological evaluation
 Document justification in a risk assessment
 Include all the supporting references.
 Establish limits for the removal of any cleaning
agents used.
 Consider the potential cumulative effect of
multiple items of equipment in the process
equipment train to determine acceptance criteria.
4/3/2015 104
 Limits for the carryover of product residues
should be based on a toxicological evaluation
 Therapeutic macromolecules and peptides degrade
and denature (when exposed to pH extremes
and/or heat )
 May become pharmacologically inactive.
 A toxicological evaluation may therefore not be
applicable in these circumstances.
4/3/2015 105
 Limits for the carryover of product residues
should be based on a toxicological
evaluation
 When testing for specific product residues is
not feasible other representative parameters
may be selected
 Total organic carbon (TOC)
 Conductivity
4/3/2015 106
 Consider the risk presented by
 Microbial contamination
 Endotoxin contamination
4/3/2015 107
 Consider Influence of the time
 between manufacture and cleaning
 between cleaning and use
 Based on this define for the cleaning
process
 Dirty hold time
 Clean hold time
4/3/2015 108
 For campaign manufacture consider
 Impact on the ease of cleaning at the
end of the campaign
 Maximum length of a campaign (in
time and/or number of batches)
4/3/2015 109
 Worst case product approach
 Provide a scientific rationale for
 Selection of the worst case product
 Impact of new products to the site assessed
 Criteria for determining worst case
 Solubility
 Cleanability
 Toxicity
 Potency
4/3/2015 110
 Cleaning validation protocols
 Specify or reference the locations to be
sampled
 Rationale for the selection of these
locations
 Define the acceptance criteria
4/3/2015 111
 Sampling
 Swabbing
 Rinsing
 Other means depending on the production equipment.
 Sampling materials and method should not influence
the result.
 Demonstrate recovery from all product contact
materials sampled in the equipment with all the
sampling methods used.
4/3/2015 112
 Cleaning procedure
 Perform an appropriate number of times
 Base this on a risk assessment
 Meet the acceptance criteria in order to
prove that the cleaning method is
validated.
4/3/2015 113
 Cleaning process
 Ineffective
 Not appropriate for some equipment
 Use
 Dedicated equipment
 Other appropriate measures for each product
 Refer chapters 3 and 5 of EudraLex, Volume
4, Part I.
4/3/2015 114
 Manual cleaning of equipment
 Confirm effectiveness of the manual
process at a justified frequency.
4/3/2015 115
 Control of change
 Important part of knowledge
management
 Handle within the pharmaceutical
quality system
4/3/2015 116
 Put written procedures in place & describe the actions to be taken if a planned
change is proposed to
 Starting material
 Product component
 Process
 Equipment
 Premises
 Product range
 Method of production or testing
 Batch size
 Design space
 Any other change during the lifecycle that may affect product quality or
reproducibility.
4/3/2015 117
 When Design space is used
 Consider the impact on changes to the
design space as registered in M A
 Assess need for any regulatory actions
4/3/2015 118
 Use Quality Risk Management to evaluate planned changes to determine the
potential impact on
 Product quality
 Pharmaceutical quality systems
 Documentation
 Validation
 Regulatory status
 Calibration
 Maintenance
 Any other system
 Avoid unintended consequences
 Plan for any necessary process validation, verification or requalification efforts.
4/3/2015 119
 Changes
 Authorised
 Approved
 Responsible persons
 Relevant functional personnel
 Follow the pharmaceutical quality system.
4/3/2015 120
 Review supporting data
 Confirm impact of change has been
demonstrated prior to final approval.
4/3/2015 121
 Perform an evaluation of the
effectiveness of change
 Confirm that the change has been
successful
4/3/2015 122
This presentation is compiled from freely available
resources like the website of EU, specifically
“EU GMP Guide-Annex 15
Qualification & Validation”
“Drug Regulations” is a non profit organization
which provides free online resource to the
Pharmaceutical Professional.
Visit http://www.drugregulations.org for latest
information from the world of Pharmaceuticals.
4/3/2015
12
3
Drug Regulations : Online
Resource for Latest Information

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New EU Requirements for Qualification & Validation

  • 1. This presentation is prepared by “ Drug Regulations” a non profit organization which provides free online resource to the Pharmaceutical Professional. Visit http://www.drugregulations.org for latest information from the world of Pharmaceuticals. 4/3/2015 1
  • 2. This presentation is compiled from freely available resources like the website of EU, specifically “EU GMP Guide-Annex 15 Qualification & Validation” “Drug Regulations” is a non profit organization which provides free online resource to the Pharmaceutical Professional. Visit http://www.drugregulations.org for latest information from the world of Pharmaceuticals. 4/3/2015 2 Drug Regulations : Online Resource for Latest Information
  • 3.  Updated version of Annex 15 ◦ Qualification and Validation  Draft released in February 2014  Final version released on the 30th of March , 2015  Will be effective on 01 October 2015 4/3/2015 3
  • 4.  May be used as supplementary optional guidance for active substances without introduction of additional requirements to EudraLex, Volume 4, Part II.  Retrospective validation is no longer an acceptable approach  The term “validation” has been replaced with “qualification and validation” to reflect the true intent of the Annex 15 in several instances 4/3/2015 4
  • 5.  An “equivalent document” to a VMP may be used for qualification and validation planning  VMP no longer needs to include ◦ Protocol and report templates, ◦ scheduling and planning information ◦ Confirmation of materials and suppliers used 4/3/2015 5
  • 6.  For large and complex projects separate validation plans may be used  The importance of Quality Risk Management is evident  Risk assessment to be repeated if further knowledge and understanding is gained from any changes during the project phase or during commercial production, 4/3/2015 6
  • 7.  Data integrity is also mentioned were “appropriate checks” needs to be built into qualification and validation tasks “to ensure the integrity of all data obtained”. 4/3/2015 7
  • 8.  Current version of Annex 15 of the EU Guide to GMP ◦ Originally published in September 2001 ◦ Significant changes in the GMP environment ◦ Advancements in manufacturing technology and continuous manufacture processes. 4/3/2015 8
  • 9. ◦ Many changes to other Chapters and Annexes which have an impact on Annex 15 ◦ Current version of the US FDA Guide on Process Validation, ◦ Approaches in ASTM E2500-07 “Standard Guide for Specification, Design, and Verification of Pharmaceutical and Biopharmaceutical Manufacturing Systems and Equipment “  All the above has justified the change 4/3/2015 9
  • 10.  This revision to Annex 15 takes into account ◦ Changes to Other sections of the EudraLex, Volume 4, Part I ◦ Relationship to Part II ◦ Annex 11 ◦ ICH Q8, Q9, Q10 and Q11 ◦ QWP guidance on process validation ◦ Changes in manufacturing technology 4/3/2015 10
  • 11.  Annex describes  Principles of Qualification and Validation  Applicable to ◦ Facilities ◦ Equipment ◦ Utilities and processes ◦ Manufacture of medicinal products  May also be used as supplementary optional guidance for active substances without introduction of additional requirements to EudraLex, Volume 4, Part II 4/3/2015 11
  • 12.  Qualification & Validation ◦ GMP requirement ◦ Control critical aspects of particular operations ◦ Applicable over the life cycle of product and process ◦ Document any planned changes to the facilities, equipment, utilities and processes, which may affect the quality of the product, and the impact on the validated status or control strategy assessed. 4/3/2015 12
  • 13.  Qualification & Validation ◦ Validate computerised systems :Annex 11. ◦ Use concepts and guidance of ICH Q8, Q9, Q10 and Q11 4/3/2015 13
  • 14.  Qualification & Validation ◦ Apply quality risk management approach throughout the lifecycle ◦ Determine scope and extent of qualification and validation on risk assessment of the facilities, equipment, utilities and processes. ◦ Document the risk assessment ◦ Retrospective validation is no longer considered an acceptable approach. 4/3/2015 14
  • 15.  Qualification & Validation ◦ Data obtained from sources outside of the manufacturers own programmes  May be used  Justify this approach  Adequate assurance that controls were in place throughout the acquisition of such data. 4/3/2015 15
  • 16.  Qualification & Validation ◦ Plan all activities ◦ Implement the life cycle approach ◦ Consider  Facilities  Equipment  Utilities  Process  Product 4/3/2015 16
  • 17.  Qualification & Validation ◦ Performed by suitably trained personnel ◦ Follow approved procedures ◦ Qualification/validation personnel should report as defined in the pharmaceutical quality system ◦ Not essential to be a quality management or a quality assurance function. ◦ Appropriate quality oversight over the whole validation life cycle is essential 4/3/2015 17
  • 18.  Qualification & Validation ◦ Define key elements of the site qualification and validation ◦ Document in a validation master plan (VMP) or equivalent document. 4/3/2015 18
  • 19.  Qualification & Validation ◦ VMP or equivalent document ◦ Define qualification/validation system ◦ Include or reference information on at least the following: 4/3/2015 19
  • 20.  Qualification & Validation  Include or reference information on at least the following: ◦ Qualification and Validation policy ◦ Organisational structure ◦ Roles and responsibilities for qualification and validation activities 4/3/2015 20
  • 21.  Qualification & Validation  Include or reference information on at least the following: ◦ Summary of the facilities, equipment, systems, processes on site ◦ Qualification and validation status ◦ Change control and deviation management for qualification and validation ◦ Guidance on developing acceptance criteria ◦ References to existing documents ◦ Strategy, including requalification, where applicable 4/3/2015 21
  • 22.  Qualification & Validation ◦ For large and complex projects, ◦ Added importance to planning ◦ Separate validation plans may enhance clarity 4/3/2015 22
  • 23.  Qualification & Validation ◦ Use quality risk management approach ◦ Repeat Risk assessment with increased knowledge & Changes  Project Phase  Commercial Phase ◦ Document the way in which risk assessments are used 4/3/2015 23
  • 24.  Qualification & Validation ◦ Incorporate appropriate checks ◦ Ensure the integrity of all data obtained 4/3/2015 24
  • 25.  Good Documentation Practices  Important to support knowledge management  Implement throughout the product lifecycle  All documents should be approved and authorised by appropriate personnel as defined in the pharmaceutical quality system.  Define the inter-relationship between documents in complex validation projects  Prepare validation protocols which defines the critical systems, attributes and parameters and the associated acceptance criteria. 4/3/2015 25
  • 26.  Good Documentation Practices  Documents may be combined together, where appropriate  e.g. installation qualification (IQ) and operational qualification (OQ). 4/3/2015 26
  • 27.  Good Documentation Practices  Any significant changes to the approved protocol during execution  Acceptance criteria  Operating parameters  Document as a deviation  Justify scientifically 4/3/2015 27
  • 28.  Good Documentation Practices  Record results not meeting pre-defined acceptance criteria as a deviation  Investigate all devotions  Discuss any implications for the validation in the report 4/3/2015 28
  • 29.  Good Documentation Practices  Each stage should have a formal release before proceeding to next stage  Release should be authorised by relevant responsible personnel  Release may be a part of validation report or as a separate summary document  Conditional approval to proceed to the next qualification stage possible when  Certain acceptance criteria or deviations have not been fully addressed  There is a documented assessment that there is no significant impact on the next activity. 4/3/2015 29
  • 30.  Qualification activities  Consider all stages  Initial development of the user requirements specification through to End of use of the equipment, facility, utility or system. 4/3/2015 30
  • 31.  The main stages and some suggested criteria which could be included in each stage are indicated in subsequent slides:  although this depends on individual project circumstances and may be different 4/3/2015 31
  • 32.  User requirements specification (URS)  Define specification in a URS and/or a functional specification for  Equipment  Facilities  Utilities or systems  The essential elements of quality need to be built in at this stage  GMP risks if any should be mitigated to an acceptable level.  URS should be a point of reference throughout the validation life cycle. 4/3/2015 32
  • 33.  Design qualification (DQ)  The next element in the qualification of equipment, facilities, utilities, or systems  Demonstrate compliance of the design with GMP  Document compliance  Verify requirements of the user requirements specification during the design qualification. 4/3/2015 33
  • 34.  Factory acceptance testing (FAT) /Site acceptance testing (SAT)  Equipment may be evaluated at the vendor prior to delivery.  Confirm compliance with URS/functional specification prior to installation at the vendor site 4/3/2015 34
  • 35.  Factory acceptance testing (FAT) /Site acceptance testing (SAT)  Documentation review & some tests could be performed at the FAT or other stages  These tests need not be repeated on site at IQ/OQ if functionality is not affected by transport and installation. 4/3/2015 35
  • 36.  Factory acceptance testing (FAT) /Site acceptance testing (SAT)  FAT may be supplemented by the execution of a SAT following the receipt of equipment at the manufacturing site. 4/3/2015 36
  • 37.  Installation qualification (IQ)  Perform IQ on  Equipment  Facilities  Utilities  Systems. 4/3/2015 37
  • 38.  Installation qualification (IQ)  IQ should include, but is not limited to the following:  Verification of the correct installation of components, instrumentation, equipment, pipe work and services against the engineering drawings and specifications;  Verification of the correct installation against pre-defined criteria;  Collection and collation of supplier operating and working instructions and maintenance requirements;  Calibration of instrumentation  Verification of the materials of construction. 4/3/2015 38
  • 39.  Operational qualification (OQ)  OQ normally follows IQ  May be performed as a combined Installation/Operation Qualification (IOQ).  Depends on the complexity of the equipment 4/3/2015 39
  • 40.  Operational qualification (OQ)  OQ should include but is not limited to the following:  Tests that have been developed from the knowledge of processes, systems and equipment to ensure the system is operating as designed;  Tests to confirm upper and lower operating limits, and /or “worst case” conditions. 4/3/2015 40
  • 41.  Performance qualification (PQ)  PQ should normally follow the successful completion of IQ and OQ.  Could also be performed in conjunction with OQ or Process Validation. 4/3/2015 41
  • 42.  Performance qualification (PQ)  PQ should include, but is not limited to the following:  Tests using  Production materials,  Qualified substitutes or  Simulated product proven to have equivalent behaviour  Normal operating conditions  Worst case batch sizes.  Justify the frequency of sampling used to confirm process control 4/3/2015 42
  • 43.  Performance qualification (PQ)  PQ should include, but is not limited to the following:  Tests should cover the operating range of the intended process  No need for this if documented evidence from the development phases confirming the operational ranges is available. 4/3/2015 43
  • 44.  RE-QUALIFICATION  Evaluate at an appropriate frequency to confirm that following remain in a state of control  Equipment  Facilities  Utilities  Systems 4/3/2015 44
  • 45.  RE-QUALIFICATION  Justify requalification period  Define criteria for reevaluation  Assess the possibility of small changes over time 4/3/2015 45
  • 46.  General Principles  Applicable to the manufacture of all pharmaceutical dosage forms.  Initial validation of new processes  Subsequent validation of modified processes  Site transfers and ongoing process verification 4/3/2015 46
  • 47.  General Principles  Robust product development process required to enable successful process validation  This guidance should be used in conjunction with the current EMA guideline on Process Validation for Finished Products. 4/3/2015 47
  • 48.  General Principles  Guideline on Process Validation for Finished Products (LINK)  Guidance on information and data to be provided in the regulatory submission only.  However GMP requirements for process validation continue throughout the lifecycle of the process  Apply this approach to link product and process development. 4/3/2015 48
  • 49.  General Principles  Manufacturing processes may be developed using a  Traditional approach  Continuous verification approach 4/3/2015 49
  • 50.  General Principles  Before any product is released to the market & irrespective of the approach used  Processes must be shown to be robust  Ensure consistent product quality 4/3/2015 50
  • 51.  General Principles  Traditional approach  Only prospective validation programme prior to certification of the product.  Retrospective validation is no longer an acceptable approach. 4/3/2015 51
  • 52.  General Principles  New products  Cover all intended marketed strengths  Cover all sites of manufacture  Bracketing could be used. Justify based on  Extensive process knowledge from the development stage  An appropriate ongoing verification programme 4/3/2015 52
  • 53.  General Principles  Site Transfer  Transferred from one site to another  Within the same site, 4/3/2015 53
  • 54.  General Principles  Site Transfer  Number of validation batches could be reduced by the use of a bracketing approach. Justify based on  Existing product knowledge,  Content of the previous validation  Use bracketing for  Different strengths  Batch sizes  Pack sizes  Container types 4/3/2015 54
  • 55.  General Principles  Site Transfer of Legacy products  Manufacturing process and controls must comply with the marketing authorisation  Meet current standards for marketing authorisation for that product type.  If necessary, variations to the marketing authorisation should be submitted. 4/3/2015 55
  • 56.  General Principles  Attributes and parameters  Important for ensuring the validated state and acceptable product quality  Process validation should establish whether these can be consistently met by the process  Document the basis for identifying criticality of parameters & attributes 4/3/2015 56
  • 57.  General Principles  Process validation batches  Same size as the intended commercial scale batches  Justify use of any other batch sizes 4/3/2015 57
  • 58.  General Principles  Development studies & Process knowledge  Basis of all validation activities  For all products  Irrespective of validation  Should be accessible to the manufacturing site,  Other wise justify 4/3/2015 58
  • 59.  General Principles  Process validation batches  Production personnel  Development personnel  Other site transfer personnel  Use only trained personnel  Manufacture in accordance with GMP  Use approved documentation  Production personnel should facilitate product understanding 4/3/2015 59
  • 60.  General Principles  Qualify suppliers of critical starting and packaging materials prior to manufacture  Otherwise  Justify based on of quality risk management principles  Document justification 4/3/2015 60
  • 61.  General Principles  Design Space & Mathematical Models  Could be used for Process control strategy  Following should be available  Underlying process knowledge  Development of any mathematical models  Justification 4/3/2015 61
  • 62.  General Principles  Release of Validation batches to the Market  Pre-define  Manufacture should fully comply with  GMP  Validation acceptance criteria  Continuous process verification criteria (if used)  Marketing authorisation  Clinical trial authorisation. 4/3/2015 62
  • 63.  General Principles  Investigational medicinal products (IMP),  Refer to Annex 13. 4/3/2015 63
  • 64.  Concurrent validation  Routine production starts before completion of validation  Concurrent validation can be used under exceptional circumstances  A strong benefit-risk ratio for the patient required  Justify decision to carry out concurrent validation  Document the decision in the VMP for visibility  Decision should be approved by authorised personnel 4/3/2015 64
  • 65.  Concurrent validation  Have sufficient data to support a conclusion that  Any given batch of product is uniform  Meets the defined acceptance criteria.  Document the results and conclusion formally  Document should be available to the Qualified Person prior to certification of the batch 4/3/2015 65
  • 66.  Traditional process validation  Number of batches of the finished product are manufactured under routine conditions to confirm reproducibility. 4/3/2015 66
  • 67.  Traditional process validation  Number of batches manufactured & Number of samples taken  Use Quality Risk Management principles  Allow the normal range of variation and trends to be established  Provide sufficient data for evaluation. 4/3/2015 67
  • 68.  Traditional process validation  Number of batches manufactured & Number of samples taken  Determine and justify the number of batches necessary to demonstrate a high level of assurance that the process is capable of consistently delivering quality product. 4/3/2015 68
  • 69.  Traditional process validation  Generally acceptable  Without prejudice to earlier requirement  Minimum of three consecutive batches manufactured under routine conditions could constitute a validation of the process 4/3/2015 69
  • 70.  Traditional process validation  Generally acceptable  Alternative number of batches may be justified based on  Whether standard methods of manufacture are used  Whether similar products or processes are already used at the site. 4/3/2015 70
  • 71.  Traditional process validation  Generally acceptable  Supplement an initial validation exercise with three batches with further data obtained from subsequent batches as part of an on-going process verification exercise. 4/3/2015 71
  • 72.  Traditional process validation  Process validation protocol should be prepared which defines  Critical process parameters (CPP),  Critical quality attributes (CQA)  Associated acceptance criteria  Base this on development data or documented process knowledge. 4/3/2015 72
  • 73.  Traditional process validation  Process validation protocols should include, but are not limited to the following: 1. A short description of the process and a reference to the respective Master Batch Record; 2. Functions and responsibilities; 3. Summary of the CQAs to be investigated; 4. Summary of CPPs and their associated limits; 4/3/2015 73
  • 74.  Traditional process validation  Process validation protocols should include, but are not limited to the following: 4. Summary of other (non-critical) attributes and parameters which will be investigated or monitored during the validation activity, and the reasons for their inclusion; 5. List of the equipment/facilities to be used (including measuring/monitoring/recording equipment) together with the calibration status; 6. List of analytical methods and method validation, as appropriate 4/3/2015 74
  • 75.  Traditional process validation  Process validation protocols should include, but are not limited to the following: 7. Proposed in-process controls with acceptance criteria and the reason(s) why each in-process control is selected; 8. Additional testing to be carried out with acceptance criteria; 9. Sampling plan and the rationale behind it; 10. Methods for recording and evaluating results; 11. Process for release and certification of batches (if applicable) 4/3/2015 75
  • 76.  Continuous process verification  Can be used as an alternate approach for traditional process validation for  Products developed by a quality by design approach  Scientifically established control strategy during development  A strategy which provides a high degree of assurance of product quality 4/3/2015 76
  • 77.  Continuous process verification  Define the method by which the process will be verified  Put in place a science based control strategy for the required attributes to confirm product realisation for  Incoming materials  Critical quality attributes  Critical process parameters 4/3/2015 77
  • 78.  Continuous process verification  Put in place a science based control strategy for the required attributes to confirm product realisation  Include regular evaluation of the control strategy.  Process Analytical Technology and multivariate statistical process control may be used as tools. 4/3/2015 78
  • 79.  Continuous process verification  Determine and justify the number of batches necessary to demonstrate a high level of assurance that the process is capable of consistently delivering quality product.  The general principles presented earlier still apply. 4/3/2015 79
  • 80.  Hybrid approach  A hybrid of the traditional approach and continuous process verification approach  Could be used where there is  Substantial amount of product and process knowledge  Understanding which has been gained from manufacturing experience and historical batch data. 4/3/2015 80
  • 81.  Hybrid approach  Could be used  Even if the product was initially validated using a traditional approach  For any validation activities after changes  During ongoing process verification 4/3/2015 81
  • 82.  Ongoing Process Verification during Lifecycle  Applicable to all three approaches to process validation mentioned earlier, i.e.  Traditional,  Continuous or  Hybrid. 4/3/2015 82
  • 83.  Ongoing Process Verification during Lifecycle  Monitor product quality  Ensure that a state of control is maintained throughout the product lifecycle  Evaluate relevant process trends 4/3/2015 83
  • 84.  Ongoing Process Verification during Lifecycle  Periodically review extent and frequency of ongoing process verification.  Any point during the life cycle appropriate to modify the requirements taking into account the current level of process understanding and process performance. 4/3/2015 84
  • 85.  Ongoing Process Verification during Lifecycle  Conduct under an approved protocol or equivalent documents  Prepare a corresponding report  Document the results obtained  Use Statistical tools to support any conclusions of variability and capability of a process  Ensure a state of control 4/3/2015 85
  • 86.  Ongoing Process Verification during Lifecycle  Use throughout the product lifecycle  Support the validated status of the product as documented in the Product Quality Review.  Consider  Incremental changes over time  Need for any additional actions,  e.g. enhanced sampling, should be assessed. 4/3/2015 86
  • 87.  Applicable to  Finished medicinal products  Investigational medicinal products  Bulk product  Samples  Above should be transported as defined in the  Marketing authorisation  the approved label  product specification file  As justified by the manufacturer 4/3/2015 87
  • 88.  Challenging due to the variable factors involved  Define transportation routes clearly  Consider seasonal and other variations during verification 4/3/2015 88
  • 89.  Perform a risk assessment  Consider  Impact of variables  Transportation process  Conditions which are continuously controlled or monitored,  Delays during transportation  Failure of monitoring devices  Topping up liquid nitrogen  Product susceptibility  Any other relevant factors 4/3/2015 89
  • 90.  Variable conditions are expected during transportation  Therefore perform continuous monitoring & recording of critical environmental conditions  Justify if this is not done  Document the justification 4/3/2015 90
  • 91.  Qualify primary and secondary packaging equipment for finished and bulk products  Variation in equipment processing parameters  These have significant impact on the integrity and correct functioning of the pack,  Blister strips, sachets and sterile components, therefore 4/3/2015 91
  • 92.  Qualify primary packing equipment  Qualify the minimum and maximum operating ranges defined for the critical process parameters  Temperature  Machine speed  Sealing pressure  Any other factors 4/3/2015 92
  • 93.  Perform qualification using the qualification steps described earlier following  Seam  Water  Air  Other gases 4/3/2015 93
  • 94.  Qualification  Should reflect any seasonal variations  Intended use of the utility 4/3/2015 94
  • 95.  Perform a risk assessment if there could be direct or indirect contact with the product,  Heating, ventilation and air-conditioning (HVAC) systems  Through heat exchangers  Mitigate any risks of failure 4/3/2015 95
  • 96.  Validate all analytical test methods used in  Qualification  Validation  Cleaning exercises  Validate with an appropriate detection and quantification limit  as defined in Chapter 6 of the EudraLex, Volume 4, Part I. 4/3/2015 96
  • 97.  Microbial testing of product  Validate method to confirm that the product does not influence the recovery of microorganisms. 4/3/2015 97
  • 98.  Microbial testing of surfaces in clean rooms  Perform validation to confirm that sanitising agents do not influence the recovery of microorganisms. 4/3/2015 98
  • 99.  Perform cleaning validation  Confirm the effectiveness of all cleaning procedure for all product contact equipment.  Simulating agents may be used with appropriate scientific justification.  Similar types of equipment may be grouped together  Provide a justification of the specific equipment selected for cleaning validation 4/3/2015 99
  • 100.  Visual check for cleanliness is an important part of the acceptance criteria  Do not use this criterion alone  Do not repeat cleaning and retesting until acceptable residue results are obtained  not considered an acceptable approach 4/3/2015 10 0
  • 101.  Programme may take some time to complete  Validation with verification after each batch may be required for some products,  e.g. investigational medicinal products.  Collect sufficient data from verification to support a conclusion that the equipment is clean and available for further use. 4/3/2015 101
  • 102.  Validation should consider  Level of automation in the cleaning process.  Automatic process  Validate the specified normal operating range of the utilities and equipment 4/3/2015 102
  • 103.  Perform assessment of all cleaning processes  Determine variable factors which influence cleaning effectiveness and performance  Operators  Level of detail in procedures such as rinsing times etc.  Use worst case situations for cleaning validation studies identified 4/3/2015 103
  • 104.  Limits for the carryover of product residues should be based on a toxicological evaluation  Document justification in a risk assessment  Include all the supporting references.  Establish limits for the removal of any cleaning agents used.  Consider the potential cumulative effect of multiple items of equipment in the process equipment train to determine acceptance criteria. 4/3/2015 104
  • 105.  Limits for the carryover of product residues should be based on a toxicological evaluation  Therapeutic macromolecules and peptides degrade and denature (when exposed to pH extremes and/or heat )  May become pharmacologically inactive.  A toxicological evaluation may therefore not be applicable in these circumstances. 4/3/2015 105
  • 106.  Limits for the carryover of product residues should be based on a toxicological evaluation  When testing for specific product residues is not feasible other representative parameters may be selected  Total organic carbon (TOC)  Conductivity 4/3/2015 106
  • 107.  Consider the risk presented by  Microbial contamination  Endotoxin contamination 4/3/2015 107
  • 108.  Consider Influence of the time  between manufacture and cleaning  between cleaning and use  Based on this define for the cleaning process  Dirty hold time  Clean hold time 4/3/2015 108
  • 109.  For campaign manufacture consider  Impact on the ease of cleaning at the end of the campaign  Maximum length of a campaign (in time and/or number of batches) 4/3/2015 109
  • 110.  Worst case product approach  Provide a scientific rationale for  Selection of the worst case product  Impact of new products to the site assessed  Criteria for determining worst case  Solubility  Cleanability  Toxicity  Potency 4/3/2015 110
  • 111.  Cleaning validation protocols  Specify or reference the locations to be sampled  Rationale for the selection of these locations  Define the acceptance criteria 4/3/2015 111
  • 112.  Sampling  Swabbing  Rinsing  Other means depending on the production equipment.  Sampling materials and method should not influence the result.  Demonstrate recovery from all product contact materials sampled in the equipment with all the sampling methods used. 4/3/2015 112
  • 113.  Cleaning procedure  Perform an appropriate number of times  Base this on a risk assessment  Meet the acceptance criteria in order to prove that the cleaning method is validated. 4/3/2015 113
  • 114.  Cleaning process  Ineffective  Not appropriate for some equipment  Use  Dedicated equipment  Other appropriate measures for each product  Refer chapters 3 and 5 of EudraLex, Volume 4, Part I. 4/3/2015 114
  • 115.  Manual cleaning of equipment  Confirm effectiveness of the manual process at a justified frequency. 4/3/2015 115
  • 116.  Control of change  Important part of knowledge management  Handle within the pharmaceutical quality system 4/3/2015 116
  • 117.  Put written procedures in place & describe the actions to be taken if a planned change is proposed to  Starting material  Product component  Process  Equipment  Premises  Product range  Method of production or testing  Batch size  Design space  Any other change during the lifecycle that may affect product quality or reproducibility. 4/3/2015 117
  • 118.  When Design space is used  Consider the impact on changes to the design space as registered in M A  Assess need for any regulatory actions 4/3/2015 118
  • 119.  Use Quality Risk Management to evaluate planned changes to determine the potential impact on  Product quality  Pharmaceutical quality systems  Documentation  Validation  Regulatory status  Calibration  Maintenance  Any other system  Avoid unintended consequences  Plan for any necessary process validation, verification or requalification efforts. 4/3/2015 119
  • 120.  Changes  Authorised  Approved  Responsible persons  Relevant functional personnel  Follow the pharmaceutical quality system. 4/3/2015 120
  • 121.  Review supporting data  Confirm impact of change has been demonstrated prior to final approval. 4/3/2015 121
  • 122.  Perform an evaluation of the effectiveness of change  Confirm that the change has been successful 4/3/2015 122
  • 123. This presentation is compiled from freely available resources like the website of EU, specifically “EU GMP Guide-Annex 15 Qualification & Validation” “Drug Regulations” is a non profit organization which provides free online resource to the Pharmaceutical Professional. Visit http://www.drugregulations.org for latest information from the world of Pharmaceuticals. 4/3/2015 12 3 Drug Regulations : Online Resource for Latest Information