ISPE Central Canada Chapter BAS Lifecycle Overview using GaMP January 24, 2006 – Toronto January 25, 2006 – Montreal Irene Miess – Sr Manager Regulated Industries Siemens Building Technologies Company Confidential BAS Lifecycle Overview using GaMP GaMP Model System Impact Assessment – Direct Impact Systems – Indirect Impact Systems Good Engineering Practice Commissioning Qualification Practices – Installation and Operational Qualification Documentation Requirements Ongoing Operation Company Confidential Good Automated Manufacturing Practice (GaMP) As a regulated site supplier, what guidance do we have in delivering a validated and compliant system? Planning Design & Development Installation FAT Required? YES Factory Acceptance Testing Company Confidential NO Commissioning & Qualification Ongoing Operation Good Automated Manufacturing Practice (GaMP) GaMP provides a method to relate development activities to validation activities on automated systems using a life cycle approach Good Automated Manufacturing Practice (GaMP) GaMP was created due to: – the increased use and complexity of automated systems in FDA regulated manufacturing areas – the less mature interpretation of regulations in automated applications than in more conventional, non-automated areas GaMP benefits FDA regulated companies by: – Improving the understanding & interpretation of regulations – Providing established guidelines for suppliers of automated systems – Clarifying the division of responsibility between user and supplier – Reducing the cost and time taken to achieve compliant systems A GaMP Industry Board establishes GaMP principles and recommendations Company Confidential Project Lifecycle (GaMP) Planning Design & Development Installation FAT Required? YES Factory Acceptance Testing Company Confidential NO Commissioning & Qualification Ongoing Operation Planning and Design/Development Phases Master Validation Plan (MVP) Planning Phase User Requirement Specification (URS) Impact Assessment Quality System Program and Implementation Plan Functional Specification Hardware Engineering Submittal Hardware Software Software Design & Development Phase Customer Approval of Functional and Design Factory Acceptance Test (FAT) Phase Company Confidential Master Validation Plan The Validation Master Plan (VMP) is the key document in the overall validation process, and is critical to the success of the project. It is an important project document and a living document that must be maintained throughout the project life cycle. The validation master plan typically defines: Validation Strategy Validation Deliverables Acceptance Criteria Change Control Management Standard Operating Procedures Training Documentation Management Maintaining a Validated State Company Confidential Master Validation Plan BAS needs to be addressed – Monitor & Alarm only – Direct Impact only …If you want tomatoes, don’t plant turnips! Company Confidential Planning and Design/Development Phases Master Validation Plan (MVP) Planning Phase User Requirement Specification (URS) Impact Assessment Quality System Program and Implementation Plan Functional Specification Hardware Engineering Submittal Hardware Software Software Design & Development Phase Customer Approval of Functional and Design Factory Acceptance Test (FAT) Phase Company Confidential User Requirements The User Requirement Specification (URS) specifies the requirements of the user for individual aspects of the facility, equipment, and systems in terms of function, throughput, operability, and applicable standards Defines what the user wants the system to do. What functions will be carried out, the data on which the system will operate, and the operating environment. Non-functional requirements, such as constraints (that is, time) and what deliverables will be provided by the system (that is, Training, Testing, Tools), are also documented The User Requirement Specification (URS) and Performance Testing are linked. The URS provides the performance benchmark criteria upon which the performance qualification (PQ) is based Company Confidential BAS User Requirement Spec Do you want – to follow GaMP • traceability matrix • functional specs • testing – calibratable sensors – commissioning documents – remote notification • horn/bell • paging Company Confidential Planning and Design/Development Phases Master Validation Plan (MVP) Planning Phase User Requirement Specification (URS) Impact Assessment Quality System Program and Implementation Plan Functional Specification Hardware Engineering Submittal Hardware Software Software Design & Development Phase Customer Approval of Functional Design Factory Acceptance Test (FAT) Phase Company Confidential Impact Assessment A process which allows a complex situation of interdependent engineering systems and components to be reviewed, understood and systematically evaluated for their effect on product quality (Commissioning vs. Qualification). Company Confidential Relationship Between Systems and Components Components Critical Direct Impact Systems Indirect/ No Impact Company Confidential 8 Non-Critical Good Engineering Practices + Qualification Practices Good Engineering Practices + Commissioning System Level Assessment System: An organization of engineering components which have defined operational function (e.g., piping, instrumentation, equipment, facilities, computer hardware, computer software, etc.) System Boundary: A limit drawn around a system to logically define what is and is not included in the system. Company Confidential System Level Assessment Direct Impact System: An engineering system that is expected to have a direct impact on product quality. Indirect Impact System: An engineering system that is not expected to have a direct impact on product quality, but is linked to a direct impact system. No Impact System: An engineering system that is not expected to have an impact on product quality. Company Confidential System Level Assessment System Impact Assessment: The process of evaluating the impact of the operating, controlling, alarming and failure conditions of a system on the quality of a product. The quality of the product can be impacted by a system or systems which meets any of the following criteria: − In contact with the product − Used as an excipient − Controls the process or − Provides information relative to product acceptance or rejection Company Confidential Component Level Assessment Critical Component: A component within a system where the operation, contact, data, control, alarm or failure will have a direct impact on the quality of the product. Non-Critical Component: A component within a system where the operation, contact, data control, alarm or failure will have an indirect or no impact on the quality of the product. Company Confidential Relationship Between Systems and Components Components Critical Direct Impact Systems Indirect/ No Impact Company Confidential 8 Non-Critical Good Engineering Practices + Qualification Practices Good Engineering Practices + Commissioning BAS Draw Boundaries – HVAC – BAS only • AHU controls • zone controls • monitor & alarm – Design system accordingly • Separation by panels • Separate GMP from non GMP Company Confidential Where are YOUR Boundaries Sample P&ID of HVAC and BAS Equipment Company Confidential Planning and Design/Development Phases Master Validation Plan (MVP) Planning Phase User Requirement Specification (URS) Impact Assessment Quality System Program and Implementation Plan Functional Specification Hardware Engineering Submittal Hardware Software Software Design & Development Phase Customer Approval of Functional and Design Factory Acceptance Test (FAT) Phase Company Confidential Quality System Program and Implementation Plan The Quality System Program and Implementation Plan is a contractual document between the Client and BAS supplier. Defines actions, deliverables, responsibilities, and procedures satisfying the user quality and validation requirements. Company Confidential Planning and Design/Development Phases Master Validation Plan (MVP) Planning Phase User Requirement Specification (URS) Impact Assessment Quality System Program and Implementation Plan Functional Specification Hardware Engineering Submittal Hardware Software Software Design & Development Phase Customer Approval of Functional and Design Factory Acceptance Test (FAT) Phase Company Confidential Functional Requirements Specification The Functional Requirements Specification (FRS) describes the detailed functions of the facility, equipment, and system (i.e., what the system will do). The Functional Specification is normally written by the Supplier and then reviewed and approved by the Customer. The FRS is used to develop the Acceptance Test Specification that outlines those items to be tested as part of the Factory Acceptance Test (FAT) and/or Site Assessment Test (SAT). Company Confidential Planning and Design/Development Phases Master Validation Plan (MVP) Planning Phase User Requirement Specification (URS) Impact Assessment Quality System Program and Implementation Plan Functional Specification Hardware Engineering Submittal Hardware Software Software Design & Development Phase Customer Approval of Functional and Design Factory Acceptance Test (FAT) Phase Company Confidential Design Specification The Design Specification (DS) document developed by Supplier describes how to build the facility, equipment, and system (that is, how to design or construct the system). It is recommended that the Design Specification is illustrated by the use of diagrams wherever possible. The Design Specification is normally written by the Supplier and then reviewed and approved by the Customer. In most cases the DS may be included in the FS Company Confidential Planning and Design/Development Phases Master Validation Plan (MVP) Planning Phase User Requirement Specification (URS) Quality System Program and Implementation Plan Impact Assessment Functional Specification Hardware Engineering Submittal Linked to Installation Qualification (IQ) Linked to Operational Qualification (OQ) Linked to Performance Qualification (PQ) Company Confidential Hardware Software Software Design & Development Phase Customer Approval of Functional and Design Factory Acceptance Test (FAT) Phase Project Lifecycle (GaMP) Planning Design & Development Installation FAT Required? YES Factory Acceptance Testing Company Confidential NO Commissioning & Qualification Ongoing Operation Project Lifecycle (GaMP) Planning Design & Development Installation FAT Required? YES Factory Acceptance Testing Company Confidential NO Commissioning & Qualification Ongoing Operation FAT and Installation Phases NO Factory Acceptance Test (FAT) Required? Factory Acceptance Test (FAT) Phase YES BUILD SYSTEM Factory Acceptance Test (FAT) BUILD SYSTEM Installation at Job Site Installation Phase Develop IQ/OQ/PQ Tests Develop Commissioning Plan Commissioning& Qualification Phase Company Confidential FAT and Installation Phases NO Factory Acceptance Test (FAT) Required? Factory Acceptance Test (FAT) Phase YES BUILD SYSTEM Factory Acceptance Test (FAT) BUILD SYSTEM Installation at Job Site Installation Phase Develop IQ/OQ/PQ Tests Develop Commissioning Plan Commissioning& Qualification Phase Company Confidential Factory Acceptance Test (FAT) A FAT is recommended when the project deadline is critical and construction schedule does not allow enough time for commissioning and validation after installation. Combining the commissioning findings with the FAT as part of the validation process helps avoid collecting data twice, making better use of time and project resources. Other tests used during the FAT and SAT may be used to support the validation effort. The request for the FAT occurs during the planning stage of a project and usually is included in the Validation Master Plan and the Request for Quote (RFQ). Company Confidential Project Lifecycle (GaMP) Planning Design & Development Installation FAT Required? YES Factory Acceptance Testing Company Confidential NO Commissioning & Qualification Ongoing Operation Commissioning/Qualification Phase & Ongoing Ops Start-up & Commissioning Site Acceptance Test (SAT) DIRECT IMPACT SYSTEMS INDIRECT & NO IMPACT SYSTEMS Installation Qualification (IQ) Trending to verify operational changes Commissioning & Qualification Phase Operational Qualification (OQ) Performance Qualification (PQ) Change Control Standard Operations (SOPs) Maintenance Operations Company Confidential Document Control Training Business Continuity Ongoing Operations Impact Assessment GEP Only Parking Facilities No Impact Office Terminal Devices Office HVAC Systems Chilled Water Systems Indirect Impact? cGMP HVAC Systems Building Management System GEP and Qualification Company Confidential cGMP Terminal Devices Direct Impact Commissioning Plan IMPACT ASSESSMENT GEP DOCUMENTATION COMMISSIONING GEP / QUALIFICATION IQ / OQ Parking Facility Vendor Standard X Office Terminal HVAC Equipment Vendor Standard X Office Central HVAC Equipment Vendor Standard X Chilled / Hot Water Systems Vendor Standard X Building Automation System Vendor Standard X Enhanced Documentation / FAT? X cGMP Central HVAC Critical Systems X Enhanced Documentation X cGMP Terminal HVAC Critical Systems X Enhanced Documentation X Other Validated Ancillary Systems X Enhanced Documentation X Company Confidential Commissioning A well planned, documented and managed engineering approach to the start-up and turnover of facilities, systems and equipment to the end-user that results in a safe and functional environment that meets established design requirements and stakeholders expectations. Company Confidential Commissioning Concepts: Requires close cooperation of a multi-disciplined team Builds on concepts and activities such as Impact Assessment and Good Engineering Practices Execution typically occurs after the installation of equipment, piping and instrumentation is complete and operational Systems, equipment and instrumentation need to be physically complete and operational Company Confidential Commissioning Plan Agree on the Commissioning Plan early in the project Plan should identify systems to be commissioned, activities and sequences, deliverables, personnel and organizations involved and their roles/responsibilities Provide list of facilities, utilities and equipment to be commissioned Approvers should include Design, Construction and the End-User representatives; include Validation and QA for direct impact systems Commissioning should be integrated with qualification activities for direct impact systems Commissioning may be the final activity prior to use/operation by the end-user Plan for either phased or one-time turnover Company Confidential Commissioning Process Levels of commissioning for building automation systems: – Standard Commissioning – Enhanced Commissioning The level of commissioning is defined in the VMP and Quality Plan. Direct Impact systems require enhanced documentation, which may involve additional tests, documentation, QA change control, and QA review/approval. Enhance documentation should complement (not repeat) the documentation that is created through GEP. Company Confidential Commissioning/Qualification Phase & Ongoing Ops Start-up & Commissioning Site Acceptance Test (SAT) DIRECT IMPACT SYSTEMS INDIRECT & NO IMPACT SYSTEMS Installation Qualification (IQ) Trending to verify operational changes Commissioning & Qualification Phase Operational Qualification (OQ) Performance Qualification (PQ) Change Control Standard Operations (SOPs) Maintenance Operations Company Confidential Document Control Training Business Continuity Ongoing Operations Site Acceptance Test Tests that are completed ‘On-site’ with installed equipment to prove the correct operation of the software, hardware, and instrumentation as defined by the URS Company Confidential Site Acceptance Test The Site Acceptance Test (SAT) is performed to determine that the system and any associated equipment has not been damaged and functions correctly in its operating environment. The SAT normally constitutes a repeat of the FAT (or portions of the FAT) in the user’s environment plus those test made possible with all process, field instrumentation, interfaces, and service connections established. The SAT may be combined with equipment and plant commissioning, and this will provide a basis for the IQ and OQ. The incorporation of SAT into qualification testing is acceptable where the level of detail and documentation of the tests meet the requirement of user company policies and procedures, and are acceptable to user company QA. Company Confidential Commissioning/Qualification Phase & Ongoing Ops Start-up & Commissioning Site Acceptance Test (SAT) DIRECT IMPACT SYSTEMS INDIRECT & NO IMPACT SYSTEMS Installation Qualification (IQ) Trending to verify operational changes Commissioning & Qualification Phase Operational Qualification (OQ) Performance Qualification (PQ) Change Control Standard Operations (SOPs) Maintenance Operations Company Confidential Document Control Training Business Continuity Ongoing Operations BAS Installation Qualification – Table of Contents Documentation Verification SOP Verification Hardware and Software Verification Field Panel Hardware and Firmware Verification Utility Verification Application Code Version Verification Company Confidential Installation Qualification – Table of Contents Database Configuration Verification Trend Configuration Verification Trend Collection Schedule Verification Alarm Configuration Verification Point Configuration Verification Alarm Management Configuration Verification Remote Notification Configuration Verification Alarm Paging Notification Verification Point List Verification Company Confidential Installation Qualification – Table of Contents Archive Database Configuration Verification Data Base Verification Data Server Configuration Verification Archive Schedule Verification Data Purge Configuration Verification Summary Point Configuration Verification Uninterruptible Power Supply Installation Verification Field Device Calibration Verification Field Equipment Installation Verification Company Confidential Commissioning/Qualification Phase & Ongoing Ops Start-up & Commissioning Site Acceptance Test (SAT) DIRECT IMPACT SYSTEMS INDIRECT & NO IMPACT SYSTEMS Installation Qualification (IQ) Trending to verify operational changes Commissioning & Qualification Phase Operational Qualification (OQ) Performance Qualification (PQ) Change Control Standard Operations (SOPs) Maintenance Operations Company Confidential Document Control Training Business Continuity Ongoing Operations Operational Qualification – Table of Contents System Security Qualification Test Cases User Account Security Access Groups Audit Trail Qualification Test Cases Audit Trail Verification Long Term Storage of Audit Trails Field Panel Qualification Test Cases •Field Panel Loss of Communication •Field Panel Battery Check •Field Panel Power Failure Alarming and Recovery •Electric Field Instrument (EFI) Interference Company Confidential Operational Qualification – Table of Contents Uninterrupted Power Supply Custom Code Testing Scheduled Functions Qualification Test Cases Trend Collection Report Verification Data Server Verification Archive Schedule Verification System Alarms Qualification Test Cases Standard Alarm Notification Test Enhanced Alarms Notification Test Company Confidential Operational Qualification – Table of Contents Remote Notification Qualification Test Cases Building Level Network Event Escalation Test Alarm Management Qualification Test Cases Alarm Management Operational Test Case Alarm Management Archival Test Case Data Integrity Qualification Test Cases Transmitter Failure Test 72 Hour Trend Analysis Company Confidential Commissioning/Qualification Phase & Ongoing Ops Linked to User Requirements Spec Start-up & Commissioning Linked to Functional Requirements Spec Linked to Design Spec Site Acceptance Test (SAT) DIRECT IMPACT SYSTEMS INDIRECT & NO IMPACT SYSTEMS Installation Qualification (IQ) Trending to verify operational changes Commissioning & Qualification Phase Operational Qualification (OQ) Performance Qualification (PQ) Change Control Standard Operations (SOPs) Maintenance Operations Company Confidential Document Control Training Business Continuity Ongoing Operations Standard Operating Procedures (SOPs) System Operation Change Control/ Upgrade Procedures Hardware Maintenance Procedures Software Maintenance Procedures Electronic Records/Data Management Procedures Incident Management Procedures System Security Procedures Training Procedures Disaster Recovery Procedures Source Code Handling Company Confidential The V-Model: A Basic Framework for Specification, Design and Testing User Requirements Specification PQ Test Plan Functional Specification OQ Test Plan Design Specification IQ Test Plan System Build Company Confidential Performance Qualification Operational Qualification Installation Qualification IQ/OQ Pre-Approved Protocol Installation Direct Impact Systems Critical Devices Calibration Operation Performance < < < Change Control Indirect/ No Impact Systems Non-Critical Devices Point to Point Start Up Trending Forms with Signatures & Dates Related Specifications Design Specification Company Confidential Functional Specification User Requirement Specification Questions?? If you want tomatoes … Don’t plant turnips! Company Confidential Company Confidential Siemens Building Technologies Irene Miess 847-941-5840 irene.miess@siemens.com Dave Barrett 905-799-9937 david.barrett@siemens.com Company Confidential