Design, Construction, Commission, and Qualification of Critical Utility Systems Part I: Overview B Y D AV I D W. V I N C E N T A N D H E R B E RT M AT H E S O N ❖ INTRODUCTION Overview of Critical Utility Systems The use of critical utility systems in the pharmaceutical industry is very important to final product quality. That is why the design, construction, commissioning, qualification, and routine monitoring of these systems is important in enssuring that the end product will maintain a reproducible quality. Critical utility systems can be considered the backbone of any production facility and should be the first systems to be validated. Without properly functioning utilities, the quality of any product will be open to question. Critical utilities found in pharmaceutical, medical device, and biotechnology production facilities usually support various equipment and processes. These utilities must meet both quantitative and qualitative specifications in order to be considered satisfactory. The actual criteria may vary from one utility system to another and may even be influenced by the particular equipment being supported. The design, construction, commissioning, qualification, and monitoring of each utility will vary depending on the system. Therefore, it is important to follow a logical, comprehensive scheme when attempting to validate or monitor these systems. This article will discuss the various phases of design, construction, commissioning, qualification, and the routine monitoring of various critical utility systems. While it takes a great deal of time and effort to qualify most critical utili- 236 Journal of Validation Technology ties, this article will only cover general procedures used to bring these systems to a validated state and, once they are validated, to establish a routine environmental program. The Routine Environmental Monitoring (REM) program is designed to ensure that the validation lifecycle is maintained for these systems. The REM program also ensures that the systems are capable of maintaining the same quality output throughout the life of the system. This article will not describe the detailed procedures needed to validate these systems. It is impractical to discuss all the existing methods and procedures used to validate utility systems within the scope of this article. However, this article will discuss an approach to integrate the commissioning and qualification phases of the project in order to streamline the qualification phase while verifying that the critical utilities meet their pre-determined design features. The critical utilities that will be addressed in the article are as follows: 1. Water systems 2. Clean steam system 3. Heating Ventilation and Air Conditioning (HVAC) systems 4. Process gases This article is the first of three-parts. Part I is an overview of critical utility systems and the planning needed before specific utilities may be addressed. David W. Vincent and Herbert Matheson User Requirement Specifications The development of User Requirement Specifications (URS) is one of the most critical elements in the compliance documentation process. A successful project is dependent on clear definition, communication, the understanding of project scope and objectives, as well as other stakeholder requirements as defined by them and the end user. At the outset of the project, after the front end conceptual study has been completed, the user must specify the requirements for individual aspects of the utility systems in terms of function, throughput, operation, and applicable regulatory requirements to the engineering service provider. This enables the development and assessment of specific engineering options. These requirements are normally formalized in a detailed URS document. The URS describes critical installation and operating parameters. It includes performance standards that are required for the intended use of the equipment and provides the basis for the qualification and maintenance of equipment. The URS should be prepared by the equipment owner in collaboration with representatives from departments that will participate in qualifying and maintaining the equipment, and from departments that will be affected by the operation of that equipment. Design Specifications and the Design Review Phase Design specifications for each system are established based on engineering and manufacturing provisions, as well as input from various organizations and departments. Design specifications are the foundation for the development of the qualification document acceptance criteria. It is necessary to track compliance with specifications throughout the validation project. In the end, validation activities will demonstrate that the design intent has been achieved through the proper tracking and control of design specifications. A formal design review process at the beginning of the project will decrease the number of deviations associated with improper control of design specifications during the execution of Installation and Operational Qualification (I/OQ) protocols. A design review process compares the design of equipment and systems with the applicable user and process requirements as defined in the current URS, processing requirements, product specifications, license commitments, manufacturing records, and applicable Standard Operating Procedures (SOP). The design review is intended to ensure and record that system design meets user requirements. One of the first steps that should be considered is defining which areas are to be qualified and what their intended uses will be. A facility room classification or design specification should be based on the product being manufactured and the processes being used. It is important that the Architecture and Engineering (A/E) team who are creating the design and layout are aware of those areas. The reasons for this are as follows:1 • To define exactly those areas for which qualification data must be developed. • To prevent any misunderstanding, either by the owner or the Food and Drug Administration (FDA), as to what areas will be subject to qualification. During a pre-construction review of the drawings with the FDA, the list of areas that were specified should be discussed. Then, if there are any differences of opinion between the owner and the FDA, they can be resolved before construction starts. It should also be added that drawings are required of the entire facility noting production features and functions. If the A/E firm knows ahead of time that as-built drawings are required, the field people who are responsible for monitoring the construction activities will make the changes to the drawings as the actual changes are being made in the field. This is the way to be assured that as-built drawings will truly be “as builts,” instead of “I think-builts.” Good Manufacturing Practices (GMPs) call for the following pertaining to layouts: • Smooth flow of personnel and product • Adequate space to perform each operation • Spatial separation, where appropriate, to prevent product mix-ups, component mix-ups, etc. • Adequate lighting • Environmental controls The design and construction of any facility requires a team effort. The Design Qualification (DQ) phase of the project requires the assistance of various departments and professionals such as Quality Control (QC) and Quality Assurance (QA), Regulatory Affairs (RA), Facilities/Engineering, Validation, Manufacturing, as well as the general contractor and sub-contractors. M a y 2 0 0 5 • Vo l u m e 11 , N u m b e r 3 237 David W. Vincent and Herbert Matheson System Level Impact Assessment A simplified approach can be summarized as follows: • Determine facility design task force (QA, QC, Engineering, Manufacturing, Validation, etc.) • Determine process environment requirements • Determine operation requirements, including personnel flow and material and waste flows • Quantify production, process, and equipment space requirements • Develop conceptual layout • Approve final facility layout • Develop detail system engineering • Prepare designs and specifications • Obtain acceptance of the design review team • Prepare bidding documents • Determine bidding and acceptance process • Determine construction start date It is important to remember that the products and manufacturing processes usually determine the design and layout of the facility. It is also important to arrange a pre-construction meeting with the FDA. This meeting can decrease the effort expended in justifying the design after the fact. By developing a formalized and well-documented design review process, the critical component, design specification, and parameters can be referenced in the validation protocols, thereby decreasing and streamlining the amount of information that requires verification in the qualification protocols. Impact Assessments Impact assessments are a formal process used to identify systems and the components of those systems that have a direct impact on product quality. “Direct impact” systems are expected to have an impact on the product quality, whereas an “indirect impact” system is not expected to have an impact on the product quality. Both systems require commissioning; however, the direct impact system will be subject to qualification practices to meet the additional regulatory requirements of the FDA and other regulatory authorities. The impact assessment process decreases the scope of IQ/OQ protocols by allowing the validation activities to focus on those systems and components that have been identified as having a direct impact on product quality, rather than all systems and components within those processes. Impact assessments should be performed on two levels: the system level and the component level. 238 Journal of Validation Technology System impact assessments are performed to differentiate those systems that have a direct impact on product quality from those having indirect or no impact on product quality. The system impact assessments are preliminary until the completion of subsequent component impact assessments for each of the systems. The results of the component impact assessments could change the results of the system impact assessments, which is why the initial system impact assessment should be considered preliminary. The advantage of performing system impact assessments is that only direct impact systems require qualification. Indirect impact and no impact systems are subject to less stringent test and inspection procedures based on business risk and typical Good Engineering Practices (GEPs). A number of utility systems that were commonly qualified in the past, such as plant steam, chill water, industrial cold water, and heating hot water, are typically no longer qualified based on the results of system impact assessments. The following summarizes the system impact assessment process: • Identification of the system and system number: This information is typically obtained from the project Process and Instrumentation Diagrams (P&IDs). Complete the system description with a general narrative of the system and its major components, design, operation, functional capabilities, and critical functions. • System Boundary Definition: Identifying the boundaries and scope of the system is typically done using the system P&IDs as well as other drawings and specifications, as appropriate. The easiest and clearest way to accomplish this is to mark the system P&IDs to identify the system boundaries and all components of the system included within those bounds. Specify system boundaries by inserting a horizontal or vertical line at the boundary. These lines should be placed to clearly identify whether or not the adjacent component is part of the system. David W. Vincent and Herbert Matheson Figure 1 ______________________________________________________________________________ Impact Assessment Questions Challenge 1. 2. 3. 4. 5. 6. 7. Yes No Does the system have direct contact with the product (e.g. air quality) or direct contact with a product contact surface [e.g.: Clean in Place (CIP) solution]? Does the system provide an excipient, or produce an ingredient or solvent [e.g.: Water For Injection (WFI)]? Is the system used in cleaning, sanitizing, or sterilizing (e.g.: clean steam)? Does the system preserve product status (e.g.: nitrogen purge for oxygen sensitive products)? Does the system produce data that is used to accept or reject product (e.g.: electronic batch record system, critical process parameter chart recorder, or release laboratory instrument)? Is the system a process control system (e.g., PLC, DCS) or does it contain a process control system that may affect the product quality and there is no system for independent verification of control system performance in place? Is the system expected to not have a direct impact on product quality, but supports a direct impact system? To help in establishing a system boundary, utilize the following general guidelines (there may be exceptions to these guidelines): ➣ If the component number of a valve, etc., is labeled as part of the main system being assessed, then it generally will be part of that system. ➣ The control system I/O for a given system will become part of that system. ➣ Disposable, flexible piping connectors, portable tanks, etc., should not be highlighted as part of the system and should be noted either on the drawing or in the comments section of the form so it is clear that not highlighting them was intentional. • System Impact Assessment: Once the system has been identified and the system boundaries defined, the impact of the system may be determined. The impact of the system is determined by answering a series of seven questions about the system. In Figure 1, the Impact Assessment Questions show how the assessment could be completed for the example of a hypothetical nitrogen gas system. System Classification The system is classified as “direct impact,” “indirect impact,” or “no impact” as follows: • If the response to any of challenges one through six in Figure 1 is “Yes,” then the system shall be classified as a “direct impact” system. • If the response to challenges one through six is “No,” but the response to challenge seven is “Yes,” the system shall be classified as an “indirect impact” system. • If the response to challenges one through seven is “No,” the system shall be classified as a “no impact” system. Based on the above criteria, the hypothetical nitrogen system would be classified as “direct impact” because it has direct product contact. Document the reasons for this classification with a brief explanation to ensure the understanding of future reviewers and approvers. M a y 2 0 0 5 • Vo l u m e 11 , N u m b e r 3 239 David W. Vincent and Herbert Matheson Component Criticality Assessments After system impact assessments have been completed, component criticality assessments are performed to identify those components within a system that have direct, indirect or no impact on product quality. The results of the component criticality assessments have a direct bearing on the validation of the system, in that IQ and OQ testing of the system can be focused on those components identified as having a direct impact on product quality. Volume 5, “Commissioning and Qualification,” of the International Society for Pharmaceutical Engineering (ISPE) Pharmaceutical Engineering Guides for New and Renovated Facilities recommends that components within direct impact, indirect impact, and in some cases, no impact systems, should be assessed for criticality. This is suggested to ensure that systems previously judged to have indirect or no impact in the early, high level assessment, have not subsequently acquired a critical function as the detailed design has progressed to conclusion. The component criticality assessment process requires the detailed review of the system P&IDs and system instrument lists. Like the system impact assessment, the component criticality assessment is performed by answering a series of questions about each of the system components. The questions proposed by the ISPE “Commissioning and Qualification Guideline” are as follows below in Figure 2. System Classification • A positive answer to any questions in Figure 2 identifies the component as a critical component that should be verified during IQ and OQ testing. • When answers to all the questions in Figure 2 are in the negative, the component is thereby identified as a non-critical component of the system that does not require verification during IQ and OQ testing. Component Approval The construction contractors translate the project specifications and design documents created by the A/E team into a completed facility. The project specifications created by the A/E team are typically detailed and often specify a component to a specific manufacturer and model, allowing the use of an “approved equal.” The construction contractors are required to submit to the A/E team technical data on the components that they intend to use during the construction of the facility so that the A/E team can approve the proposed components. Due to a number of legitimate reasons, including cost and availability, the components that contractors submit for use often do not match all the detailed specifications created by the A/E team. The A/E team reviews the technical data provided by the contractor to determine whether the proposed components are acceptable for use. Oftentimes, the Figure 2 ______________________________________________________________________________ Component Criticality Assessment Questions Challenge 1. 2. 3. 4. 5. 6. 7. 240 Is the component used to demonstrate compliance with the registered process? Does the normal operation or control of the component have a direct effect on product quality? Will the failure or alarm of the component have a direct effect on product quality or efficacy? Is information from this component recorded as part of the batch record, lot release data, or other GMP-related documentation? Does the component have direct contact with the product or product components? Are the component controls critical process elements that may affect product quality without independent verification of the control system performance? Is the component used to create or preserve a critical status of a system? Journal of Validation Technology Yes No David W. Vincent and Herbert Matheson A/E team determines that a component is acceptable even though it does not exactly match all of the project specifications; they indicate approval with a stamp on the submittal. In the real world, gaps in the submittal process are common, such as in the following situations: • Contractors often submit generic product data sheets that do not adequately specify the component that will be installed. In example, a generic valve data sheet may identify the options available for materials and finishes, but may not identify which of these options the contractor will select. • The submittal process is often slow and may not be completed for all components before the components are installed in the facility. • Submittals are often stamped as approved by the A/E but not by a designated representative of the client for whom the facility is being constructed. Submittal Review A review and approval of the submittals by the building owner is a useful process to resolve these discrepancies and to improve the efficiency of the IQ process. A submittal review should be completed for each of the critical components identified by the component criticality assessment. The submittal review process proceeds as follows: • Identify the critical component by description and tag number as appropriate. • Identify the system that contains the component. • Identify the specification number that applies to the critical component. • Identify the submittal number that applies to the critical component. • In a “Specified Attribute” column, list the critical attributes of the component as indicated in the applicable specification, such as manufacturer, model number, materials of construction, capacity, etc. • In an “Actual Attribute” column, enter the existent component information for each of the critical attributes as determined by the component vendor. Note: It is especially important to identify where the component varies from the specified attribute in order for reviewers to make an informed decision as to the acceptability of the component. • Attach supporting vendor technical literature to the submittal review form. • Appropriate representatives of the building owner should check the submittal review package. These representatives typically should include the system owner along with Facilities, Engineering, and Quality Assurance personnel. The acceptability of a component is determined based on its intended use and its compliance with project specifications. The disposition of a component is identified typically as ACCEPTED, ACCEPTED WITH COMMENTS, or REJECTED. The reviewers then approve the form. This process ensures that there is an approved submittal package for each of the critical components identified during the component criticality review. Note: The IQ protocols can be simplified, because the IQ need only verify that the installed critical components match the approved submittals by manufacturer and model numbers. This is allowed because the critical attributes of the components have already been approved through the submittal review process. Systematic Risk Assessment for System Qualifications The Risk Assessment section discusses the potential impact on current Good Manufacturing Practice (cGMP) operations associated with the use of the equipment, and the steps that will be taken to reduce those risks. Identify conditions that could lead to failure of the equipment and the effects of failure on cGMP operations. Evaluate the degree of risk to product quality, company operations, and the safety of personnel and equipment. During the risk assessment, it is important to perform an impact assessment on the system. An impact assessment is the process by which the effects of the system - and the critical components within those systems - on product quality are evaluated. System risk assessment is measured in a minimum of three categories: direct product impact, indirect product impact, and no direct product impact. By performing design impact assessments, companies can reduce the scope of the systems and the components subject to qualification, and allow appropriate focus to be placed on the components that may present a potential risk to the product. M a y 2 0 0 5 • Vo l u m e 11 , N u m b e r 3 241 David W. Vincent and Herbert Matheson Risk Assessment Example The elements in Figures 3 and 4 indicate one example of how applying risk assessment to a validatable system can be beneficial in developing a scientific rationale and justification for the selection of the different types of qualification needed to support a system. Figure 3 ______________________________________________________________________________ Impact Analysis • Summarize risks and associated controls in an impact and complexity analysis. Rate the impact of the equipment on product quality, safety, and purity, and on the safety of personnel and equipment. Evaluate the systems in place to control those risks. A. Quality Impact Score No impact: Equipment will not be directly or indirectly associated with cGMP activity. Minimal impact: Equipment indirectly affects cGMP processes or procedures. (Non-direct product impact) Potential Impact: Equipment performs or directly supports a cGMP process or procedure; failure could potentially affect product quality. Equipment failure could negatively impact operational efficiency or costs. (Indirect product impact) Direct Impact: Equipment is an essential component of a cGMP process or procedure, or is in direct contact with the drug substance or product. Equipment failure could result in loss of product; safety hazard; damage to materials, equipment, or facility; or negative inspection findings. (Direct product impact) B. Quality Risk Management Journal of Validation Technology 1 2 3 Score No risk control necessary. Failure of the equipment would be detected immediately and be corrected before affecting a cGMP process or procedure. Failure could not go undetected. Systems and procedures are in place to detect negative impact on product quality safety or purity before significant loss of productivity. Failure could potentially go undetected and cause failure of other processes or procedures. 242 0 0 1 2 3 David W. Vincent and Herbert Matheson Figure 4 ______________________________________________________________________________ Complexity Analysis • Describe the technological risks and controls associated with the equipment. The complexity analysis evaluates the risk of failure due to technical sophistication of the equipment, and the relative difficulty of maintaining the equipment in a state of control. C. Technology Risk Score Very simple system; minimal chance of failure. Commonly understood technology, rugged equipment; low probability of failure. Somewhat complex equipment, generally reliable technology, components, and controls. Highly complex or sensitive equipment, sophisticated technology, unique components, or processes. D. Technology Risk Management 0 1 2 3 Score Control and repair possible without impacting cGMP activities. Equipment requires that minimal training, simple maintenance procedures; backup, repair, or like-for-like replacement is readily available. Requires trained operators and maintenance technicians. Backup systems, repair, maintenance, and replacement are readily available. Operators and maintenance technicians must be highly trained. Maintenance, repair, or replacement requires specialized or time-consuming effort; backup systems, repair, maintenance, or replacement are not readily available. 0 1 2 3 Risk Score • The calculation used to evaluate the overall risk (as seen in Figure 4) of the equipment combines the individual impact and complexity scores in the following formula: (A + B) x (C + D) Where: A = Quality Impact B = Quality Risk Management C = Technology Risk D = Technology Risk Management M a y 2 0 0 5 • Vo l u m e 11 , N u m b e r 3 243 David W. Vincent and Herbert Matheson Validation Requirements Identify the qualification requirement for the equipment based on the impact and complexity analysis as shown in Figure 5. For smaller, less complex system qualification, protocols can be combined into I/OQ or IQ/OQ and Procedure Qualification (PQ) protocols. Any additional information to support and justify the validation requirements should be included. Figure 5 ______________________________________________________________________________ Qualification and Validation Justification Risk Score Qualification Requirements 0 Document installation and commissioning 1 to 3 IQ Validation Maintenance Requirements • • • 4 to 6 • IQ/OQ • • ≥7 IQ/OQ/PQ • • 244 Journal of Validation Technology Documentation maintained by users or Facilities Department. Installation, commissioning, maintenance, and change control documentation maintained by QA. Operate, maintain, and calibrate according to written SOPs. Document preventive and corrective maintenance and calibration according to SOPs. Apply change control procedures according to SOPs and change control programs. Perform operation, maintenance, calibration, and performance verification tasks according to written procedures. Document preventive and corrective maintenance and calibration according to SOPs. Apply change control procedures according to SOPs and change control programs. David W. Vincent and Herbert Matheson Construction Qualification (CQ) Activities The construction of a pharmaceutical manufacturing facility requires strict adherence to the requirements outlined in the Code of Federal Regulations (CFR), title 21, section 211.42 of the cGMPs2 for processing human drugs and newly proposed regulatory requirements. A great deal of emphasis is placed on design compliance with cGMP requirements, but the effects of construction issues on cGMP compliance are profound and must be understood by owners, facility operators, and contractors. Integration of construction and qualification activities is critical to a successful validation project. Document procurement and the verification and documentation of construction activities are critical to supporting Installation Qualification (IQ). The proper integration of qualification and construction, commissioning, and startup activities will: • Accelerate the start-up effort. • Produce superior documentation. • Reduce time to completion of subsequent IQ and OQ activities. • Ensure that product is produced in a GMPcompliant facility. Critical Systems The following are common critical systems that should be inspected during the CQ phase: • Cleanroom HVAC • Purified Water (WP) system • Water For Injection (WFI) system • Computerized systems • Product contact compressed gases • Clean-in-Place (CIP) systems • Product Piping systems • Architectural finishes Documentation In order to utilize tests and inspections performed during the construction phase of the project, it is necessary that the tests be performed and documented in compliance with cGMP requirements, including: • The tests and inspections must be performed per written and approved procedures. • The personnel performing and documenting the tests and inspections have been trained in the test procedures, and that training has been documented. • The test results have been documented using Good Documentation Practices (GDP). The SOPs necessary to support these requirements must be reviewed and approved by the appropriate contractor and the QA Department owner. The following is a partial list of typical SOPs necessary to support the integration of construction activities into the qualification process: • Contractor training • Good Documentation Practices • Equipment and component receipt verification • Red line drawing control • Air duct cleaning and inspection • Air duct leakage testing • HEPA filter installation • HEPA filter leak testing • Boroscope inspection procedures • Slope verification procedures • Weld inspection procedures • Weld log procedure • Welder qualification procedures • Piping system walk down procedures • Hydrostatic pressure testing • Pneumatic pressure testing • Cleaning and passivation • Clean build protocol Coordinator and Team Members Depending upon the project size, a CQ coordinator and CQ team with engineering and construction background, should be assigned to monitor and document the construction activities necessary to support the qualification process. A CQ coordinator is most successful in the role when he or she reports directly to the client or is a representative of the client. This direct reporting relationship will eliminate the conflict of interest that would derive from the coordinator being part of the construction company. The Construction Qualification Team is tasked to perform the following duties: • Work closely with the general contractor and mechanical contractors, to procure, verify, and organize documentation for the Turn Over Packages (TOPs) for direct and indirect impact systems as part of Good Engineering Practices: ➣ ➣ ➣ ➣ ➣ Project specifications Vendor or manufacturer submittals Manufacturer mechanical specifications Purchase orders Vendor test reports M a y 2 0 0 5 • Vo l u m e 11 , N u m b e r 3 245 David W. Vincent and Herbert Matheson ➣ ➣ ➣ ➣ ➣ ➣ ➣ ➣ ➣ ➣ ➣ ➣ Material certifications Calibration data State and local code compliance ASME, ANSI, and other certifications Pipe specifications Cleaning and passivation reports Stainless steel weld documentation Instrumentation specifications Drawings Material and finish verification MSDS Any other useful documentation • Monitor the construction schedule as it relates to validation activities to ensure that the required tests and inspections are documented. • Verify during component receipt inspection that the actual components delivered to the jobsite match the components approved for use during the submittal review process. This requirement applies to the components identified as being critical during the component criticality assessments. • Witness tests and inspections performed during the construction process necessary to support the qualification of the critical utility systems. The tests and inspections should be witnessed to assure that the procedures are performed according to specifications and should be fully documented. • Audit the construction site for cleanliness and compliance with specified construction sequences, practices, and craftsmanship standards. Enter observations into a Construction Site Audit Log. • Document and report any problems that may affect the construction schedule or have a negative impact on the qualification phase of the project. Specific Documentation Packages Format Items listed in the previous sections are included in the CQ packages according to the following guidelines: ➣ CQ Summary Sheet The CQ Summary Sheet, placed before the CQ packages defined here, will briefly describe CQ findings. Specific items for discussion should include identification of construction and installation contractor(s), start and completion dates, historical overview of CQ effort, and a description of CQ documentation. Both the CQ coordinator and project manager, serving as approval for the entire CQ package, will approve the CQ Summary Sheet. ➣ CQ Section Index The CQ Section Index shall list all major CQ sections. Figure 6 ______________________________________________________________________________ Tests Required for Two Common Critical Utility Systems System Test or Inspection HVAC WFI 246 Critical component receipt inspection Air duct cleaning and inspection Air duct leakage testing HEPA filter installation HEPA filter leak testing Drawing verification Critical component receipt inspection Weld documentation and inspection Hydrostatic pressure testing Slope verification procedures Drawing verification Cleaning and passivation Journal of Validation Technology David W. Vincent and Herbert Matheson ➣ Project Specifications Project specifications are provided by the architect(s) of the project and serve as guidelines for construction. Only those project specification sections applicable to the CQ system should be included. ➣ Purchase Orders All available purchase orders for equipment and materials within the system will be included. Each individual purchase order will be included in a separate subsection. Dollar amounts may be removed. ➣ Purchase Specification The Purchase Specifications section will immediately follow "Purchase Orders." Purchase specifications should include documentation provided from the vendors, contractors, and manufacturers. Purchase specifications should serve as succeeding documentation for the Installation Qualification (IQ) protocol of the CQ system. In addition, those areas of the purchase specification giving direct evidence to IQ requirements should be highlighted, using a single color. ➣ Test Reports The Test Reports section will immediately follow Purchase Specifications. Test reports include documents such as pressure test reports, factory test reports, and certifications. Test reports included in CQ packages should depict the static attributes of the system, not operational testing. Wherever practical, the CQ coordinator or validation team member should witness tests. ➣ Drawings The Drawings section will be the final section of the CQ package. Drawings will be classified as either reference or as built. Reference drawings should be reviewed and signed by at least one person, while as-built drawings should be reviewed and signed (and red lined, if necessary) by at least one person. (It is desirable to have two reviewers for as-built drawings.) Figure 7 _____________________________________ Table of Contents Example for a Typical CQ Package Section 1 - General 1. DESIGN SPECIFICATIONS 2. PURCHASE ORDERS Section 2 - Equipment 3. EQUIPMENT DATA SHEETS 4. EQUIPMENT CHECKLIST 5. SPARE PARTS LIST 6. VENDOR TEST REPORTS 7. VENDOR CERTIFICATION • ASME • ANSI • MATERIAL CERTIFICATIONS 8. OPERATION AND MAINTENANCE MANUALS 9. DRAWINGS Section 3 - Piping and Duct 10. SPECIFICATION LIST/INDEX 11. MATERIAL CERTIFICATIONS 12. WELD DOCUMENT • WELDER QUALIFICATIONS • WELD LOG • WELD INSPECTIONS • WELD AUDIT 13. HYDROSTATIC TEST REPORTS 14. CLEANING REPORTS 15. PASSIVATION REPORTS 16. LINE SLOPE VERIFICATION 17. VALVE LABEL VERIFICATION 18. LINE LABEL VERFICATION 19. TAG INSPECTION 20. LINE SUPPORT Section 4 - Drawings 21. PIPING AND INSTRUMENTATION DIAGRAMS 22. ISOMETRIC 23. RED-LINED DRAWINGS ➣ Additional Sections Any additional sections will be included in the CQ between the Test Reports and the Drawings sections. M a y 2 0 0 5 • Vo l u m e 11 , N u m b e r 3 247 David W. Vincent and Herbert Matheson ➣ Review Once each document is received and verified, it should be stamped "CONSTRUCTION QUALIFICATION Reviewed by" the CQ coordinator with signature and date. Note: There is no clear demarcation between the construction qualification and commissioning phases of the project. CQ and commissioning activities will often take place concurrently. As in the CQ phase, tests and inspections performed during the commissioning phase of the project must be performed and documented in compliance with written and approved SOPs. ➣ CQ Section Index The CQ Section Index listing all major CQ sections should be included immediately following the CQ Summary Sheet. Aspects of Commissioning Commissioning and Startup The ISPE Baseline Guide, Volume 5, defines commissioning as: "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 stakeholder expectations." The commissioning phase of the project, which typically occurs after mechanical completion of the system and prior to turnover of the system to the owner, is another opportunity to integrate qualification activities into the facility construction, commissioning, and start-up process. While the qualification activities during the construction phase of the project primarily support IQ, qualification activities during the commissioning and start-up phase will primarily support Operational Qualification (OQ). Pharmaceutical manufacturing facilities, laboratories, and even office buildings demand a complete program of start-up, functional challenge, training, documentation, and turnover. It is incumbent upon the individuals responsible for design and construction to finish the job by handing over a completely operable and documented facility so that validation activities can follow with minimal problems. Too often, an owner's project manager will move on to his or her next big project before the whole job is finished, leaving maintenance technicians, facility operators, and validation personnel with the tasks of: struggling to locate as-built documents, making equipment work, calling vendors for training, working off the punch list, and attempting to enforce warranties. 248 Journal of Validation Technology Commissioning activities should encompass all aspects of the completion phase of any facility built. Some of the key aspects include: • • • • • • • • • • • • • Organizing and planning Factory testing Static testing (pre-commissioning) Operator training Walk down and tagging Startup reports Full functional testing Turnover and punch lists As-built documentation System and equipment manuals Spare parts management IQ documentation (as applicable) OQ documentation (as applicable) Commissioning Team Every project team needs a leader who is empowered by the company to manage the project from start to finish, from inception to completion. "Completion" should be defined as a time when the appropriate signatures on all punch lists, commissioning documents, as-built drawings, validation protocols, and SOPs are attained. The project leader or project manager should not leave the project until the "ink is dry" on each of those documents. Organizing and planning for commissioning are the keys to a successful project. Each of the project members should report to one individual, who can ensure that all project objectives (cost, quality, schedule, safety, etc.) are continuously considered in decision making. Commissioning suffers when the project team does not plan or organize itself early enough. The commissioning manager must be selected early and should report to the project manager. By early selection, the commissioning manager David W. Vincent and Herbert Matheson and team can plan for completion when project engineers and construction staff are actively involved in the daily rigors of construction. Selection of the commissioning manager is extremely important; the individual must have operations experience as well as good planning and interpersonal skills. The commissioning manager must then select an appropriate complement of field technicians, calibration and metrology staff, document specialists, and technical writers. Some of these individuals may be sometimes "loaned" by maintenance and operation groups and then returned to those groups after project completion. In fact, the loaning of team members is often the best solution because it enables startup knowledge to transfer from project team to operations. • Pre-Delivery Activities Provide detail and instructions for each pre-delivery activity. Examples of pre-delivery activities include: ➣ Control of specifications ➣ Review of vendor submittals ➣ Vendor audits ➣ Third party inspections of off-site fabrication ➣ Module and equipment vendor quality control and inspections ➣ Factory Acceptance Testing (FAT) ➣ Factory inspection plan Commission Plan • Equipment and Material Receipt Control The commission plan is, properly, one of the most important criteria documents that will be used on the project. The commissioning plan should indicate the various commission activities for both GMP and non-GMP systems. The plan should identify the overall commissioning strategy for the project and complement the Validation Master Plan (VMP) to identify the integration of commissioning and validation activities. It also should define the roles and responsibilities of each functional department and their vendors as they relate to the commissioning and integration of the qualification activates. The following items describe the key elements of successful commissioning plan: • A description of the equipment and systems to be commissioned including their means of automation • A description of the methods and tools to be used in commissioning execution • A detailed description of the commissioning strategy including integration of commissioning and validation activities • Overall sequence of commissioning activities • A detailed description of project deliverables including identification of the parties responsible for providing the deliverables • Roles and responsibilities of personnel involved in the commissioning effort throughout construction and commissioning The commissioning plan should include a strategy for integrating the qualification phase into the commissioning activities. Describe the procedures, documentation, and methods of control to be utilized for equipment and material receipt. The system should include the following: ➣ Approving and rejecting components and equipment ➣ Defining storage locations and conditions for critical components (direct contact copper tubing verses non-critical copper) to minimize mix-up ➣ Separation of non-GMP materials from GMP materials • Construction Quality Assurance Activities It is critical to define the role and responsibility of the quality unit during the commissioning phase. While it is clearly understood that commissioning is usually an engineering function, sometimes it is not clear what the Quality Unit role is during the commissioning phase of the project. During the engineering phase of the project, QA may audit the approved equipment and utility system vendors to verify that they have the necessary quality systems in place to ensure the quality of their product or service. Part of the integration concept also involves auditing design and construction activities for compliance with cGMPs, verifying documentation, and keeping a close eye on the installation progress throughout the project’s construction phase. The Quality Unit must be aware that GMP requires qualification activities. Whether some of the qualification is performed during the commission phase or not, the regulations require these activities be reviewed and signed-off by the Quality Unit. Therefore, if any aspects of the qualification M a y 2 0 0 5 • Vo l u m e 11 , N u m b e r 3 249 David W. Vincent and Herbert Matheson activities are being captured during the commissioning phase, the Quality Unit must at least agree and sign-off on the commissioning plan or strategy. (Because some qualification activities are integrated into the commissioning phase does not mean that they are no longer GMP activities.) ➣ Describe the roles and responsibilities for all project quality control and quality assurance activities. ➣ Define the scope of the quality control program, authorized documentation, and responsibilities for the implementation and maintenance of the program. ➣ Detail the requirements for in-process inspections and the methods to be used to document the inspections. ➣ Describe the requirements for the creation, maintenance, and verification of red-line, as-built drawings ➣ Specify the requirements, methods, and procedures to be utilized for foreign material exclusion for direct impact components and materials. ➣ Startup and Formal Commissioning This section of the commission plan should describe, in detail, the components of startup and commissioning execution. Components may include: • Special pre-startup checks • Notification to stake holders that startup activities will commence that may affect certain process equipment or systems, i.e.: backup generator, etc. • Startup procedures • Setting to work and initial shakedown • Software structural testing • Inspections • Functional testing • Cycle development • Special testing ➣ Commissioning Documentation and Turnover Packages • Commissioning Execution ➣ Pre-Commissioning A pre-commissioning phase includes the completion of tasks necessary to verify that the system is mechanically complete and ready for the initiation of subsequent commissioning activities. These activities include: • Mechanical completion • Safety reviews • Code inspections • Site Acceptance Testing • Tagging and labeling verification • Valve or damper lineups • Installation of temporary strainers and filters • Walk down of the system This section of the commission plan should describe, in detail, the commissioning documents and requirements for turnover packages. Components may include: • Commissioning Documentation that specifies the requirements for commissioning including: required documentation, references, documentation practices, and final reports. • Turnover Packages, which provide an outline of the procedures and requirements for the assembly and turnover of system manuals and other turnover packages. ➣ Commissioning Completion and Turnover to Owner This section of the commission plan should describe, in detail, the commissioning completion and turnover to owner. Project closeout procedures, deliverables, and responsibilities must be clearly defined well before construction commences. The method of project turnover, whether phased or in single project completion turnover package, should be clearly defined in this section. 250 Journal of Validation Technology David W. Vincent and Herbert Matheson Components of turnover strategy may include: • Deliverables including final release of liens, certificate of occupancy, final as-built drawings and specifications, turnover packages, finalized punch list, etc. • Project supplied training • Spare parts • Owner acceptance of operational responsibilities Commissioning Documentation List Commissioning starts with the preparation of many lists, which ultimately form the foundation for planning and document management. An orderly set of equipment lists, instrument lists, vendor lists, etc., will allow the commissioning manager to organize his thoughts and begin paying attention to details early. The key to preparing the needed lists is an exhaustive review of all systems in the facility and selecting the right number of turnover packages. This is best accomplished by reviewing Process Flow Diagrams (PFDs) or P&IDs, key documents for any manufacturing facility. These diagrams are best used to distinguish the boundaries of each system. The turnover packages will become a central theme for commissioning and will be described later in more detail. The various lists may well be the most tedious and timeconsuming part of the commissioning manager's job. A few of the key lists and the related data are recommended below: Drawings and Specifications List • Drawing or revision number(s) • Drawing title • Drawing status • Drawing developed by . . . • Final walk down completed on . . . • Applicable system number (cross reference) Equipment List • Equipment tag number (should match maintenance system tag) • Equipment name • Critical or non-critical? • P&ID reference • Vendor name • Installation date • Vendor submittal received (date and time) • SOP required? (yes or no) • Start-up date • Applicable system number (cross reference) Instrument List • Instrument tag number • Instrument name • Critical or non-critical? • P&ID reference • Vendor name • Manufacturer submittal received (date and time) • Local or panel mounted The Role of Qualification Phase in Commissioning Qualification is a process that focuses on systems affecting product quality - those defined as direct impact systems during the system impact assessment process. However, this represents only a fraction of what must be done to properly commission and document an entire facility. The qualification phase, therefore, must be considered a part of the commissioning umbrella. IQ and OQ activities should be planned to take advantage of key commissioning activities, which take place in parallel. As the schedule indicates, commissioning and qualification should start together and should be executed together. Validation documents should be considered supplemental and complimentary to commissioning documents, and duplication should be avoided. This approach, if adopted, will yield the earliest possible project delivery. Figure 8 is a typical validation flow chart. Use of an Integrated and Streamlined Validation Approach One cost effective method for managing the validation project is the using of an integrated and streamlined approach to optimize commissioning and validation activities on a project. Using an integrated approach, project success would include the following benefits: • Reduced project schedules and better overall schedule management • Reduced start-up time needed in the field • Reduced project costs • Fewer defects or deviations during the qualification phase • Reduced internal resource needs at the end of the project M a y 2 0 0 5 • Vo l u m e 11 , N u m b e r 3 251 David W. Vincent and Herbert Matheson Figure 8 ______________________________________________________________________________ Typical Validation Flowcart Engineering Validation Front End Concept Study Validation Master Plan (VMP) Engineering Specifications/User Requirement Specification (URS) Functional and Detail Design Generate and Address Snag List GMP Audit, Design Qualification (DQ) and Impact Assessment Factory Acceptance Test (FAT) Tender Procedure and Construct Generate and Address Snag List Pre-delivery Inspection (PDI) Protocol Development Install Commission Generate and Address Snag List Formal Project Turnover Generate and Address Snag List Formal Installation Qualification (IQ)/ Operational Qualification (OQ) Formal Equipment Performance Qualification (EPQ) Release and Use Decommissioning Periodic Review, Change Control and Revalidation 252 Journal of Validation Technology David W. Vincent and Herbert Matheson • Adherence to compliance requirements • Overall project quality improvement During streamlining, the commissioning and validation activities should adhere to the following basic principles: • Start the project by evaluating the impact of a system on product quality • Focus resources on the qualification of systems with "direct impact" on product quality according to GMP • Focus on critical components that will have a direct impact on the project quality • Establish system boundaries in the early phase of the project • Evaluate system design from both a quality perspective and a risk-based approach • Provide contractors, vendors, and engineers with the project validation requirements up-front to enable them to plan installations to meet these requirements • Design and commission those systems that have no "direct impact" on product quality according to GEP • Enhance the commissioning, qualification, and validation documentation generation, review, and approval processes • Integrate the commissioning and qualification activities to avoid duplication of work • Conduct training of employees, contractors, consultants, and other personnel early in the project lifecycle Strategies The following section includes some detailed strategies that could be followed to reduce project resource requirements and improve the efficiencies of the commissioning and validation programs. Integrate Validation Schedules into the Overall Project Schedule The project manager, with support of team members, should ensure the development of a commissioning and validation plan as an integral part of the project plan and schedule. Integrating validation into the overall project schedule can save both time and money. Integrated schedules should be developed with input from the construction and validation project teams and be maintained and updated at regular intervals. IQ/OQ may be conducted as part of the physical com- pletion of the facility, thus tying IQ/OQ closely to the construction contractor’s scope of work that includes commissioning. To avoid the effort and inconvenience of discovering and rectifying basic problems, it is recommended that all systems go through an informal shakedown phase before IQ/OQ commences. This will help ensure a smooth transition between IQ and OQ, and will minimize the number of deviations that may occur during the IQ and OQ phases. Scheduling of PQ is particularly critical because PQ testing is often the most time consuming part of the qualification. Scheduling should take into account any prerequisites that should be achieved prior to PQ execution (such as commissioning of all support systems, availability of SOPs, system interdependencies). The PQ protocol often receives the greatest amount of scrutiny from the approval team. Again, it is important that IQs and OQs are completed and that there are no major deviations that may have negative impact on the PQ phase. Integrate Commissioning with Validation Activities There are considerable advantages of time, cost, and quality in integrating the many functions carried out by skilled resources, such as engineering, contractor, and validation teams. The responsibility for timely and appropriate execution should be a combination of both the validation and engineering teams, this will reduce the time spent on validating the facility and scaling up to production. The use of a competent, expert, multi-disciplinary team will ensure that best practice is deployed and that duplication of activities is avoided. Integrating activities such as Design Qualification, Construction Qualification, Factory Acceptance Testing, Site Acceptance Testing and commissioning into qualification and validation activities can control validation costs and minimize project delays. Instruments, components, and equipment can be verified at the vendor site during the FAT and CQ phases of the project. This reduces delays caused by identifying potential problems before equipment is delivered to the job site. If these items are not altered or dismantled in any way for transport, these checks, if properly documented, could be used in support of SAT or qualification activities. For OQ, the duration of the testing can be shortened by identifying the critical operational criteria that require testing prior to the facility, utility, or equipment being used in production and planning the schedule accordingly. This can be performed by determining which functional controls are critical and non critical in the early stages of the DQ phase of the project. Testing the non-critical functions M a y 2 0 0 5 • Vo l u m e 11 , N u m b e r 3 253 David W. Vincent and Herbert Matheson during the FAT or SAT will reduce the amount of testing required during OQ phase. If FAT is executed for equipment, i.e., alarms and interlocks testing, some or all of these tests can be performed at the vendor site, or these tests can be performed as part of commissioning, and can be used in support of the OQ. Performance testing carried out as part of commissioning can contribute to PQ when performed consistently with qualification practices. Thus, if the integrated approach is used and proper inspections, field verification, documentation, and certain required field execution work is accomplished by the construction vendors and contractors, then the qualification scope can be reduced to that of review, verification, cross linkage to FAT and SAT documents, monitoring, and compiling. The integration of commissioning and qualification merges activities, minimizes resource requirements, and streamlines the validation effort by reducing the number of protocols and reports. Approaches to streamline the amount of paperwork required to give sufficient documented evidence of validation may include: • Using standardized protocol and report templates wherever possible, so that reviewers become accustomed to protocol formats and contents. • Using procedures and forms that can minimize redundancy normally found in qualification protocols. • Structuring executed protocols as reports to obviate the need for writing a separate report. • Combining IQ and OQ documents (to I/OQ) will result in fewer documents to develop, track, review, and approve. However, the IQ section must be completed before OQ commences. • Including only critical tests in the protocol, and not repeating non-critical ones already conducted in FAT or SAT phases, simply verifying that these test have been performed in the qualification protocols. • Understanding upfront the critical and test items to be included in the qualification can reduce both cost and unnecessary deviations. • Establishing realistic protocol acceptance criteria based upon the process demands for reproducibility and product quality. • Recording deviations in the qualification protocol attachments and then having them immediately reviewed and approved by the Quality Unit rather then waiting until the entire protocol is executed. • Ensuring that commissioning documentation for 254 Journal of Validation Technology direct impact systems are appropriately planned, created, organized, and authorized so that they may become an integral part of the qualification support documentation. • Combining engineering and validation information to minimize duplication. Once qualification protocols are written, they should be approved, and this may be a time consuming process. Several ways to streamline this process include: • Minimizing the number of approvals required by developing approval matrixes. • Clarifying the review process with all parties early in the project. • Instituting a formalized protocol tracking process. • Minimizing the number of review cycles allowed by the team. • Implementing a simple review and approval procedure with time limit for the review cycle. • Instituting protocol review meetings for all parties involved. • Ensuring the protocol review and approval process is included in the overall project schedule. Define which activities the vendors are responsible for executing when utilizing an integrated approach to commissioning and validation activities. Figure 9 is an example of the integration of commissioning, qualification testing, and verification activities related to WFI skid and distribution system (See Figure 9): Note: Vendors performs 100% loop check during commissioning phase. Validation engineer performs 10% during Qualification Phase. If failure is detected during the 10% verification, then 100% inspection is performed by validation engineer or validation engineer witnesses 100% performed by vendor. ❏ David W. Vincent and Herbert Matheson Figure 9 ______________________________________________________________________________ Commissioning and Qualification Integration Approach Tests and Verification Activities Functional Design, Verification, and Design Specifications Facility As-built and Piping and Instrumentation Drawings Electrical drawings Critical Component Verification Materials of Construction Welding Documentation Alarm and Interlock Test Control System Component Verification Hydrostatics Testing Material Incoming Receipt Cleaning and Passivation Steam in Place Startup Surface Finish Documentation Report Vent Filter Integrity Spare Part Inventory Operation Control Function Non-Critical Operation Control Function Critical Software Installation Verification Operation and Maintenance Procedures Verification Pump and Motor Checkouts (Rotation, Lube, Alignment, Belt, etc.) Control System Function *Loop Check Verification Compliance (ASME Certifications) Control System Security Access and Password Protection Sequence of Operations Radio Frequency Interference Test Voltage test Shut Down and Startup sequence Data Trending Ability Operation Parameter Control Baseline Performance CQ = Construction Qualification IQ = Installation Qualification SAT = Site Acceptance Testing Commissioning Phase Qualification Phase CQ FAT ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ SAT IQ ✓ PQ ✓ ✓ ✓ ✓ ✓ OQ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ DQ = Design Qualification OQ = Operational Qualification ✓ ✓ ✓ FAT = Factory Acceptance Testing PQ = Performance Qualification M a y 2 0 0 5 • Vo l u m e 11 , N u m b e r 3 255 David W. Vincent and Herbert Matheson This is the first part of a three-part article. Parts II and III will be published in the Journal of Validation Technology in the August and November 2005 issues, respectively. About the Author David W. Vincent has over 25 years experience in the Biopharmaceutical industry with 19 years dedicated to the fields of validation and engineering. He has a BS degree in Microbiology and Mechanical Engineering Technology; Mr. Vincent has consulted for many companies both nationally and internationally. He has presented many training seminars and has written numerous articles and technical guides regarding validation topics. Mr. Vincent teaches "Validation Program for the Pharmaceutical, Biotechnology, and Medical Device Industries" at San Diego State University (SDSU) for their Regulatory Affairs Master Degree program. Currently, Dave is the Chief Executive Office (CEO) for Validation Technologies Incorporated (VTI), a worldwide validation and technical services company. VTI is also a certified commissioning company that offers commissioning and startup functions for the healthcare industry. Dave can be reached by phone at 800-930-9222, by fax at 858-638-5532, or by email at david@validation.org. (Web Site is located at www.validation.org) The following references are those applicable to Part I. The full list of references used in the three-part article will appear with Part III in the November 2005, Journal of Validation Technology. References 1. Center for Drugs and Biologics, Center for Devices and Radiographic Health, "Guidelines on General Principles of Process Validation," FDA Rockville, Maryland, 1987. 2. "cGMP Compliance in Architecture and Construction of Biopharmaceutical Manufacturing Facilities" BioPharm, Prepared January-February, 1993. 3. "Code of Federal Regulations Section 21 Parts 200 to 299 and Parts 600 to 799," Food and Drugs Administration (FDA). 4. "Guidelines for Bulk Drug Manufacturers," Food and Drugs Administration (FDA). 5. Center for Drug Evaluation and Research, Center for 256 Journal of Validation Technology Article Acronym Listing A/E ANSI ASME CFR cGMP CIP CQ DCS DQ FAT FDA GDP GEP GMP HEPA HVAC I/O IQ ISPE MSDS OQ P&ID PFD PLC PQ PW QA QC RA REM SAT SOP TOP URS VMP WFI Architecture and Engineering American National Standards Institute American Society of Mechanical Engineers Code of Federal Regulations Current Good Manufacturing Practice Clean in Place Construction Qualification Design Qualification Factory Acceptance Test Food and Drug Administration Good Documentation Practice Good Engineering Practice Good Manufacturing Practice High Efficiency Particulate Air Heating, Ventilation, and Air Conditioning Input/Output Installation Qualification International Society for Pharmaceutical Engineering Material Safety Data Sheet Operational Qualification Process and Instrumentation Diagram Process Flow Diagram Performance Qualification Purified Water Quality Assurance Quality Control Regulatory Affairs Routine Environmental Monitoring Site Acceptance Testing Standard Operating Procedure Turn Over Package User Requirement Specification Validation Master Plan Water For Injection Biologics Evaluation and Research, Office of Regulatory Affairs, "Guidelines on Sterile Drug Products Produced by Aseptic Processing," FDA Rockville, Maryland, June 1987. 6. Center for Drug Evaluation and Research, Center for Biologics Evaluation and Research, Office of Regulatory Affairs, "Guidelines on Sterile Drug Products Pro- David W. Vincent and Herbert Matheson duced by Aseptic Processing," FDA Rockville, Maryland, June 1987. 7. PDA Environmental Task Force, "Fundamentals of a Microbiological Environmental Monitoring Program," Vol. 44, Supplement 1990. 8. "Microbiological Control and Validation," The Institute for Applied Pharmaceutical Sciences, March 7-9, 1994. 9. Powell-Evans, K., "Streamlining Validation; Value Added Qualifications." Institute of Validation Technology. December 2000. Newsletter. 10. Graham C. Wrigley, Pfizer Global Manufacturing, and Jan L. du Preez, Ph.D., "Research Institute for Industrial Pharmacy Facility Validation: A Case Study for Integrating and Streamlining the Validation Approach to Reduce Project Resources," Volume 8, Number 2, February 2002. M a y 2 0 0 5 • Vo l u m e 11 , N u m b e r 3 257