Basic Principles of GMP 3. Validation (and Qualification) 1 Validation, Qualification Two phylosophies: • Validation, qualification (and calibration) are different, although interrelated activities (e.g. EU GMP) • Qualification and also calibration belong to validation activities (e.g. WHO GMP) 2 Terms Qualification or validation? • A system/equipment must be qualified to operate in a validated process • Qualify a system and/or equipment • Validate a process • Qualification versus validation, e.g. you qualify the autoclave, while you validate the whole sterilization process • (and calibrate a measuring instrument!) 3 Validation Introduction Three basic principles of Quality Assurance: • Quality, safety, efficacy • Cannot inspect quality into a product • Processes must be under control (for this, they should be validated, whether they can be under control! 4 Validation Objectives • To review the definition and types of validation • To understand the requirements for documentation and key stages in the process of validation • To consider models for process validation 5 Validation Definition Validation is the documented act of proving that any procedure, process, equipment, material, activity or system actually leads to the expected result 6 Validation Qualification and validation work require: • Collaboration of experts • Budget • Meticulous and careful A Validation Master Plan helps the manufacturer and inspectorate planning 7 Validation Essential Part of GMP • • • • • Predetermined protocols Written reports Processes and procedures Periodic revalidation Specific attention: – processing process validation – testing analytical method validation – cleaning cleaning validation 8 Validation Types of Manufacturing Process Validation • Experimental approach – Prospective validation – Concurrent validation • Analysis of historical data – Retrospective validation • Revalidation – Periodic revalidation – Revalidation after change 9 Prospective validation • Before starting a new manufacturing process (or after its significant change), or revalidation: • Manufacturing 3 batches only for validation purposes, all data documented. Reason: to see that the process is under control • As a rule, these batches are not marketed later, except special decision to do that 10 Concurrent validation • In case of rarely produced medicines (e.g. 2 batches per year: no reason to produce 3 „validation” batches) • Concurrent validation: during the manufacture of „normal” batches to be marketed • Strict documentation! 11 Retrospective validation • This validation means the assessment of data generated during previous batch manufacturing • Only for established technologies, the GMP is strictly applied, defects are rare • Assessment of data of 10-30 batches, including defective ones (their data are very valuable to see how the process can run out of control!) 12 Qualification Types (Stages) of Qualification • • • • Design qualification (DQ) Installation qualification (IQ) Operational qualification (OQ) Performance qualification (PQ) 13 Design qualification DQ • E.g. of a manufacturing equipment • Before purchasing! • Collection of data about the similar equipments available on the market, assessing our needs, resources to buy and to operate, space and maintenance they would need, etc. • Making the decision 14 Installation Qualification IQ • E.g. of a manufacturing equipment • After purchasing (or critical repair) • Put it on its intended place, connect with other equipments, electric power, material flow devices • Collect its documents incl. Operation Manual, etc. • Its formal „release”: it is ready for working with 15 Operational Qualification OP • E.g. of a manufacturing equipment • „Model manufacturing” experiments with model materials, similar to those to be used in the real manufacture • E.g. qualifying an autoclave we use culture-media • Permit the acceptable fluctuations of parameters, even set the „worst conditions” 16 „Worst conditions” • say, an equipment must be operated within the limits of – temperature: 20 and 35 oC – pressure: 0.9 and 1.2 atm • The worst cases, when it operates at – – – – 20 oC and 0.9 atm 35 oC and 1.2 atm 20 oC 0.9 and 1.2 atm 35 oC and 0.9 atm 17 Performance Qualification PQ • Similar to the Operational Qualification, but the real manufacture is running • Permit accepted fluctuations up to their limits (incl. worse conditions, if occur) 18 Qualification 19 Validation Priorities for Process Validation Type of process • New • Existing Sterile products Non-sterile Requirement • Every new process before approval for routine • All processes affecting the sterility, and manufacturing environment including sterilization stage • Low dose tablets and capsules: mixing and granulation, content uniformity (possible other parameters) • Other tablets and capsules: uniformity of mass(possible other parameters) 20 Validation Types of Documentation • • • • Validation Master Plan (VMP) Validation protocols (VP) Validation reports (VR) Standard Operating Procedures (SOPs) 21 Validation The Validation Master Plan could consist of: – – – – – – – – – – – Approval page and table of contents Introduction and objectives Facility and process description Personnel, planning and scheduling Responsibilities of committee members Process control aspects Equipment, apparatus, processes and systems to be validated Acceptance criteria Documentation e.g.validation protocols and reports SOPs Training requirements 22 Validation Protocol – Objectives of the validation and qualification study – Site of the study – Responsible personnel – Description of the equipment – SOPs – Standards – Criteria for the relevant products and processes 23 Validation Report – Title – Objective of the study – Refer to the protocol – Details of material – Equipment – Programmes and cycles use – Details of procedure and test methods 24 Let us spend some time on the Validation Master Plan now 25 Validation The Validation Master Plan (VMP) • Philosophy • Content • Strategy 26 Validation Validation Master Plan • • • • Recommendation only Cover manufacturer’s validation policy and needs Provides information on validation organization It should describe: by whom? – why? how? – what? – where? when? 27 Validation Validation Master Plan • Prospective validation • Concurrent validation • Retrospective validation • Revalidation • Change control 28 Validation The VMP • Identifies validation items (products, processes, systems) • Defines nature and extent of testing expected • Outlines test procedures and protocols • Summary document • Management agreement 29 Validation The VMP helps: • Management • Validation team members • Project leaders • GMP inspectors 30 Validation Validation Activities in VMP • Every validation activity included • Revalidation • Validation of new process cycles • Large validation projects have separate VMPs • Include reasonable unexpected events 31 Validation The VMP: • Enables overview of entire validation project • Lists items to be validated with the planning schedule as its heart • Is like a map 32 Validation The “Introduction” to the VMP • • • • • Validation policy Project scope Location and timing (including priorities) Validation procedures Standards 33 Validation VMP should state who is responsible for: • Preparing the VMP • The protocols and SOPs • Validation work • Report and document preparation and control • • Approval/authorisation of validation protocols and reports in all stages of validation process Tracking system • Training needs in support of validation 34 Validation VMP should contain: • Cross references to documents • Specific process considerations • Specific characteristics briefly outlined • Validation list (What to validate) – premises, systems and equipment – processes – products 35 Validation VMP should contain, 2: • Descriptions of – plant (where to validate) – processes – products • Personnel attributes – expertise and training • Key acceptance criteria 36 Validation VMP should contain, 3: • Format for protocols and other documentation • List of relevant SOPs (How) • Planning and scheduling (When) • Location (Where) • Estimate of staffing requirements (Who) • A time plan of the project (When) • Annexes 37 Validation VMP should contain change control • Policy and procedure • Risk assessment • Authorization • Failure to properly document changes to the system means invalidation of the process 38 Validation Changes that require revalidation • • • • • • • Software changes; Controllers Site changes; Operational changes Change of source of material Change in the process Significant equipment change Production area changes Support system changes 39 Validation In summary, a VMP should contain at least: • • • • • • • Validation policy Organizational structure Summary of facilities, systems, equipment, processes to be validated Documentation format for protocols and reports Planning and scheduling Change control Training requirements 40 Finishing Validation Master Plan, something about the Validation Protocol and Report 41 Validation WHO Model for Validation Protocol and Report, 1 • Part 1 – Purpose and prerequisites • Part 2 – Presentation of the process • Part 3 – Validation protocol 42 Validation WHO Model for Validation Protocol and Report, 2 • Part 4 – Installation qualification • Part 5 – Qualification protocol/report • Part 6 – Product characteristics 43 Validation WHO Model for Validation Protocol and Report, 3 • Part 7 – Evaluation • Part 8 – Certification • Part 9 – Summary 44 Special validation types Validation of •cleaning •manuf. process •QC related processes 45 Cleaning validation 46 Cleaning validation Objectives To review: • General requirements • Validation protocol requirements • How to check limits • Analytical requirements • Sampling methods 47 Cleaning validation Why cleaning validation is so important (1) • Pharmaceuticals can be contaminated by potentially dangerous substances • Essential to establish adequate cleaning procedures 48 Cleaning validation Why cleaning validation is so important (2) • “Particular attention should be accorded to the validation of … cleaning procedures” (WHO) • “Cleaning validation should be performed in order to confirm the effectiveness of a cleaning procedure” (PIC/S) • “The data should support a conclusion that residues have been reduced to an ‘acceptable’ level” (FDA) 49 Cleaning validation Possible contaminants • • • • • • Product residues Cleaning agent residues and breakdown Airborne matter Lubricants, ancillary material Decomposition residues Bacteria, mould and pyrogens 50 Cleaning validation Strategy on cleaning validation • Product contact surfaces • After product changeover • Between batches in campaigns • Bracketing products for cleaning validation • Periodic re-evaluation and revalidation 51 Cleaning validation Cleaning validation protocol (1) Should include : • Objective of the validation • Responsibility for performing and approving validation study • Description of equipment to be used 52 Cleaning validation Cleaning validation protocol (2) Should include: • Interval between end of production and cleaning, and commencement of cleaning procedure • Cleaning procedures to be used • Any routine monitoring equipment used • Number of cleaning cycles performed consecutively • Sampling procedures used and rationale • Sampling locations (clearly defined) 53 Cleaning validation Record of cleaning validation Should include : • Data on recovery studies • Analytical methods including Limit of Detection and Limit of Quantitation • Acceptance criteria and rationale • When revalidation will be required • Must have management and QA involvement • Management commitment and QA involvement 54 Cleaning validation Results and reports • Cleaning record signed by operator, checked by production and reviewed by QA • Final Validation Reports, including conclusions 55 Cleaning validation Personnel • Manual cleaning methods are difficult to validate • Cannot validate people; can measure proficiency • Must have good training • Must have effective supervision 56 Cleaning validation Microbiological aspects • Include in validation strategy • Analyse risks of contamination • Consider equipment storage time • Equipment should be stored dry • Sterilization and pyrogen contamination 57 Cleaning validation How to take samples • Swab/swatch • Rinse fluid • Placebo • The sample transport and storage conditions should be defined 58 Cleaning validation Swab samples • • • • • Direct sampling method Reproducibility Extraction efficiency Document swab locations Disadvantages – inability to access some areas – assumes uniformity of contamination surface – must extrapolate sample area to whole surface 59 Cleaning validation Rinse samples • Indirect method • Combine with swabs • Useful for cleaning agent residues • pH, conductivity • Insufficient evidence of cleaning • Sample very large surface areas 60 Cleaning validation Analytical method (1) • Validate analytical method • Must be sensitive assay procedure: – HPLC, GC, HPTLC – pH – conductivity – UV – ELISA 61 Cleaning validation Analytical method (2) Check: • Precision, linearity, selectivity • Limit of Detection (LOD) • Limit of Quantitation (LOQ) • Recovery, by spiking • Consistency of recovery 62 Cleaning validation Setting limits (1) • Regulatory authorities do not set limits for specific products • Logically based • Limits must be practical, achievable and verifiable • Allergenic and potent substances • Limit setting approach needed 63 Cleaning validation Setting limits (2) • Uniform distribution of contaminants not guaranteed • Decomposition products to be checked • Setting limits; cleaning criteria: – visually clean – 10 ppm in another product – 0.1% of therapeutic dose 64 Cleaning validation Setting limits: “Visually clean” • Always first criteria • Can be very sensitive but needs verification • Use between same product batches of same formulation • Illuminate surface • Spiking studies 65 Cleaning validation Setting limits: “10 ppm” • • • • Historical In some poisons regulations Pharmacopoeias limit test Assumes residue to be harmful as heavy metal • Useful for materials for which no available toxicological data • Not for pharmacologically potent material 66 Cleaning validation Setting limits: not more than 0.1% • Proportion of MINIMUM daily dose of current product carried over into MAXIMUM daily dose of subsequent product • Need to identify worst case 67 Cleaning validation Other issues • Clean-In-Place (CIP) systems • Placebo studies • Detergent residues; composition should be known • Scrubbing by hand 68 Cleaning validation Questions for the GMP Inspector to ask • How is equipment cleaned? • Are different cleaning processes required? • How many times is a cleaning process repeated before acceptable results are obtained? • What is most appropriate solvent or detergent? • At what point does system become clean? • What does visually clean mean? 69 Cleaning validation Conclusion • The manufacturer needs a cleaning validation strategy • Assess each situation on its merits • Scientific rationale must be developed – equipment selection – contamination distribution – significance of the contaminant • “Visually clean” may be all that is required 70 Process validation 71 Process validation Objectives To review: • Validation, risk analysis, and critical steps of processing • Points to consider in process validation of: – solid dose mixing – tablet compression – sterilization • Finalization of validation 72 Process validation Reliable, repeatable, under control • At least first 3 consecutive batches repeatable • Must investigate failures • The rationale should be documented if experimental method is changed – document deviations, decisions and reasoning • Does not improve processes • Should not validate bad processes 73 Process validation DQ, IQ, OQ and PQ Design user or process requirements Install installation qualification Operate operational qualification Perform performance qualification and process validation Review periodically (+ change control) 74 Process validation Critical factors or parameters • Need to be determined • Need to be monitored during validation • May affect the quality of the product 75 Process validation Setting Limits • Marketing authorization limits – stability specifications • Release specification • Validation limits Marketing authorisation limits based on stability specifications Batch release limits Validation limits 76 Process validation Determining critical control point: example of a tablet granulation process • Particle size distribution of the active(s) • Blending time for the powder • Granulating time and speed, • Amount of granulating fluid-binder concentration • Drying time - final moisture content, granule particle size distribution • Granule active content and homogeneity, blending time of external phase 77 Process validation Determining critical control points 78 Process validation • • • • • • Solid dose mixing (1) Homogeneity in blending – the key to quality! Sampling strategy Sample site, label, container Storage Transport Sample thief 79 Process validation Solid dose mixing (2) • In situ analysis • Methods of analysis • Statistical analysis – inter-batch – intra-batch – within-sample-site 80 Process validation • • • • • • Tablet compression variables Fill volume Pre-compression force, compression force Turntable speed Dwell time Granule size and feed Ejection force, lubrication 81 Process validation Tablet compression parameters Tablet coating variables Mass Spray rate Hardness Inlet and outlet air temp Moisture Coating weight Friability Disintegration Dissolution Thickness 82 Process validation Sterilization validation (1) • Sterility test • Physical measurements • Chemical and biological indicators • Loading patterns 83 Process validation • • • • • • Sterilization validation (2) Cooling fluid or gas Automated process Leak tests Control instrumentation Steam quality Heat distribution 84 Process validation Dry heat sterilization • Parameters • Air circulation, positive air pressure, HEPA filter • Advantages – microorganisms destroyed – depyrogenation possible • Disadvantages – poor heat transfer – higher temperatures for long periods 85 Process validation Process variation Controllable causes of variation may include: • Temperature, humidity • Variations in electrical supply • Vibration • Environmental contaminants • Light • Human factors • Variability of materials • Wear and tear of equipment 86 Process validation Change control • Must be a review procedure for validated processes • From time to time changes may be necessary • Documented change control procedure needed • “Like for like" changes do not require re-validation 87 Process validation Mixing validation liquid and solid dose change control and scale up • Mixer type and size • Batch size • Pilot study scale up • Limit on the proportion of the scale up 88 Process validation Finalization of validation process • Final report required • Summarize and reference protocols and results • Conclusion required: “Is the process valid” • Final report should be reviewed and approved by – the validation team – “authorized person” 89 Tablet manufacturing flow chart 90 Quality Control related validation 91 QC related validation Introduction • Why is analytical monitoring necessary? • What is the purpose of analytical validation? 92 QC related validation Objectives To introduce the concepts of : • Protocol development • Instrument qualification • Analytical procedure • Extent of validation • Method transfer • Chemical and physical, biological, and microbiological test validation 93 QC related validation Validation of analytical procedures requires: • Qualified and calibrated instruments • Documented methods • Reliable reference standards • Qualified analysts • Sample integrity 94 QC related validation Validation protocol for analytical method • • • • • Statement of purpose and scope Responsibilities Documented test method List of materials and equipment Procedure for the experiments for each parameter • Statistical analysis • Acceptance criteria for each performance parameter 95 QC related validation Qualification of the instrument • Make, model and maker’s manual • Modifications • Installation and operational qualification • Calibration programs • Maintenance schedules 96 QC related validation Characteristics of analytical procedures (1) • Accuracy • Precision • Repeatability • Reproducibility 97 QC related validation Relationship between accuracy and precision In a c c u ra te & im p re c is e In a c c u ra te b u t p re c is e A c c u ra te b u t im p re c is e Accurate AND Precise 98 QC related validation Characteristics of analytical procedures (2) • • • Ruggedness Robustness Variability caused by: – – – – – – – Day-to-day variations Analyst-to-analyst Laboratory-to-laboratory Instrument-to-instrument Chromatographic column-to-column Reagent kit-to-kit Instability of analytical reagents 99 QC related validation Characteristics of analytical procedures (3) • • • • • Linearity and range Specificity Sensitivity Limit of detection Limit of quantitation 100 0.040 0.035 0.030 0.025 0.020 0.015 0.010 0.01 Calculated analyte in mg/mL QC related validation Table of values (x,y) Linearity of an analyte in a material 0.015 Reference material mg/ml 0.02 0.025 0.03 0.035 0.04 x y # Reference material mg/ml Calculated mg/ml 1 0.0100 0.0101 2 0.0150 0.0145 3 0.0200 0.0210 4 0.0250 0.0260 5 0.0300 0.0294 6 0.0400 0.0410 101 QC related validation Linearity Statistics • • Intercept -0.0002 Limit of Linearity and Range 0.005 – 0.040 mg/mL • • Slope 1.0237 Correlation coefficient – – Pearson Olkin and Pratt 0.9978 0.9985 • Relative procedure standard deviation 3.4% 102 QC related validation LOQ, LOD and SNR • Limit of Quantitation • Limit of Detection • Signal to Noise Ratio Peak B LOQ Peak A LOD Baseline noise 103 QC related validation Different classes of analytical tests • Class A: To establish identity • Class B: To detect and quantitate impurities • Class C: To determine quantitatively the concentration • Class D: To assess the characteristics 104 QC related validation Characteristic A B quant. B Limit test C D Accuracy X X X* Precision X X X X X X X X X Robustness X Linearity and range Specificity X X X X Limit of detection Limit of quantitation X X X X * A degree of bias may be allowed 105 QC related validation Extent of validation • • • New methods require complete validation Pharmacopoeial methods require partial validation (or verification) Significant changes mean partial revalidation – equipment changes – formula changed – changed suppliers of critical reagents 106 QC related validation Analytical method transfer • Method transfer protocol and procedure – precision – accuracy – ruggedness • Written and approved specific test method • Proficiency check • Formal acceptance by new laboratory 107 QC related validation Chemical laboratory validation requirements (1) • • Balances Chromatography – • • • • HPLC, HPTLC, GC, TLC Dissolution or disintegration apparatus Karl Fischer moisture determination Melting, softening or freezing point apparatus Ovens, refrigerators, incubators 108 QC related validation Chemical laboratory validation requirements (2) • pH meter • Polarimeter - optical rotation • Refractometer • Spectrophotometer UV/Vis, IR, FTIR, Raman, AA • Timers • Viscometer • Volumetric equipment 109 QC related validation Typical validation of HPCL assay (1) • System suitability (performance check) – – – – system precision column efficiency symmetry factor capacity factor 110 QC related validation Typical validation of HPLC assay (2) • Method validation – – – – – specificity accuracy precision linearity robustness 111 QC related validation Biological assays • Can be difficult to "validate" • "Validity" on a case by case basis • Strictly adhere to the Biological Testing monographs in pharmacopoeias 112 QC related validation Microbiological testing requiring validation • Microbial limit testing • Microbial count • Sterility testing • Preservative effectiveness testing • Environmental monitoring program • Biological testing 113 QC related validation Validation of microbial test procedures (1) • Virtually impossible to completely validate test procedures for every microorganism • Neutralize /inactivate inhibitory substances, or dilute • Periodic media challenge • Media QC • Reliable methods 114 QC related validation Validation of microbial test procedures (2) • Incubation temperature and time • Media may not grow all microorganisms • Variations in media may affect recovery • Inhibitory disinfectants or preservatives • Sample – procedures – handling, storage, transport 115 QC related validation Microbiological viable count method validation (1) • Methods – pour plate / spread plate – membrane filtration – Most Probable Number • • • Sample size Test dilution Inoculation size 116 QC related validation Microbiological viable count method validation (2) • Membrane filtration conditions • Incubation conditions • Acceptance criteria 117 QC related validation Sterility testing validation requirements • Media growth promotion, sterility, pH • Product validation • Stasis testing • Environmental monitoring • Negative controls • Challenge organisms 118 Validation Personnel - Validation team members • • • • Quality Assurance Engineering Manufacturing Other disciplines may be involved depending on the product and process: – – – – – laboratory, technical services research and development, regulatory affairs clinical chemical engineering purchasing/planning 119 Validation Protocol development (1) • Identification of process • Objective and measurable criteria • Length and duration of the validation • Shifts, equipment • Identification and quality of utilities • Identification of operators and operator training and qualification 120 Validation Protocol development (2) • Complete description of the process • Relevant specifications and tests • Samples and sampling methods • Special controls or conditions • Process parameters to be monitored • Methods for controlling and monitoring 121 Validation Protocol development (3) • Objective and subjective criteria used to evaluate the product • Definition of non-conformance • Statistical methods • Maintenance and repairs • Criteria for revalidation • Criteria for change control 122 Validation GMP Inspector’s check list for validation (1) Check that the manufacturer has: • A VMP and multi-functional team for validation • Planned approach, defined requirements • Identified and described processes • Analyse the amount of validation work to perform 123 Validation GMP Inspector’s check list for validation (2) Check that the manufacturer has: • Selected methods and tools for validation • Created protocols • Performed DQ, IQ, OQ, PQ and documented results • Exerted change control, set revalidation time 124 Validation: summary Validation • A quality tool that makes sense • A prevention-based activity • Expensive • In danger of becoming overwhelming • Risk-based assessment of what needs to be validated or verified • The process must be under control 125 We are now validated! 126 Exam topics 127 Validation and Qualification in GMP • • • • • Definitions. What is their difference? Their importance Describe the 3 process validation types Describe the 4 qualification types Validation documentation (special emphasis to VMP) • What is change control, why to do it? 128 Validation of clening processes and analytical procedures in GMP • Cleaning validation – Its 2 targets – How to perform it (examples) • Analytical method validation – List the main method characteristics – Classes of testing for validation – Analytical instrument validation (examples) – Microbiology 129