Category Archives: Commissioning

ORAL SOLID DOSE – Supporting Equipment and Systems

Hello good people of the world! Continuing the series on oral solid dosage forms, today we’re going to talk about supporting equipment and systems. The main equipment in unit operations get the spotlight when it comes to manufacturing Oral Solid Dosage forms, but they cannot work without supporting equipment and systems.

Supporting Equipment:
Typical supporting equipment in a OSD manufacturing process includes:

  1. Air Systems: all modern manufacturing processes use air systems for process, instruments, and environment. HVAC helps control environmental conditions, including particulate (viable and nonviable) counts, temperature, and humidity. Compressed air systems may be used in the process to cool or cover product, such as with nitrogen, or operate unit operation steps, such as in fluid bed drying. Automated systems will use compressed air to pneumatically control valves and other components.
  2. Dust Collection: compared to biotech and other pharmacuetical processes, OSD processes have the added complication of dust collection. OSD material movement and processes can create a lot of dust, which can be a risk from a product quality point-of-view, but also a safety point-of-view, since dust can lead to fires and even explosions. Dust collection equipment must be employed to minimize and control dust.
  3. Vacuum Systems: vacuum systems may be used for cleaning, dust collection, and also in process steps such as vacuum drying.

Supporting Systems:
Typical supporting systems include:

  1. Change Control: it is expected that engineering changes are controlled with quality oversight through a formal process.
  2. Preventive Maintenance: it is expected that regular preventive maintenance be performed and documented formally.
  3. Calibration: it is expected that “critical” instruments are calibrated at regular intervals traceable to an international standard. Calibration procedures and results must be formally documented. The method to determine and results of the determination of critical instruments must be documented.

What supporting equipment and/or systems do you use in your OSD manufacturing process? Comment below!

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ORAL SOLID DOSE – Unit Operations

Granulator at an OSD Plant in Vietnam

Hello good people of the world! Continuing the series on oral solid dosage forms, today we’re going to talk about unit operations typical in a oral solid dose manufacturing process.

Typical OSD processes may include some combination of weighing/dispensing, material transfer, blending, granulation, drying, milling/sieving, compression, encapsulation, and coating. Some considerations around each step may include:

  1. Weighing/Dispensing: includes sampling for quality purposes. Materials to be sampled typically include: APIs, excipients, primary and secondary packaging, cleaning agents. Sampling areas must be protected from contamination.
  2. Material Transfer: material flows should be documented and reviewed, with the intention of minimizing any contamination.
  3. Blending: materials are typically blended to ensure a uniform composition, prior to downstream process steps. Many methods exist, including: tumble blending, bin blending, and agitator mixers.
  4. Granulation: granulation is the process of combining particles into a granule. Many methods of granulation exist: wet massing/extrusion, high shear, spray, speronization, and hot melt extrusion, for example.
  5. Drying: the purpose of the drying step is to remove any excess moisture from the drug product. Drying methods include: tray , fluidized bed, and spray drying.
  6. Milling/Sieving: the purpose of this process step is to reduce granule size to conform to specification. Some methods include: impact/hammer mills, conical mills, and oscillating horizontal screens.
  7. Compression: compression is used to create tablets.
  8. Encapsulation: encapsulation is used to create capsules.
  9. Coating: coating is used to apply a coat to tablets

In the next post we’ll cover supporting equipment and quality systems. What process steps do you use in your OSD process? Comment below!

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ISPE’s Commissioning and Qualification Guide Second Edition

Hello good people of the world! Today’s post covers ISPE’s release of the second edition of their commissioning and qualification guide. This is volume 5 of the baseline guides. The first edition was first released way back in March 2001, so we should expect this to be a significant revision. Please note this guide is not available for free.

One very nice thing about this second edition is that it not only updates the first edition of the volume 5 guide, but incorporates scope from two other now-outdated guides as well: “Science and Risk-Based Approach for the Delivery of Facilities, Systems, and Equipment” and “Applied Risk Management for Commissioning and Qualification.” So if you have these in your library, you can safely archive them.

It’s always important to note that industry guides such as this one do not constitute regulations and are not required to be followed. It is often the case however that best practices documented in guides become industry standard, and then set expectations for regulators. Per the guide, it is intended to comply with EU GMP Annex 15FDA Guidance on Process Validation, and ICH Q9.

The table of contents shows the following sections:

  1. Introduction
  2. User Requirements Specification
  3. System Classification
  4. System Risk Assessment
  5. Design Review and Design Qualification
  6. C&Q Planning
  7. C&Q Testing and Documentation
  8. Acceptance and Release
  9. Periodic Review
  10. Vendor Assessment for C&Q Documentation Purposes
  11. Engineering Quality Process
  12. Change Management
  13. Good Documentation Practice for C&Q
  14. Strategies for Implementation of Science and Risk-Based C&Q Process

And the following appendices:

  1. Regulatory Basis
  2. User Requirements Specification Example
  3. System Classification Form Example
  4. Direct Impact System Examples
  5. System Risk Assessment Example
  6. Design Review/Design Qualification Examples
  7. Supporting Plans
  8. System Start-Up Examples
  9. Discrepancy Form Example
  10. Qualification Summary Report Examples
  11. Periodic Review Example
  12. Periodic Review for Controlled Temperature Chambers
  13. Vendor Assessment Tool Example
  14. Organizational Maturity Assessment Example
  15. Approach to Qualifying Legacy Systems or Systems with Inadequate Qualification
  16. References
  17. Glossary

You’ll have to purchase the guide to get all the details, but below are some highlights that stuck out to me:

  • This second edition introduces the term Critical Design Elements (CDEs). CDEs are defined as “design functions or features of an engineered system that are necessary to consistently manufacture products with the desired quality attributes.”
  • Concepts that were removed from this edition of the guide include Component Criticality Assessment, Enhanced Commissioning, Enhanced Design Review, Enhanced Document, Indirect Impact (systems are either direct impact or not direct impact now), and the V-Model.
  • A Direct Impact system is defined as a system that directly impacts product CQAs, or directly impacts the quality of the product delivered by a critical utility system. All other systems are considered to be not direct impact. An example included in section 3 demonstrates the previously categorized “indirect impact” systems would become not direct impact systems and would be commissioned only, although the commissioning for these system may be more robust than a purely “no impact” system. The guide provides an eight (8) question process for determining if a system is direct impact.
  • System boundaries should be marked on design drawings.
  • Inputs to the URS should include: CQAs, CPPs, regulatory, organization quality, business, data integrity and storage, alarm, automation, and health, safety, and environmental requirements, and engineering specifications and industry standards. The example URS template does include a classification of each requirement (e.g. business, safety, quality).
  • A system risk assessment is performed to identify CDEs and controls required to mitigate risks. Standard off-the-shelf systems typically do not require a risk assessment. Risk levels are defined as low, medium, and high and the risk assessment approach is not a typical FMECA process. Instead each CQA at each step gets one entry on how the CQA can be impacted, what are the design controls around that CQA and any alarm or procedural controls to mitigate risk. The residual risk post-controls is includes as low, medium, or high.
  • Design Qualification looks somewhat informal 0=- no DQ protocol, but a DQ report that summarizes other documents (URS, SIA) and design review meetings.
  • A C&Q plan should include clear scope, the execution strategy, documentation expected for each system (URS, FAT, SAT, IOQ, SOPs, etc.), and roles and responsibilities (e.g. approval matrix).
  • The discrepancy form has closure signatures only (no pre-implementation signatures)
  • For legacy systems without adequate C&Q documentation, focus should be on identifying product and process user requirements including Critical Quality Attributes (CQAs) and Critical Process Parameters (CPPs), and then the Critical Design Elements (CDEs) that affect them. It is necessary to confirm that accurate drawings exist, that maintenance files are up-to-date, and there is test evidence to support changes since commissioning. A risk-based approach can be used to qualify the system in the absence of typical C&Q documentation.

Do you use the ISPE guides for your C&Q approach? Comment below.

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Free Offer! Track Punchlist Items in Real-time with Your Mobile Device

portfolio7Hello good people of the world! So every project needs to track open items and that is typically done with a punchlist. You may have seen a punchlist in a Microsoft Excel spreadsheet, with one person as the owner, or even worse, on pen and paper.

A punchlist is a collection of data, and any good data collection is:

  • Secure
  • Accessible
  • Robust

Continue reading Free Offer! Track Punchlist Items in Real-time with Your Mobile Device

Commissioning and Qualification of Process Instrumentation

Pressure Transmitter

Hello good people of the world! Today’s post is on the commissioning and qualification of instruments used in process measurement and control. Instruments may be used to measure such things as flow, temperature, pressure, level, weight, conductivity, etc. In use, many of these parameters may be quality critical, so proper commissioning and qualification is key! Continue reading Commissioning and Qualification of Process Instrumentation

Quality During Construction

Construction Quality Assurance

Hello good people of the world! This blog post covers Construction Quality Assurance, based on an article that appeared in the Nov/Dec 2012 edition of Pharmaceutical Engineering titled “Assured Construction Quality Saves Time and Money.” All credit goes to the authors: Jay Lad of Skanska Pharmaceutical Group and Bruce Beck of Eli Lilly. Continue reading Quality During Construction

Staying in Control: Alerts and Alarms

alarm

Hello good people of the world! If you work with a mix of process equipment and supervisory control or monitoring systems, you know the importance of alerts and alarms, but most companies do not take the necessary steps to ensure their alerts and alarms are well configured and meaningful. One of the enemies is so-called “nuisance-alarms,” but just as important is knowing that you have enough alerting/alarming so that critical events are not missed and appropriate actions are taken before harm is done.

And by the  way, alerts and alarms are something the FDA has historically shown to care about (e.g.  FDA had observation at Teva Irvine for lack of validation on alerts and alarms). So what considerations are at play?

What should alert/alarm? If you’ve clearly defined your Critical Process Parameters (CPPs) and know what your Critical Quality Attributes (CQAs) are, you know already what needs alerts/alarms: all CPPs.

What should the alert/alarm limits be? This part is tricky: you need limits that provide operators with sufficient information without becoming a nuisance. All too often I see the situation where alarm banners are flashing but no one is paying attention because “there’s always alarms” or whatever.

What action should occur based on alert/alarm conditions? This is another place I often see improvements needed: every alert and alarm should have a documented action associated with it, typically in the SOP, that operators are trained on. If there is no documented action required for an alert/alarm, why do you have it?

What do you find critical in configuring alerts/alarms and introducing them into a manufacturing process?

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