Tag Archives: Validation

ORAL SOLID DOSE – Equipment Cleaning

Hello good people of the world! Continuing the series on oral solid dosage forms, today we’re going to talk about equipment cleaning. OSD manufacturing equipment can be notoriously hard to clean, and manual cleaning procedures introduce high risk of contamination and carryover. It is recommended that any new or existing process equipment be cleaned with automated processes wherever possible.

The three automated cleaning processes typically used in industry are:

  • Clean-in-Place (CIP)
  • Wash-in-Place (WIP)
  • Clean-out-of-Place (COP)

CIP is done without moving the equipment, as the name implies, and uses a CIP skid to deliver cleaning and rinse solutions. CIP should not require any manual operations.

WIP is done in-place as well, but may include some manual operations, such as removing filters.

COP requires equipment to be moved to a wash station. Tanks and vessels are typically COP’d.

Some specific concerns related to cleaning OSD equipment include:

  • Dry Granulator/Roller Compactor cannot typically be CIP’d. Particularly the auger must be removed and COP’d.
  • Fluid Bed Dryers a large and complex, making cleaning difficult. Modern dryers will include CIP/WIP but typically still require manual cleaning of some parts.
  • Milling equipment typically requires the screen to be manually removed before any CIP/WIP.
  • Tablet presses can be difficult to clean, requiring many manual interventions prior to washing.
  • Capsule filling machines should be wettable to allow cleaning.
  • Tablet coaters should include WIP

Of course, cleaning processes, whether automated or not, need to be validated. Riboflavin tests may be performed to verify wash coverage, and swabbing can verify lack of residual API and cleaning solutions.

What challenges have you run into in cleaning your OSD manufacturing equipment? Comment below!

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Oral Solid Dose – Equipment

Hello good people of the world! Today’s post is the third in the series covering the commissioning, qualification, and validation of facilities, systems, and equipment involved in the manufacture of oral solid dose (OSD) products. This post covers the equipment used to manufacture these products.

Considerations include: materials of construction, sampling, and cleanability.

  1. Materials of Construction: it is critical that equipment materials do not react with or otherwise adulterate the product being manufactured. Materials of construction may be metals (e.g. 316L stainless steel), plastics, or elastomers. Other considerations include design documentation, surface finish including at welds, and any certification required.
  2. Sampling: equipment must be designed so that sampling is facilitated where required. Sampling is typically a mitigation for product quality failure modes such as content uniformity in granulation, over/under drying in drying, failed particle size distribution in milling, leakage in encapsulation, and over spray in coating, among others.
  3. Cleanability: automated clean-in-place (CIP) cleaning procedures are preferred where practical. Manual cleaning and sterilization may also be considerations.

What do you think about in terms of your OSD manufacturing equipment?

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Oral Solid Dose – Quality Risk Management Considerations

Hello good people of the world! Today’s post is the second in the series covering the commissioning, qualification, and validation of facilities, systems, and equipment involved in the manufacture of oral solid dose (OSD) products. This post covers quality risk management.

Quality Risk Management is performed per the principles outlined in ICH Q9. The management process may then be divided up into six (6) steps:

  1. Determine risk areas. These are typically safety, product quality, schedule, cost, etc.
  2. Identify the risks for each area defined in step 1. For example, microbiological contamination may be a risk to product quality, APIs may be a risk to personnel safety.
  3. Identify the failure modes which contribute to the risks identified in step 2. For example, pests contribute to microbiological contamination risk, and HVAC failure could be a vector by which personnel are exposed to an API.
  4. Analyze failure modes and identify mitigations. In our examples procedures around pest control and qualification of HVAC systems could be mitigation to the failure modes identified.
  5. Implement monitoring and CAPA (corrective and preventative action) processes.
  6. Apply a continuous improvement plan to periodically review risks, risk assessments, and mitigation.

There are many tools which may be used to document the process, such as: FMEA, HAZOP, PHA, etc.

How do you execute your quality risk management process?

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Oral Solid Dose – Critical Properties

Hello good people of the world! Today’s post is the first in a series covering considerations around the commissioning, qualification, and validation of facilities, systems, and equipment involved in the manufacture of oral solid dose (OSD) products. OSD is a wide-spread method of pharmaceutical delivery, including well known medicines such as aspirin, Viagra, and many antibiotics. Solid doses can take the form of powders, tablets, capsules, pills, lozenges, granules and more.

Here we’re going to cover the physical and chemical properties that should be considered in equipment design.

First, environmental factors:

  1. Temperature and Humidity: temperature and humidity should be controlled even if the product is not sensitive, as most processes are susceptible to flow issues in the extreme temperature and/or humidity ranges.
  2. Light: some OSD products are light (especially UV light) sensitive and must be protected from sunlight and even indoor light in some cases.
  3. Oxygen: some products may also be sensitive to oxygen exposure.

Second, process factors:

  1. Particle size and size distribution: powders inevitably have some variation in particle size that must be understood and controlled
  2. Particle shape: similarly to size, particles will have variation in shape
  3. Surface properties: are the particles smooth or rough? Do they stick together? Do they readily absorb moisture? Surface properties must be understood
  4. Particle strength: particles will break down under enough force. Particle strength must be understood and undue stress avoided in manufacturing processes.
  5. Density, porosity, and packing: how does a particle pack? Things like minimum bulk density, poured bulk density, and tapped bulk density should be understood.
  6. Cohesion in powders: related to surface properties, how to particles stick together? Magnetic, electrostatic, and intermolecular forces may be in play and should be understood.

What factors do you consider in your OSD manufacturing process?

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Validation Program Tenets

Hello good people of the world! What are the overarching tenets that you go to when making decisions related to your validation program? The regulations and guidance from industry only go so far and you will be regularly tasked with situations unique to your program. How do you know what is the right way to go in the grey areas? I like to keep these tenets in mind:

  1. The manufacturing process should be the most complex process on the site. Reduce complexity everywhere else. Reduce the number of deliverables. Reduce the number of process steps.
  2. Requirements feed specifications feed test protocols. Remember that you should always be able to trace a test case to a requirement through the specifications.
  3. Compliance is not binary, you are accepting degrees of regulatory risk. Make sure you understand the risk and that you accept it.
  4. Good Manufacturing Practices are not just from the CFRs. World-wide best practices need to be considered and applied where applicable.
  5. It’s all about documentation. If it’s not documented it didn’t happen. Create a logical narrative, and you’re already mostly there.
  6. Our primary purpose is to create documentation for agencies. Take any kind of writing class, and one of the first things you’ll learn is: know who your audience is and write for them. While it’s great the validation documentation can be used for commissioning, process improvement, etc. that must not come at the cost of it’s primary purpose.

What are some of your go-to tenets?  Comment below.

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PLC/HMI IOQ – What to Test?

PLC

Hello good people of the world! Today’s post is on initial control system Installation and Operational Qualification (IOQ) of a simple system consisting of an Human/Machine Interface (HMI), Programmable Logic Controller (PLC), and any number of end devices (valves, pumps, sensors, etc.). The question is what should be tested?

Obviously there’s a ton of guidance out there (see e.g.: GAMP) that will have a lot more detail than this post. The purpose here is to list at a high level the tests that could be expected. So let’s get started!

Installation Qualification
IQ can be its own protocol or combined with OQ in an IOQ for cases without a ton of complexity. IQ is supposed to verify the installation of hardware, software, and any peripherals. You also want to check what documentation is available/applicable here. IQ tests may include:

  • Documentation Verification (e.g. SOPs, EREC/ESIG assessment, operating/maintenance manuals, panel and electrical drawings, etc.)
  • Hardware Verification: verify the make and model of major components at a minimum
  • Software Verification: verify/record software versions. You’ve got to know what you’ll be OQ’ing!
  • Configuration Verification: verify any hardware and/or software configuration. This could be two tests, one for hardware, one for software.
  • Loop Check Verification: verify loop checks are performed.
  • Alarm Configuration Verification: ideally alarms a setup in such a way that you don’t have to functionality test them all!
  • Any other critical installation items

Operational Qualification
OQ is the meat of your control qualification. Here you want to test critical functions, that hopefully you have identified earlier (see here for one approach). OQ may test:

  • Interlock Verification including e-stops. A lot of interlocks are safety/business related, but they’re often included in OQ due to how critical they are.
  • Functional Alarm Verification – be sure to include data loss/communication alarms
  • HMI Navigation and Layout Verification
  • Restart/Recovery Verification
  • Sequence of Operations Verification

What kinds of testing are you sure to cover in your control system IOQ protocols? Comment below.

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Validation Project Plans

develop-project-plan-1200x480

Hello good people of the world! Today’s post is about Validation Project Plans, which is a specific type of project plan for projects in the pharmaceutical, biotechnology, and medical device regulated industries. This post covers Validation Project Plans for pharmaceutical/biotechnology industries in particular.

Often I’ve see Validation Project Plans contain a lot of fluff but little meat, making them of less value to the project team. A good project plan clearly documents the following, at a minimum:

  1. What facilities, systems, and equipment are in scope of the plan
  2. What are the expected activities and deliverables
  3. Who is responsible for what
  4. What is the validation approach and rationale for that approach
  5. What happens after the validation scope covered in the plan is completed (i.e. ongoing requirements)

Note I do not include project cost or schedule in a project plan, because these are often changing rapidly and should be maintained in a less controlled, more flexible manner, e.g. with scheduling software for a schedule.

The plan itself should be controlled (i.e. approved and revision controlled) as soon as possible in the project but early enough so that scope will not change (too much).

Additional things to think about when drafting your plan:

  1.  Commissioning versus Qualification versus Validation. If your project has multiple phases (and any decent-sized project should), be sure to clearly state responsibilities and deliverables at each stage.
  2. Include references to regulations, industry guidance, and site procedures that govern your plan. Make it clear to everyone who reads the plan what framework you are working inside.
  3. The purpose and scope of the document should be clear and up front.
  4. Get buy-in from all functional groups by having them approve the document.
  5. Like all controlled documents, the plan should have version/revision history.
  6. Use tables to clearly present information.

I put together a quick template here:

Validation Project Plan Template MWV

What do you feel is necessary in a Validation Project Plan? Comment below.

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