Tag Archives: Validation

Basic Components of a Test Form

Hello good people of the world! Today’s post is a short one on what are the basic components of a test form. In Validation, you’re going to record a lot of data, and you want this data to be well organized and easily understood. Here are the basic components I think every test form should have:

  1. Numbering! Each step should have a unique number so that it is easily identifiable and easy to reference elsewhere.
  2. A Title! What is this test all about? A short description should be provide.
  3. Purpose! What is the purpose of the test? Make it clear.
  4. Verification Steps! Clearly define what steps need to be performed.
  5. Expected Results! Clearly define what the expected results are. Does every step need an expected result? Every step can have one, so include it.
  6. Actual Results! This is where the actual data is collected. The actual results can be recorded exactly as the expected results are stated to avoid any confusion.
  7. Pass/Fail! Did the step pass or fail? This will quickly tell you. Also a good place to reference any comments.
  8. Initials/Date! In order for the data to be attributable, initial/date uniquely identifying the test executer must be included for each step.

What basic components do you include on your test forms? Comment below.

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What NOT to Re-qualify

autoclave
Hello good people of the world! Today’s post is on what NOT to include in requalification/revalidation. I was recently on a site that had a five (5) year requalification requirement for sterilizers per a site SOP, which sounds reasonable (continuous monitoring would be better). But then I noted they included in their requalification requirements a re-execution of the entire initial controls system IOQ! The requalification included verification of:

  • Hardware/software installation
  • E-stop, guarding, and door interlocks
  • Restart and recovery
  • Recipe management
  • Temperature, pressure, and time control
  • Communication
  • Security

And it was expected that this would be done every five years! It just so happened that in 2014 they paid a contractor to do the work, who sadly did not help the site out by letting them know the wastefulness of such an endeavor. This is an egregious example of resource misuse and not understanding the expectations of a validation program/taking a risk-based approach. The point of requalification/revalidation is to look for drift in processes, not blindly repeat testing already performed.

What misunderstanding-of-validation-expectation horror stories do you have? Comment below.

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WHO’s Draft Guidelines on Validation May 2016

Hello good people of the world! On May 15, 2016, the World Health Organization released its draft Guidelines on Validation. It is available on the WHO website for download here.

This post covers my review of the guidance. Continue reading WHO’s Draft Guidelines on Validation May 2016

Considerations in SaaS Validation

SaaS Qualification

Hello good people of the world! Today’s post is about qualifying Software as a Service (SaaS), also known as “cloud-based” or “hosted” software. Simply, SaaS is any computer system in which any server is not hosted by the system owner. Here are some key considerations in qualifying SaaS computer systems:

Continue reading Considerations in SaaS Validation

False Positives in Statistical Process Control

false positive

Hello good people of the world! This post is about Statistical Process Control (SPC), and what false positives, or type I errors, mean for SPC results.

A false positive or type I error may be simply described as an error where a correlation is believed to be seen, although it does not actually exist. In statistics, this is called falsely rejecting the null hypothesis. Details can be found, for instance, on Wikipedia.

Continue reading False Positives in Statistical Process Control

Container Closure Integrity Testing

Hello good people of the world! The present post concerns itself with Container Closure Integrity (CCI) testing. CCI testing is an integral part of packaging validation, involving primary packaging such as ampoules, blisters, bottles, vials, syringes, tubes, etc. Biopharmaceuticals are typically packaged in hermetically-sealed containers to prevent the ingress of any liquid or gas that could be reactive or carry microorganisms. Packaging may also by light-resistant, if light could affect the properties of the product.

There are three regulatory/industry guidelines typically cited in the U.S. regarding CCI testing:

  1. FDA Guidance for Industry (2008), Container and Closure System Integrity Testing in Lieu of Sterility Testing as a Component of the Stability Protocol for Sterile Products
  2. PDA Technical Report No. 27 (1998), Pharmaceutical Package Integrity (not available for free)
  3. USP <1207>, Sterile Product Packaging – Integrity Evaluation

CCI testing is either physical (bubble, liquid tracer, vacuum/pressure decay, dye ingress, etc.) or microbial (microbial ingress).

Each has it’s advantages and disadvantages, as shown in the below from American Pharmaceutical Review:

When should these tests be performed? CCI testing is applicable to new container closure systems and can be performed on newly sealed containers to validate sealing performance, and then annually and at the expiration date to validate stability.

What are your preferred methods of Container Closure Integrity Testing?

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Cleanroom Isolators

RABS

Hello good people of the world! Today’s post is about cleanroom isolator technology, specifically Restricted Access Barrier Systems (RABS). RABS are typically employed at the high-risk manufacturing step of fill/finish, were finished product may be exposed to the surrounding environment (i.e. the process is “open”). In the case of parenteral (injectable) pharmaceuticals or biologics, where post-fill sterilization is not possible, environmental control at the fill step is of paramount criticality.

Heating, Ventilation, and Air Conditioning (HVAC) general concepts: HVAC is an important system in maintaining cleanroom cleanliness, but is typically categorized as an “indirect-impact” “commission-only” system, separated from the cleanroom itself via High Efficiency Air Particulate (HEPA) filters and controlled via feedback from local cleanroom differential pressure (DP), temperature, and, if required, humidity sensors.  The main components of the HVAC system include the Air Handling Unit, which may be comprised of a mixing chamber (for return and outside air), filters, heaters, coolers, and humidifiers.

Cleanroom general concepts: the cleanroom is typically classified according to ISO 14644-1, GMP EU grades, and/or US Federal Standard 209E classes, among others. A good summary is here. These classifications define the allowable number of total airborne particles and viable airborne particles. Total and viable particulates can be reduced by increasing the air exchange rate, which is the number of times (typically per hour) that the total room air volume moves through the AHU. For class B (ISO 7 in operation), 30-60 air changes are used. For class C (ISO 8 in operation), 20 air changes may be used.  Class A space (ISO 5) could require Unidirectional Air Flow (UDAF), which should be differentiated from Laminar Flow (LF), with an air velocity of 0.45 m/s ± 20%.

In cleanrooms, by far the grossest contributor to airborne particulate counts are the operators. Moving even slightly, an operator might produce more than 2.5 million particles of size 0.3 μm or greater per minute! (source). For this reason alone, barrier technology is critical in Class A cleanroom space. This is typically achieved via an active or passive Restricted Access Barrier System (RABS) or via an Isolator.

A RABS is an area that has a rigid enclosure with safety-interlocked doors, and glove ports for manual interventions. Passive RABS has no aeration equipment. Active RABS has it’s own aeration and filtration equipment.

Isolators are similar to RABS, except that they are hermetically (airtight) sealed to completely separate operators from the process area.

Both the RABS and Isolator create an UDAF over the Class A space.

Which do you use? Which do you prefer? What application would required an Isolator over a RABS?

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