Transcript Slide 1
US & EU GMP Guidelines on Analytical Instrument Qualification and Related Warning Letters 1 Confidentialit Overview • • • • • • FDA/EU/USP Requirements and enforcement practices Examples of FDA warning letters The 4Q model for equipment qualification Essential steps and example templates for Instrument Qualification: DQ, IQ, OQ, PQ Validation of existing systems Requalification: what, when Reference material: www.labcompliance.com/agilent Available until March 10, 2014 Copyright Slide 2 Regulations and Quality Standards • • • • • Good Laboratory Practices GMP Manufacturing Practices Good Clinical Practices 21 CFR Part 11: E-Records&signatures IS0 17025 • Equipment should be suitable for its intended use • Equipment should be calibrated and maintained Copyright Slide 3 US FDA; 21 CFR Part 211 - 211.68 • Automatic, mechanical, or electronic equipment or other types of equipment, including computers, or related systems that will perform a function satisfactorily, may be used in the manufacture, processing, packing, and holding of a drug product • If such equipment is so used, it shall be routinely calibrated, inspected, or checked according to a written program designed to assure proper performance. Written records of those calibration checks and inspections shall be maintained. Copyright Slide 4 Other Regulations and Guidelines Europe • EU GMP Annex 15 (draft February 2014) – Validation and qualification activities should consider all stages from initial development of the user requirements specification through to the end of use of the equipment – Steps include: User requirement specifications, design qualification, installation qualification, operational qualification and performance qualification (4Q model) United States Pharmacopeia • .USP general chapter <1058>: “Analytical Instrument Qualification” – Global standard for laboratory equipment qualification – Follows the 4Q model (see Annex 15 above) Copyright Slide 5 FDA Warning Letters • Failure of your quality control unit/laboratory to ensure that analytical instrumentation and test equipment used to assure the quality of your APIs has been appropriately qualified and calibrated for their intended use. • All laboratory instrumentation and equipment that you use to test material manufactured for the U.S. market should have an Operational Qualification (OQ) and should be calibrated to include applicable operating ranges (W-288) Perform Operational Qualification Equipment Ref: www.fdawarningletter.com Copyright Slide 6 FDA Warning Letters • Lacks documentation of installation and operation qualification of equipment (160) • The Validation Master Plan does not contain an operational qualification for xxx (164) • There is no requirement for a Performance Qualification protocol (164) Perform IQ/OQ/PQ for Equipment Ref: www.fdawarningletter.com Copyright Slide 7 FDA Warning Letter/483/EIR • The calibration program for your stability chambers is deficient ill that it does not include specific directions and schedules. • You do not perform re-qualification of the stability chambers. – 1. Develop a program for equipment calibration and calibration. Include a schedule 2. Conduct regular requalification of equipment Copyright Slide 8 FDA Warning Letters • Failure to have a complete calibration program for the HPLCs in that the gradient accuracy and detector linearity is not being verified (W-110) Perform Operational Qualification for all equipment functions Ref: www.fdawarningletter.com Copyright Slide 9 FDA Warning Letters • No chromatographic system suitability testing (W-016) 1. Develop written procedures for type and frequency of system suitability testing 2. Ensure that the procedure is followed Ref: www.fdawarningletter.com Copyright Slide 10 Analytical Instrument Qualification and and other Quality Checks • Quality control checks – Verifies accuracy of sample analysis • System suitability tests – Verifies that the system performs according to analysts expectations • Analytical methods validation – Proof that analytical procedure does what it purports to do • Analytical instrument qualification – Forms the base for generating quality data – Proof suitability of the instrument for intended use Copyright Slide 11 Qualification/Validation Phases 4Q Model Design Qualification Installation Qualification Operational Qualification Performance Qualification User requirement specifications Functional specifications Operational specifications Vendor qualification Check arrival as purchased Check proper installation of hardware and software Test of operational functions Performance testing Test of security functions Test for specified application Preventive maintenance On-going performance tests Required by FDA, Europe and USP Copyright Slide 12 Design Qualification (DQ) Activities and Documentation • Vendors – Design, develop and manufacture instruments in quality control environment, e.g., ISO 9001:2008 – Develop functional and operational product specifications • Users – Develop user requirement specifications – Verify that the vendor’s instrument meets user’s requirements: product specifications, delivery and support – Verify that the vendor operates in a quality system environment Copyright Slide 13 Design Qualification - Template Function/ Performance User Requirement Supplier Specification Comment yes/no Function 1 Function 2 Physical Requirements Construction Requirement Vendor Requirement Copyright Slide 14 Documenting Equipment Supplier Selection Items Required Results Passed Recognition in the market place □ yes □ no Experience with the vendor Reliability, response to problems □ yes □ no Quality assurance ISO 9001:2008 Certification □ yes □ no Documented Software Development. □ yes □ no Support Provide specifications list □ yes □ no Installation service □ yes □ no IQ/OQ services with Certificates □ yes □ no Phone and onsite support □ yes □ no Equipment functionality Products has required functions □ yes □ no Slide 15 Installation Qualification (IQ) Vendor • Provides the user with environmental specifications and a site prep document • Provides • Offers services for IQ with inspection ready documentation User • Verify that facilities, utilities, and environment meet vendor requirements • Assemble and install equipment • Perform initial diagnostics and testing • For complex equipment: run reference sample • Document installation, including drawings Equipment lacks documentation of installation and operation qualification (160) Copyright Slide 16 Equipment Documentation for IQ Identification Manufacturer Best HPLC Model D4424A Firmware revision 1.00 Serial Number E4431A Internal ID (Asset number) D33243 Current location Glab4 Size (w x b x h) (cm) 30x22x7 Condition when installed New Supplier contact phone for 1+541-64532 services Example: HPLC detector Copyright Slide 17 Operational Qualification (OQ) Vendor • Provides services for OQ with traceable tools • Delivers inspection ready OQ documentation • Makes recommendations for frequency of requalification User • Test functions to verify that the instrument operates in the user’s environment as intended by the manufacturer and required by the user. • Test secure data handling, storage, back-up and archiving • Tests can be holistic or modular. • Tests can be done by users or qualified designees. Conductivity meters not calibrated to a NIST traceable device (156) Copyright Slide 18 OQ Test - Example Instrument BestBalance Serial number 55236A Maximal weight 11 g Control weight 1 10,000 mg Limit +-10 mg Control weight 2 1,000 mg Limit: +-1 mg Control weight 3 100 mg Limit: +- 0.1 mg Date Weight 1 Weight 2 2/3/06 9999.8 Copyright 999.9 Weight 3 100.0 o.k. Test engineer Name Signature yes Hughes Slide 19 Performance Qualification (PQ) Vendor • Provides recommendation for PQ tests, e.g., for system suitability testing • Provides software for PQ testing, e.g., for system suitability and quality control charts User • Preventive maintenance to ensure trouble free operation for the intended application • Performance checks, based on the instrument’s typical on-site applications – Test frequency depends on the ruggedness of the instruments and the criticality of the tests – System suitability and QC tests can imply suitable performance There is no requirement for a Performance Qualification protocol (164) Copyright Slide 20 Documentation of PQ Testing Test Test Case Expected result Baseline Noise T10 <1x10-4 AU Resolution between compound A and B T11 >2.0 Tailing factor T12 <1.3 Precision of amount compound A, 6 replicate injections T13 <1% Precision of amount compound B, 6 replicate injections T14 <1% Actual Result Pass/ Fail Pass Example: HPLC System Copyright Slide 21 Summary Report Template Scope of the report Product Description Qualifiaction Strategy Responsibilities Supplier Assessment Risk assessment Testing Strategies DQ IQ OQ PQ Traceability matrix Procedures Deviations Approval Documentation control Copyright Slide 22 Validation Phases – 4Q Model APPROACH FOR EXISTING EQUIPMENT Define System Use Installation Qualification Operational Qualification Performance Qualification Document equipment use Document applications Document used functions Enter all modules and systems in a database Hardware, Firmware, Software Document past tests Test of functional specifications Test of performance functions System test (system suitability testing) Preventive maintenance + Change Control Copyright Slide 23 OQ - Requalification • Required – when the instrument undergoes major repairs or modification – After transport to an other location, if the move ‘disturbs’ instrument operation • May not be required to be repeated at regular intervals No recalibration after equipment move (154) The calibration program for your stability chambers is deficient in that it does not include specific directions and schedules.(231) Copyright Slide 24 Thank You I would like to thank • All attendees for your attention • Agilent Technologies for invitation and organization Dr. Ludwig Huber [email protected] For links to Analytical Instrument Qualification references, please check www.labcompliance.com/agilent (Available until March 10, 2014) Ludwig Huber Labcompliance Sponsored by Slide 25