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Method validation is the process used to confirm that an analytical procedure employed for a specific test is reliable,
reproducible and suitable for its intended purpose. All analytical methods need to be validated prior to their
introduction into routine use, and this is especially true for novel technology platforms, such as rapid microbiological
methods (RMMs).
Because many RMM technologies consist of a combination of instrumentation, software, consumables and reagents,
in addition to specific detection, quantitative or identification methodologies, it is important to develop a
comprehensive and holistic approach to the validation process to ensure that the entire RMM system is suitable for its
intended use. The following sections provide an overview of how to design a meaningful validation program in order
to effectively demonstrate that the new RMM is suitable for its intended use and is equivalent to, or better than, the
existing method you intend to replace.
The majority of the guidance provided on this page has been excerpted from Dr. Michael J. Millers Training
Course on RMM validation and implementation, which is now aligned with the newly revised PDA Technical Report
No. 33 (Revised 2013).
INITIAL ACTIVITIES
Prior to purchasing and validating a RMM, there are a number of due diligence activities that should be undertaken.
These can include understanding and identifying the scientific and technical benefits the RMM possesses as
compared with the existing method, regulatory impact, financial advantages (e.g., return on investment), and the
capabilities and role of the RMM supplier in terms of providing support during the initial assessment, validation, and
most importantly, after the system has been placed in service for routine use. Each of these considerations are
discussed in greater detail below.
From a scientific perspective, it is important to understand what technical capabilities are required, including, but not
limited to, method sensitivity and specificity (e.g., detection levels and for what types of microorganisms), sample
throughput, sample type, automation, data handling and archiving, report management, if the system needs to meet
21 CFR Part 11 expectations, and the required degree of operator training.
Next, proof-of-concept or feasibility testing can be performed to determine if incompatibilities exist between the RMM
and the intended product or test sample(s). These types of studies can also be performed in the event the RMM
supplier has little or no data on testing similar product or test materials. This can be accomplished using a rental or
loaner instrument, or by sending samples directly to the RMM instrument supplier for evaluation. The data obtained
from these initial studies will help with the decision to purchase the RMM and proceed with formal validation activities.
The due diligence process also involves a review of existing regulatory commitments and whether implementing the
RMM will result in significant changes that will require a formal submission to relevant regulatory bodies. Additionally,
a financial assessment of the costs (and cost savings) associated with the purchase, validation and implementation of
the RMM should be performed. Information on both of these topics can be reviewed by visiting
the Regulatory and ROI (return on investment) pages.
Finally, the selection of a rapid method supplier is just as important as the technology itself, and it is important to have
a thorough understanding of the supplier's technical capabilities and their ability to support each phase of the
validation process as well as continuing assistance once the RMM is placed into service. When deciding on a RMM
and a RMM supplier, some points to consider may include the following:
Does the supplier have a robust quality, change control and manufacturing system in place?
Do they have appropriate documentation with regard to the design and manufacture of their instrumentation?
Are they the sole provider of the RMM consumables, reagents, supplies or replacement parts?
Do they provide on-site technical services, calibration and preventive maintenance programs? Can they respond
to technical issues in a timely manner?
Have they published results of their own testing or have they submitted a Drug Master File of similar document
to a regulatory agency?
How does the supplier manage software updates and notification to the end-user?
Suppliers should be assessed to determine if they can meet your requirements. This can be accomplished through a
formal audit or supplier questionnaire.
In summary, the initial assessment of a RMM should include a comprehensive scientific, regulatory and business due
diligence review, in addition to matching the appropriate technology with the desired microbiology application. It is not
uncommon for companies that have purchased a RMM system to spend considerable time, resources, and expense
in validating the instrumentation and method, only to find at a later date that the technology is incompatible with the
process and/or product being evaluated, or that the sensitivity and/or specificity of the system is not what was
originally anticipated. Therefore, careful planning and fact finding during the due diligence phase is critical to a
successful RMM validation and implementation program.
Risk Assessment
Validation Planning
System Integration
Method Validation
Method Suitability
RISK ASSESSMENT
Quality risk management (QRM) is an important part of science-based decision making. The ICH Q9 guideline,
Quality Risk Management, defines QRM as a systematic process for the assessment, control, communication and
review of risk to the quality of drug product across the product lifecycle. Similarly, the FDA Final Report for
Pharmaceutical cGMPs for the 21st Century - A Risk-Based Approach, states that using a scientific framework to find
ways of mitigating risk while facilitating continuous improvement and innovation in pharmaceutical manufacturing is a
key public health objective, and that a new risk-based pharmaceutical quality assessment system will encourage the
implementation of new technologies, including RMMs, to facilitate continuous manufacturing improvements via
implementation of an effective quality system.
A risk assessment should be performed prior to the start of any RMM validation activity. Identified risks will vary
depending on the RMM technology and the RMM supplier, the method the RMM is intended to replace, the product or
sample(s) for evaluation, whether the new measurements are qualitative or quantitative and if the resulting data are
significantly different from the existing method, method variability, method robustness, pharmacopeial equivalence,
regulatory acceptance, and other attributes.
First, the user should identify the hazards (i.e., what might go wrong when implementing the RMM), the likelihood of
occurrence, severity of harm and the ability to detect the hazard. Next, the user will analyze the risk against
predefined criteria, and determine how the risks will be addressed. Tools such as Failure Modes and Effects Analysis
(FMEA) or Hazard Analysis and Critical Control Points (HACCP) may be utilized in assessing the potential risks when
implementing the RMM.
Excluded characteristics
Safety requirements
Supplier requirements
Documentation
User manuals
Guidelines
Standards
SOPs
Physical specifications
Size
Electrical power
Voltage frequency
Operating temperature
Environmental requirements
Utility requirements
Operating software
Printer ports
Databases
Security specifications
Access to data
Record retention
Audit trail
Administrative control
21 CFR Part 11
Functional specifications
Accuracy
Precision
Specificity
Limit of detection
Limit of quantification
Linearity
Range
Ruggedness
Robustness
Equivalency
System customization
System operation
Training
Calibration
Preventive maintenance
Change control
SYSTEM INTEGRATION
System integration brings together all of the component subsystems into a single, operating system and ensures that
all of the components function appropriately. An example may include setting up the RMM to communicate with a
Laboratory Information Management System (LIMS). Many RMM systems are not required to be connected to an
external server or IT platform; however, if this is required by a firms IT organization, system integration testing may
be necessary.
Equipment installation
Environmental conditions
Preventive maintenance
Safety checks
Required utilities
Computer access
Audit trails
Report generation
PDA Technical Report No. 33, Evaluation, Validation and Implementation of Alternative and Rapid
Microbiological Methods
United States Pharmacopoeia Informational Chapter <1223>, Validation of Alternative Microbiological Methods
European Pharmacopoeia Chapter 5.1.6, Alternative Methods for Control of Microbiological Quality
The most up-to-date validation guidance may be found in PDA TR No. 33. Revised in 2013, TR33 incorporates the
latest information on testing strategies, the use of statistics, acceptance criteria and industry best practices. Both the
USP and Ph. Eur. chapters are undergoing revisions, with drafts expected sometime in 2014; however, until the
drafts are available for public review and comment, it is not possible to determine how similar (or different) the
chapters will be as compared with PDA TR33. We will update this page as the compendia drafts are made
available.
A brief review of the validation criteria from each guidance document is provided below. Please note that there are
differences in how the validation criteria and acceptance criteria are employed in EACH document, and we expect the
USP and Ph. Eur. requirements will significantly change with their next revision. In the meantime, many companies
now follow the revised PDA TR33 to meet their internal and external regulatory expectations when validating RMMs
(REMINDER: always check with the relevant regulators before embarking on a validation program, as appropriate).
Validation Criteria for Quantitative Tests
PDA TR33
USP <1223>
PDA TR33
USP <1223>
PDA TR33
USP <1223>
The following definitions and recommendations are aligned with PDA TR33. Similarities may exist with the USP and
Ph. Eur. chapters.
Accuracy is the closeness of the actual test results obtained by the new method to the actual test results obtained by
the existing method (e.g., plate count). Accuracy is demonstrated across the practical range of the test, and is usually
expressed as the percentage of recovery of microorganisms. Accuracy is usually assessed for quantitative methods,
although microbial identification systems requires Accuracy testing as well (see below).
Precision is the degree of agreement among individual test results when the procedure is applied repeatedly to
multiple samplings of the same suspension of microorganisms and using different suspensions across the range of
the test. Precision is associated with the use of the method within the same laboratory over a short period of time
using the same analyst with the same equipment (also referred as repeatability, within-run variability or intra-assay
precision). Precision is usually expressed as the standard deviation or coefficient of variation of a series of
measurements.
Specificity is the ability to detect a range of microorganisms which demonstrates that the method is fit for its
intended purpose. Specificity is usually assessed during testing of the relevant validation criteria (e.g., Accuracy) for
both quantitative and qualitative methods. Inclusivity and exclusivity testing may also be included for this methods
that are designed to specifically detect a target organism and exclude all others. Organisms may be sourced from
culture collections (e.g., ATCC), environmental or facility isolates, in-process or sterility failure isolates, slow-growing,
fastidious or anaerobic strains, and/or clinically relevant cultures.
Limit of Detection (LOD) is lowest concentration of microorganisms in a test sample that can be detected, but not
necessarily quantified, under the stated experimental conditions. The test determines the presence or absence of
microorganisms in the original sample (e.g., sterility test).
Limit of Quantification (LOQ) is the lowest number of microorganisms in a test sample that can be enumerated with
acceptable accuracy and precision under the stated experimental conditions.
Linearity is the ability to elicit results that are proportional to the concentration of microorganisms present in the
sample within a given range, where accuracy and precision are demonstrated .
Range is the interval between the upper and lower levels of microorganisms that have been demonstrated to be
determined with Accuracy, Precision and Linearity.
Ruggedness is the degree of intermediate precision or reproducibility of test results obtained by assessing the same
samples under a variety of normal test conditions, such as different analysts, different instruments, different lots of
reagents or on different days. Intermediate precision is performed within the same laboratory, and reproducibility is
performed between laboratories. Ruggedness is best suited to be determined by the supplier of the test method who
has easy access to multiple instruments and batches of components; however, similar studies may be conducted by
the end user.
Robustness is measure of a methods capacity to remain unaffected by small but deliberate variations in method
parameters and provides an indication of its reliability during normal usage. Robustness is best suited to be
determined by the supplier of the test method who has easy access to multiple instruments and batches of
components; however, similar studies may be conducted by the end user.
Equivalence or Comparative Testing is the level of agreement in accuracy, precision, specificity, limit of detection,
limit of quantification, linearity and/or range between the existing and the new method. This is initially demonstrated
using standardized microbiology cultures (see above) and separately using actual product and other sample matrices
that will be routinely tested using the new method once it is validated and implemented. However, prior to testing with
actual product or test samples, these materials should be assessed for their potential to cause background noise,
interference, false positive or false negative results (see Method Suitability below). Test samples should be identified
that are expected to contain microorganisms in order to demonstrate that the new method will detect microorganisms
similarly as the existing method. Furthermore, low levels of microorganisms may need to be inoculated into test
samples in order to conduct the evaluation for equivalency (e.g., when using a sterile product to demonstrate the
LOD for a rapid sterility test). The new method should be run in parallel with the existing method for a specified period
of time or number of product batches or test samples (the end-user should determine the most appropriate strategy
for the duration and extent of these studies).
NOTE TO READERS:
Detailed validation procedures, specific acceptance criteria and recommended statistical models are NOT
provided on this webpage.
Readers should consult with a relevant guidance document (PDA TR33, USP and/or Ph. Eur.) for this
information.
Method Suitability
Each test material should be evaluated for the potential to produce interfering or abnormal results, such as false
positives (a positive result when no viable microorganisms are present) or false negatives (a negative result when
microorganisms are present). This may also include evaluating whether cellular debris, dead microorganisms or
mammalian cell cultures have any impact on the ability of the new method to operate as it is intended to. If false
positives or negatives cannot be resolved, then the test sample may be incompatible with the new method.
Validation of Microbial Identification Systems
New or rapid microbial ID systems are usually tested for Accuracy and Precision (Repeatability). The end-user should
establish suitable acceptance criteria for each, taking into account the ID methods specific capabilities. For example,
the ID system may not be able to identify an isolate because the organism is not included in the database, the system
parameters are not sufficiently comprehensive to identify the organism, the isolate may be nonreactive in the system,
or the species may not have been taxonomically described.
plan should include a list of microbial isolates to be evaluated and what qualification requirements they will be tested
against.
Next, if the originating qualification did not include the actual product and/or process material that the site will be
evaluating routinely, then these materials must be evaluated during the local PQ where the impact of sample material
on the test method is assessed (i.e., during Method Suitability studies). The site will then determine the nature of the
test plan to provide meaningful data about the ability of the RMM system to operate as it is intended. This may
include some required number of batches, replicates, location of sampling points, length of study, etc. Additionally,
sufficient data will be required to evaluate whether the data from the RMM is statistically greater than the method
being replaced, and whether the data warrants a modification to baseline acceptance levels or product specifications
(see additional information on changing acceptance criteria).