Beruflich Dokumente
Kultur Dokumente
ALK A/S
2004 - 2013
Risk Assessment
Process validation Computer System Validation
Continued Process Verification
3
Process validation life cycle
4
Guideline US - the beginning of CPV
The goal of the third validation stage is continual assurance that the
process remains in a state of control (the validated state) during
commercial manufacture
http://www.fda.gov/downloads/Drugs/GuidanceComplianceRegulatoryInformation/Guidances/UCM070336.pdf
5
Guideline US
An ongoing program to collect and analyse product and process data that
relate to product quality must be established.
The data collected should include relevant process trends and quality of:
• incoming materials or components
• in-process material
• finished products.
We recommend that the quality unit meet periodically with production staff to
evaluate data, discuss possible trends or undesirable process variation, and
coordinate any correction or follow-up actions by production.
6
How to implement CPV?
US: Procedures should describe how trending and calculations are
to be performed and should guard against overreaction to an
individual event
7
1. Pre-requsisties for CPV
8
2. State of control - variation
Knowledge of process variation – common or special cause
9
2. State of control - variation
11,5
should be investigated. 8
UCL
1 3 5 7 9 11 13 15
9 UCL
10
2. State of control - process capability
Process capability is the repeatability and consistency of a manufacturing
process relative to the requirements in terms of specification limits (LSL
and USL) of a product parameter. This measure is used to objectively
measure the degree to which a process is or is not meeting the
requirements.
The Cpk compares the distance of the mean of the process to the nearest
specification limit with the process variation, and any number above 1,33
illustrates that there are at least 3 standard deviations from the mean to
nearest specification limit.
11
3. CPV activities
The validated state obtained from the PPQ is to be maintained by a series
of activities during the period the product is on the market.
12
3. CPV activities - protocol content
Purpose
Continual assurance that the process remains in a state of control (the
validated state) during commercial manufacture
Prerequisite
Finalized PPQ, Control strategy incl. risk assessment
Responsible
Production- establish protocol, statistically trained, prepare for CPV
meetings
QA – participate in CPV meetings, evaluate data, discuss possible trends
or undesirable process variation, and coordinate any correction or follow-
up actions
Interval
Periodically- based on a risk assessment
13
3. CPV activities - protocol content
Method for detection variation and capability
Control charts, trend rules, Cpk calculation, inter and intra batch variation
- Start by defining which CPP’s, IPC’s and CQA’s are included
Data
Samples from incoming materials, In-process and finished product
Handling of observations
Use change request system implemented in the firm
Sampling
Define whether extended sampling are needed
14
3. CPV activities - protocol content
Practical example
Extended
Control charts, see SOP updates, see Holding time study,
sampling, see
section 12.1 section 12.2 see section 13.9
section 14
15
3. CPV activities - protocol content
Protocol example:
Section 9: Equipment, Utilities and facility
16
3. CPV activities - protocol content
Protocol example
Section 10 - Product, Changes and Deviations
OOS/OOT, deviations and CC-cases related to the manufacturing
process are evaluated in the PQR [22;23], this is evaluated to be
sufficient for securing process control with regard to these parameters.
Evaluation of incoming source material is not part of the PQR, and hence
will be incorporated in the CPV. During yearly CPV all new batches of
source material must be listed [1].
17
3. CPV activities - protocol content
Protocol example
18
3. CPV activities - protocol content
Protocol example
Control charts – CPP’s (and IPC’s and CQA’s)
Process Process
Input Purpose of CPV Comment
Step Parameters
(1) In [5] a control limit of 15.56 – 16.38
Dissolution g SM was calculated, based on 25 Batch Size (input of
data points. This is as stated in [1] SM), see section 13.1
Batch size enough data for final control limit,
Report SOP update, see
(input of SM) hence purpose of CPV is to
implement control limits in section 12.2
manufacturing SOP’s, and as a Control Chart, see
control chart. section 12.1.
It’s a manual shaking, so enhanced
Stirring speed control will be added by including
SOP update, see
during Protocol check for everything is dissolved,
section 12.2
solution and no foam formation in
manufacturing SOP’s.
19
3. CPV activities - protocol content
Control chart example
20
3. CPV activities - report
Reporting – after each batch
After each batch data are entered by hand in all control charts, and
sheets for noting batch numbers and source materials, double
control of entered data is performed.
21
3. CPV activities - report
Yearly (only yearly for this product due to low manufacturing
frequency)
22
3. CPV activities - report
Strategy: Make it simple!!!!
The report must be written during the review meeting.
23
3. CPV activities - report
24
3. CPV activities - report
Recalculation of the final control limits is acceptable if all the
following conditions apply simultaneously:
• The change is positive e.g. tighter limits, higher yield, lower
impurity level
• The root cause is known and acceptable
• There is assurance that the change is going to be permanent
• At least 20 samples confirm the new process (NB! – 20
independent samples)
25
Implementation of CPV
- Legacy processes
By Senior Chemist, Linda Bech Pihl, Global Product Support, ALK
What is a legacy process?
Legacy Process A process that has been in commercial use for more
than 2 decades, and where development
documentation according to current standards is not
available
27
Challenge
inadequate
Lacking
X
Still expected to fullfill
demands
28
Solution?
29
Solution – Drug Substance
Product Validation Plan (PVP) Crit. material
Crit. equipment
Risk
Assessment Crit. Controlled
(Patient safety) documents
CQA
PP
Severity
PPE (vers. 1)
CPP
Retrospective Control
Validation Strategy
(protocol and
report)
IPC
PPE (vers. 2)
30
Learnings
• Ease the PQR process (data collection on-going)
• Ease the handling of deviations
• Increased process knowledge for responsible chemist in
production and QA
• Established system for handling of additional samples in a
validated process
• Process capability results have been an eye-opener
31
Extra slides
32
CPV versus on-going process verification
The term continued process verification is used in US and the term on-
going process verification is used in EU.
http://ec.europa.eu/health/files/eudralex/vol-4/2015-10_annex15.pdf
33
2. State of control - variation
The typical form of a control charts sets control limits at plus/minus three standard
deviations.
That means if the process is in statistical control, the risk of a point falling outside the
limits by chance is 3 per 1000. The process is influenced by chance 99.73 % of all
results do fall within 3 STD
34
2. State of control - variation
35