null 美国FDA验证高级
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Denis Kluba 博士
吴培栋 博士目录Table Of Contents目录Table Of Contents验证定义
CGMP对验证的要求
验证历史与期望
验证综述
验证主
方案
气瓶 现场处置方案 .pdf气瓶 现场处置方案 .doc见习基地管理方案.doc关于群访事件的化解方案建筑工地扬尘治理专项方案下载
与
规划
污水管网监理规划下载职业规划大学生职业规划个人职业规划职业规划论文
实施验证的方法
验证的技术内容要求
执行验证方案
工作流程
改变控制
再验证
总结
Part One: What is Validation?Part One: What is Validation??第一部分:验证定义What is Validation?What is Validation?For this Seminar it refers to two things:
1. The USA FDA requirements that must be met in order to successfully and continually sell drug products in the USA
2. Activities that will contribute to the success of the company in the manufacture of drug products验证的含义?ValidationValidation“Anything which you cannot understand is indistinguishable from magic.”
Arthur C. Clark
“Validation may not be magic!”
C. Edwards业内对验证的理解Validation Is.....Validation Is.....“Documented evidence which provides a high
degree of assurance that a specific process
will consistently produce a product meeting
its predetermined specifications and quality
attributes.”FDA对验证的定义Why Do We Validate?Why Do We Validate?To Consistently Produce A Desired Known ProductConfirm
DesignEstablish Operating
BoundariesEstablish BaselinesProduct
ComplianceTest within
Specification验证的作用/目的How Do We Validate?How Do We Validate?Details Will Follow But This is the General ModelIdentify Equipment
SystemsDevelop TestsWrite ProtocolsConduct TestsEvaluate DataReport ResultsResults OK?yesNoAmend
ProtocolAmend
TestCollect DataValidated SystemSystem Modified?验证流程图First three steps to CGMP complianceFirst three steps to CGMP compliancedocument
document
document符合CGMP要求的头三步Boundaries of ValidationBoundaries of ValidationCOMMISSIONING
START-UP
TROUBLE SHOOTING
TRIAL RUNS
CYCLE DEVELOPMENT
PROCESS DEVELOPMENT
ENGINEERING STUDIES
VENDOR SERVICE REPORTS
FACTORY ACCEPTANCE TEST
“AS-BUILT” DRAWINGS STANDARD OPERATING
PROCEDURES
MFG BATCH RECORDS
PERSONNEL TRAINING
CALIBRATION
PREVENTATIVE MTCE
CHANGE CONTROL
COMPLIANCE
VENDOR AUDITS
ANNUAL REVIEWS
COMPLAINTS
SAFETY验证的界限/范围Validation Life Cycle ApproachValidation Life Cycle ApproachProspective / ConcurrentDefine Specifications
Equipment
Process RequirementsProceduresNew / Revised Process / Product验证生命周期:
新的/修改过的工艺/产品Validation Life Cycle ApproachValidation Life Cycle ApproachRetrospectiveDefine System
Specifications
Equipment ProceduresExisting Process / Product验证生命周期:
现有工艺/产品Benefits of ValidationBenefits of ValidationIncreased Throughput
Reduction In Rejections and Reworks
Reduction In Utility Costs
Avoidance Of Capital Expenditures
Fewer Complaints About Process Related Failures
Reduced Testing – In-process and Finished Goods
More Rapid / Accurate Investigations Into Process Upsets
More Rapid and Reliable Startup Of New Equipment
Easier Scale-up From Development Work
Easier Maintenance Of The Equipment
Improved Employee Awareness Of Processes
More Rapid Automation验证带来的好处Elements Of Contemporary Validation In The USElements Of Contemporary Validation In The USEquipment Calibration - Process and Validation Equipment
Equipment Qualification - Installation and Operational
Process Development
Process Documentation
Performance Qualification - "Validation"
Maintenance of Validation - Process and Equipment Change Control 当今美国验证包含的内容cGMP and ISO-9000 - SimilaritiescGMP and ISO-9000 - SimilaritiesAimed at Quality
Require Documentation
Require Specific Quality Program
QA and QC IncludedCGMP和 ISO 9000的相似之处cGMP and ISO-9000 - DifferencescGMP and ISO-9000 - DifferencescGMP Aimed at Product
ISO-9000 Includes Design and Service, as well
cGMP Covers Activities Directly Related to Manufacturing
ISO-9000 Covers Broader Range of Activities (e.g.. Purchasing)
cGMP Requires Formal Validation
ISO-9000 Requires Applicable Statistical MethodsCGMP和 ISO 9000的不同之处Benefits of the Systems Approach to ValidationBenefits of the Systems Approach to ValidationMore Rigorous Control Over Operations
Centralized Planning for all Validation Related Aspects
Ties Existing Sub-elements into Cohesive System
Establishes Validation as a Program, not a Project
Provides for Continuity of Approach
Affirms Validation as a Discipline Much like Others
Allows For Personnel Growth within the Validation Expertise
Usually Results in Centralization of Validation Expertise
More Compatible with the Accomplishment of a Corporate Objective for Validation系统验证方法的好处The Validation ProgramThe Validation ProgramEstablish Goals and Objectives as to What Must be Validated
Qualify or Re-qualify the Equipment
Establish Validation Protocols for each, and obtain Approval of the Protocols
Establish Personnel Requirements and Training Records Procedure
Design and Conduct Experiments. Collect Data
Evaluate the Data
Prepare Summary Reports Outlining the Results of the Experiments. Obtain the Necessary Approvals
Establish and Maintain Validation Files Including Raw Data
Institute a Change Control Procedure to Insure the Ongoing Acceptability of the Work 验证项目/规划Part Two: GMP RequirementsPart Two: GMP Requirements第二部分:GMP对验证的要求GMP requirementsGMP requirementsPart 211: Current good manufacturing practice for finished pharmaceuticals §211.68 - Automatic, mechanical, and electronic equipment. §211.84 - Testing and approval or rejection of components, drug product containers, and closures. §211.110 - Sampling and testing of in-process materials and drug products. §211.113 - Control of microbiological contamination. §211.165 - Testing and release for distribution. §211.166 - Stability testing. GMP要求cGMP in the Pharmaceutical IndustrycGMP in the Pharmaceutical IndustryGMP is the abbreviation of “Good Manufacturing Practice” which is adopted by the medical and health related industries including the pharmaceutical industry in an effort to maintain the highest standards of quality in the development, manufacture and control of medicinal products. Since the industry standards are subject to continuous improvement, the letter ‘c’ in the abbreviation “cGMP” refers more specifically to the current or the latest version of the GMP requirements. 制药行业的cGMPRegulatory Requirements for Validation.....Regulatory Requirements for Validation.....The requirement of process validation is implicit in the language of 21 CFR 211.100 of the Current Good Manufacturing regulations which states:
“There shall be written procedures for product and process control to assure that drug products have the identity, strength, quality, and purity they purport or are represented to possess."
监管部门对验证的要求GMP Regulatory Requirements
for Cleaning ValidationGMP Regulatory Requirements
for Cleaning Validation1978 cGMP Regulations (part 211.67(a)) Equipment cleaning and maintenance states:
“Equipment and utensils shall be cleaned, maintained, and sanitized at appropriate intervals to prevent malfunctions or contamination that would alter the safety, identity, strength, quality, or purity of the drug product beyond the official or other established requirements”.
GMP条例对清洗验证的要求GMP Regulatory Requirements
for Test Method ValidationGMP Regulatory Requirements
for Test Method ValidationLaboratory Controls 21 CFR 211.165(e) states:
The accuracy, sensitivity, specificity and reproducibility of test methods employed by the firm shall be established and documented. Such validation and documentation may be accomplished in accordance with Part 211.194(a)(2). GMP条例对化验方法验证的要求GMP Regulatory Requirements
for Test Method ValidationGMP Regulatory Requirements
for Test Method ValidationPart 211.194(a)(2) states:
A statement of each method used. . . shall indicate the location of data that establish that the methods used in the testing of the sample meet proper standards of accuracy and reliability as applied to the product tested. The suitability of all testing methods used shall be verified under actual conditions of use.GMP条例对化验方法验证的要求GMP Regulatory Requirements
for Test Method ValidationGMP Regulatory Requirements
for Test Method ValidationU.S. Federal Court decision:
United States vs Barr Labs
Cleaning Validation: . . . it was ruled for cleaning to be effective, the specific test methods had to be shown to be effective.GMP条例对化验方法验证的要求PROCESS VALIDATIONPROCESS VALIDATION21 CFR 211.110
“such control procedures shall be established to monitor the output and to validate the performance of those manufacturing processes that may be responsible for causing variability in the characteristics of in-process material and the drug product” 工艺验证Part Three: History and ExpectationsPart Three: History and ExpectationsAs applied by the FDA and Implemented by Industry第三部分:验证历史与FDA和制药行业对验证的期望History and expectationsHistory and expectationsLearn for the experiences of the USA manufacturers and industry organizations
Current applications
Past citations
Industry guidelines
ICH Q7A
ISPE
PDA
Etc.历史与期望Validation TargetsValidation TargetsEarly Years
Sterilization
Aseptic Operations
Middle Years
Non-sterile Processes
Oral Dosage Forms
Recent Years
Biological Processes
Bulk Organic Synthesis
Developmental and Pilot Operations
Supporting Services
Currently
Total Operations
Review by Systems
Quality System
Production System Laboratory Controls
Packaging and Labeling, Materials and Facilities
Equipment Manufacturing. 验证目标History of ValidationHistory of ValidationValidation in The Early Years - 1972 to 1978
Regulatory Based to Satisfy FDA Pressures
Defensive to Protect Product Line
Validation in Its' Adolescence - 1978 To 1983
Primarily Defensive
Some Efforts at Process Optimization
Includes Some Peripheral Concerns
Validation in the US Today - 1983 to Present
Non- Regulatory in Many Areas Geared Towards Optimization and focused on Systems 验证历史"validation" vs. "VALIDATION""validation" vs. "VALIDATION""validation"
Defensive
Testing Oriented
Costly
Quality Control
Narrow Focus"VALIDATION"
Optimization
Total Process Control
Cost Effective
Quality Assurance
Diverse Application如何正确理解验证Elements of Contemporary Validation in the USElements of Contemporary Validation in the USEquipment Calibration - Process and Validation Equipment
Equipment Qualification - Installation and Operational
Process Development
Process Documentation
Performance Qualification - "Validation"
Maintenance of Validation - Process and Equipment Change Control 当今美国验证所包含的内容/要素ExpectationsExpectationsValidation is a Program not a Project
Validation Contributes to the Stability of the Operations
Validation is not Someone Else's Job!对验证的期望Part Four: ValidationPart Four: ValidationAn Overview第四部分:验证概述Who Validates?Who Validates?Validation StaffEngineeringQuality AssuranceQuality ControlManufacturing谁进行验证?ValidationValidationvDesignTestingOperation验证运作ValidationValidationvVendorSystems
IntegratorOwner/User验证系统集成者ValidationValidationvEngineering
R&D
Validation Team
MaintenanceManufacturing
Quality Assurance验证制造质量保障Write ProtocolsWrite Protocols起草方案Example Data SheetsExample Data Sheets数据单样品Conduct TestingConduct TestingChemical TestsCareful Review and
Markup of Prints, SpecsMicrobiological
TestsPhysical Tests
(Temp., Press., Flow)Computer Tests进行测试Installation Qualification (IQ)Installation Qualification (IQ)IQ documents that
system is installed in accordance with approved design, specification and regulatory codes
manufacturers installation recommendation have been taken into consideration
IQs implemented concurrently with construction of each system
安装合格确认Operational Qualification (OQ)Operational Qualification (OQ)OQ documents that the equipment:
can operate as designed and intended
is capable of repeatable operation over the entire operating range of process variables
OQ executed when equipment can be started up
运转/运作合格确认Process Qualification (PQ)Process Qualification (PQ)PQ documents
critical systems which can be challenged
test procedures
product quality attributes to be evaluated
acceptance criteria
alert/action levels
system validated under "worst case conditions"
generally 3 consecutive successful runs required
工艺合格确认Definition of Process ValidationDefinition of Process ValidationValidation is:
Documented evidence that provides a high degree of assurance that a specific process will consistently produce a product of a certain predetermined quality. 1978工艺验证定义Definition of Process ValidationDefinition of Process ValidationIn addition to documented evidence that a process will perform reliably and repeatedly, validation, in its highest form, provides an understanding of why.1993工艺验证定义Stages of the Life-CycleStages of the Life-CycleR&DDesignConstructionTestingSOPs/MaintenanceChange
Control生命周期的阶段Benefits of ValidationBenefits of ValidationIncreased Throughput
Reduction in Rejections and Reworks
Reduction in Utility Costs
Avoidance Of Capital Expenditures
Fewer Complaints About Process Related Failures
Reduced Testing – In-process and Finished Goods
More Rapid / Accurate Investigations Into Process Upsets
More Rapid and Reliable Startup Of New Equipment
Easier Scale-up From Development Work
Easier Maintenance Of The Equipment
Improved Employee Awareness Of Processes
More Rapid Automation 验证的好处Documentation of ValidationDocumentation of ValidationMaster Plan
Protocol
Data Sheets
Report
Procedures验证文件Validation ProtocolsValidation ProtocolsProvide an Outline of the Validation Effort
Include a Clear Definition of What Will Be Validated
Is Uniquely Identified
Is Dated
Approved By Competent Individuals In Responsible Areas
Are Suitable For Review By Regulatory Agencies验证方案Validation Protocol Essential ElementsValidation Protocol Essential ElementsIntroduction/Abstract
Description of Process or System
Test Plan
Responsibilities
Acceptance Criteria
Approvals
Append Data Sheets, Etc.验证方案的核心要素Validation Reports – FunctionsValidation Reports – FunctionsRestrict to One Task or Subject
Has a Unique Identification
Is Dated
Formally Reviewed and Approved
Identifies Protocol(s) Used in the Study
Is Suitable for Review by FDA验证报告-功能Validation Report - ContentsValidation Report - ContentsAbstract Or Summary Conclusion
Plan Of Study
Experimental
Results
Conclusions
Protocol Reference
Diagrams
Any Miscellaneous Information
Approvals验证报告-内容Installation Qualification (IQ)Installation Qualification (IQ)IQ Documents That The:
System is Installed in Accordance with Approved Design, Specifications and Regulatory Codes
Manufacturers Installation Recommendations have been taken into Consideration
IQ is Implemented Concurrently with Construction of Each System安装合格确认Design DocumentationDesign DocumentationDesign and Procurement Documentation Support of IQ:
PFDs/P&IDs
Critical System Installation Drawings (E.G. Water System Isometrics, Sanitary Duct Drawings)
Purchase and Installation Specifications
Vendor Manuals and Prints
Computer Software Documentation
设计
领导形象设计圆作业设计ao工艺污水处理厂设计附属工程施工组织设计清扫机器人结构设计
文件Construction DocumentationConstruction DocumentationConstruction Documents In Support Of IQ:
Slope Checks
Piping Pressure Test Reports
Motor Checkout Reports
Weld Inspection Reports
Cleaning, Passivation and Sanitization Procedures and Reports
HVAC Test and Balance Reports
Other Appropriate Construction Documentation建造文件The P&IDThe P&IDProcess Equipment
Support Vessels
Interconnecting Lines
Utility Lines
Instruments/Instrument Functions
Schematic
No Scale - Not Spatially Precise
Shows Relationships and Relative Position(Piping & Instrumentation Diagram, Engineering Flow Diagram)管线和仪器图Operational Qualification (OQ)Operational Qualification (OQ)OQ Documents That The Equipment:
Can Operate as Designed and Intended
Is Capable of Repeatable Operation Over the Entire Operating Range of Process Variables
OQ Implemented After Equipment has been Started Up or Commissioned运作合格确认Process Qualification (PQ)Process Qualification (PQ)PQ Documents That:
Processes Operate as Required at the Normal Operating Limits of Critical Parameters
Systems Operate Consistently and Reliably
Appropriate Challenges Are Employed工艺合格确认Review and ApprovalsReview and ApprovalsDesign Drawings and Specifications
Master Plan
Protocols
Reports
Procedures审阅和批准Part Five: Validation Master PlanningPart Five: Validation Master Planning第五部分:主验证规划PlanningPlanning“If you don’t know where you are going, you are likely to end up someplace else!” - Lewis Carroll
Like any other important activity in a complex organization validation must be managed. This is especially true given the multi-disciplined nature of many validation activities.规划Existing PlantsExisting PlantsThe same level of management is necessary for the validation of an existing facility, whether fully validated or not.
Validation is easier when it is an integral part of the day-to-day operation of the facility. 现有工厂Master PlanMaster PlanDefines and Establishes the Validation Approach and the Acceptance Criteria
and more!主方案Facilities, Processes or ProductsFacilities, Processes or ProductsWhat needs to be done?
Who will do it?
How will they do it?
How long will it take?
How much will it cost?设施,工艺或产品Master Plan - GeneralMaster Plan - GeneralIntroduction to Facility Purpose and Design Intent
Facility/Process Description
Process Control Considerations
System Definitions
Planning/Scheduling主方案概述Master Plan - WhyMaster Plan - WhyProject Familiarization/Training
Management Introduction
FDA Introduction/Familiarization
Validation Program Foundation
Basic Procedures
Protocol Outlines/Bases
Resource Planning/Scheduling
Contract Execution Interaction
Codifies Prior Decisions
Structures Validation Activities
Facilitates Regulatory Compliance
Useful in Regulatory and Client Interactions
Use With 3rd Parties
Convertible Into Drug Master File
Internal Audit Preparation为什么需要主方案?Master Plan - WhatMaster Plan - WhatIntroduction
Facility / Process / Product Description
Process Control Considerations
System Definition
Protocol Outlines/Acceptance Criteria
Formats
SOPs
Planning/Scheduling什么是主方案?Master Plan - Getting StartedMaster Plan - Getting StartedFacility Layout
Process Description(s)
Product Description(s)
Equipment List
Utility List
Controlled Environment Requirements
Control Philosophy
Schedule主方案的起点Master Plan – Facility DescriptionMaster Plan – Facility DescriptionLayout/Equipment Arrangement
People/Material/Component Flow
Controlled Environments
Materials of Construction
Sketches主方案中的设施描述Master Plan - Process DescriptionMaster Plan - Process DescriptionMajor Process Steps
Block Diagram
Process Flow Diagram(s)
Utilities (WFI, DI, CIP, Etc.)
Major Support Equipment
(Autoclaves, Ovens, Etc.)主方案中的工艺描述Master Plan - Process ControlMaster Plan - Process ControlGeneral Architecture
Central/Distributed Control System
PLCs/Individual Control Systems
Building Automation System
Higher Level Systems (LIMS, EBR, Etc.)
Integrate into other Sections if Minimal主方案中的工艺控制Master Plan - Validated SystemsMaster Plan - Validated SystemsLists Of Systems To Be Validated
General Acceptance Criteria
Specific Acceptance Criteria
Basic Protocol Outlines主方案中验证过的系统Master Plan - Procedures and FormatsMaster Plan - Procedures and FormatsProtocol Format
SOP Format
Basic Procedures
Validation Program
Responsibilities
Calibration
Change Control
List Of SOPs
主方案的流程和格式Master Plan - Planning and Scheduling Master Plan - Planning and Scheduling Manpower Resources
Document Preparation
Field Execution
Calibration
Lab Support
Test & Balance/Filter Certification
Start-Up/Commissioning主方案的规划与
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Master Plan - FocusMaster Plan - FocusSterile Products Facility
Emphasis On Facility and Environment
People, Component, Product Flows
Automation May Or May Not Be Central
Support Systems Critical (Autoclaves, Ovens, WFI, Etc.)
主方案的集中点Master Plan - FocusMaster Plan - FocusSolids Facility
In-process Controls
Tests
Examinations to be Conducted on Appropriate Samples of In-process Materials of Each Batch 主方案的集中点Master Plan - FocusMaster Plan - FocusAPI Facility
Emphasis On Chemical Process
Identify API Step
Cross-c