Professional Documents
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INTRODUCTION
Validation begins with good process development. It requires that process developers understand
the necessity to design a process that will be capable of ultimately meeting predetermined
specifications without being subject to deviations within a defined range of preset operating
parameters. The Common Technical Technology transfer from process development to pilot or
manufacturing is a challenge. The frustration level is high when a manufacturing process change
is made that invalidates previously validated studies. It is a two-way process, however. The
process developers must understand manufacturing capabilities. Validation documentation is
extensive and includes master validation plans, validation protocols, and validation reports. A
master validation plan is a useful essential and is now specified in EU as a requirement.
Validation protocols are also an essential basic. The protocol must state what will be done, how
it will be done, and what the outcome must be for the validation to be a success. Validation
cannot be just going back to a process step repeated three times and stating it is validated.
Validation is an ongoing process. It is not a one-time effort that can then be ignored. Most
validation is performed prospectively, i.e., prior to market approval. However, today there is
more acceptance of also using concurrent validation for some aspects. Certainly, data collected at
the manufacturing scale can be more relevant provided that in-process analysis is sufficiently
sensitive.
The development of a drug product is a lengthy process involving drug discovery, laboratory
testing, animal studies, clinical trials and regulatory registration. To further enhance the
effectiveness and safety of the drug product after approval, many regulatory agencies such as the
United States Food and Drug Administration (FDA) also require that the drug product be tested
for its identity, strength, quality, purity and stability before it can be released for use. For this
reason, pharmaceutical validation is important in spite of the problems that may be encountered.
In general, an entire process is validated and a particular object within that process is verified.
The regulations also set out an expectation that the different parts of the production process are
well defined and controlled, such that the results of that production will not substantially change
over time.
2. VALIDATION
Validation in the pharmaceutical industry is defined as the documented act of demonstrating that
a procedure, process, and activity will consistently lead to the expected results. Validation is an
essential procedure that demonstrates that a manufacturing process operating under defined
standard conditions is capable of consistently producing a product that meets the established
product specifications. It often includes the qualification of systems and equipment. It is a
requirement for Good Manufacturing Practices and other regulatory requirements. A wide
variety of procedures, processes, and activities need to be validated.
(http://en.wikipedia.org/wiki/Validation_(drug_manufacture))
Validation is an integral part of quality assurance, but the use of this term in connection with
manufacturing often gives rise to difficulties. As defined above, it involves the systematic study
of systems, facilities and processes aimed at determining whether they perform their intended
functions adequately and consistently as specified. A validated operation is one, which has been
demonstrated to provide a high degree of assurance that uniform batches will be produced that
meet the required specifications, and has there fore been formally approved.
Unlike many other requirements of GMP, validation in itself does not improve processes. It can
only confirm (or not, as the case may be) that the process has been properly developed and is
under control. Ideally, any development activity in the later stages should be finalized by a
validation phase. This includes, in particular, the manufacture of investigational products and the
scaling up of processes from pilot plant to production unit. In this event, GMP as manufacturing
practice may only be concerned with revalidation, e.g. when processes are transferred from
development to production, after modifications are introduced (in starting materials, equipment,
etc.) or when periodic revalidation are required at the pre registration stage (in the submission of,
or application for, marketing authorizations).
Good validation practice requires the close collaboration of departments such as those concerned
with development, production, engineering, quality assurance and control. This is most important
when processes go into routine full-scale production following pharmaceutical development and
pilot-plant operations.
(http://prismpharmatech.com/pdf/Validation.pdf)
2.1 History of validation
The concept of validation was first proposed by two Food and Drug Administration (FDA)
officials, Ted Byers and Bud Loftus, in the mid 1970’s in order to improve the quality of
pharmaceuticals (Agalloco 1995). It was proposed in direct response to several problems in the
sterility of large volume parenteral market. The first validation activities were focused on the
processes involved in making these products, but quickly spread to associated processes
including environmental control, media fill, equipment sanitization and purified water
production. (http://en.wikipedia.org/wiki/Validation_(drug_manufacture))
As validation is an integral part of quality assurance; it involves the systematic study of systems,
facilities and processes aimed at determining whether they perform their intended functions
adequately and consistently as specified. A validated process is one which has been
demonstrated to provide a high degree of assurance that uniform batches will be produced that
meet the required specifications and has therefore been formally approved. Validation in itself
does not improve processes but confirms that the processes have been properly developed and
are under control. Adequate validation is beneficial to the manufacturer in many ways:
1. It deepens the understanding of processes; decreases the risk of preventing problems and
thus assures the smooth running of the process.
4. A fully validated process may require less in-process controls and end- product testing.
• New equipment;
• Process and equipment which have been altered to suit changing priorities;
• Process where the end-product test is poor and an unreliable indicator of product quality.
When any new manufacturing formula or method of preparation is adopted, steps should be
taken to demonstrate its suitability for routine processing. The defined process should be shown
to yield a product consistent with the required quality. In this phase, the extent to which
deviations from chosen parameters can influence product quality should also be evaluated. When
certain processes or products have been validated during the development stage, it is not always
necessary to revalidate the whole process or product if similar equipment is used or similar
products have been produced, provided that the final product conforms to the in-process controls
and final product specification. There should be a clear distinction between in-process control
and validation. In production, tests are performed each time on a batch to batch basis using
specifications and methods devised during the development phase. The objective is to monitor
the process continuously. (http://www.tjpr.org/vol1%20no2/okhamafe12.pdf)
A validation master plan is a document that summaries the company’s overall philosophy,
intentions and approaches to be used for establishing performance adequacy. The Validation
Master Plan should be agreed upon by management.
Validation in general requires meticulous preparation and careful planning of the various steps in
the process. In addition, all work should be carried out in a structured way according to formally
authorized standard operating procedures. All observations must be documented and where
possible must be recorded as actual numerical results.
The validation master plan should provide an overview of the entire validation operation, its
organizational structure, its content and planning. The main elements of it being the
list/inventory of the items to be validated and the planning schedule. All validation activities
relating to critical technical operations, relevant to product and process controls within a firm
should be included in the validation master plan. It should comprise all prospective, concurrent
and retrospective validations as well as re validation.
The Validation Master Plan should be a summary document and should therefore be brief,
concise and clear. It should not repeat information documented elsewhere but should refer to
existing documents such as policy documents, SOP’s and validation protocols and reports
• Plant /process/product description: rational for inclusions or exclusions and extent of validation
• Specific process considerations that are critical and those requiring extra attention
• Documentation format
(http://www.hc-sc.gc.ca/dhp-mps/alt_formats/pdf/compli-conform/gmp-bpf/validation/GUI-
0029-eng.pdf)
3. PROCESS VALIDATION
Process validation is the means of ensuring and providing documentary evidence that processes
(within their specified design parameters) are capable of repeatedly and reliably producing a
finished product of the required quality. It would normally be expected that process validation be
completed prior to the release of the finished product for sale (prospective validation). Where
this is not possible, it may be necessary to validate processes during routine production
(concurrent validation). Processes, which have been in use for some time without any significant
changes, may also be validated according to an approved protocol (retrospective validation).
(http://www.tjpr.org/vol1%20no2/okhamafe12.pdf)
“Establishing 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” -1987 FDA Guideline
“The action of proving, in accordance with the principles of GMP, that any procedure, process,
equipment, material, activity or system actually leads to the expected results”-(European Union
Drug Regulatory Authorities, 1998)
“The means of ensuring and providing documentary evidence that processes (within their
specified design parameters) are capable of consistently producing a finished product of the
required quality”-(European Medicines Agency, 2001)
(http://www.bioprocessconsultants.com/PDFs/Kanarek.ProcessValidation2009.pdf)
Before process validation can be started, manufacturing equipment and control instruments as
well as the formulation must be qualified. The information on a pharmaceutical product should
be studied in detail and qualified at the development stage, i.e., before an application for
marketing authorization is submitted. This involves studies on the compatibility of active
ingredients and recipients, and of final drug product and packaging materials, stability studies,
etc. Other aspects of manufacture must be validated including critical services (water, air,
nitrogen, power supply, etc.) and supporting operations such as equipment cleaning and
sanitation of premises. Proper training and motivation of personnel are pre- requisites to
successful validation. (http://www.tjpr.org/vol1%20no2/okhamafe12.pdf).
The activities relating to validation studies may be classified into three stages:
This is the step where building and capturing of the process knowledge and understanding took
place. Early design of processes and experiments should be performed during this stage. It covers
all activities relating to product research and development, formulation, pilot batch studies,
scale-up studies, transfer of technology to commercial scale batches, establishing stability
conditions, storage and handling of in-process and finished dosage forms, equipment
qualification, installation qualification, master production documents, operational qualification,
process capability. Also this is the stage in which the establishment of a strategy for process
control is taking place using accumulation knowledge and understanding of the process.
This stage is confirmation that the process design is capable of reproducing the manufacturing
process. It confirms that all established limits of the Critical Process parameters are valid and
that satisfactory products can be produced even under “worst case” conditions. GMP compliant
procedures must be followed in this stage and successful completion of this stage is necessary
before commercial distribution of a product.
The Validation Maintenance Stage requires frequent review of all process related documents,
including validation audit reports to assure that there have been no changes, deviations, failures,
modifications to the production process, and that all SOPs have been followed, including change
control procedures. Before any batch is distributed for marketing, the manufacturer must have
full assurance of its performance. A successful validation program depends on the knowledge
and understanding and the approach to control manufacturing processes. These include the
source of variation, the limitation of the detection of the variation, and the attributes susceptible
of the variation.
It is the responsibility of the manufacturer to judge and provide evidence of a high degree of
assurance in its manufacturing processes. They are also responsible for maintaining the degree of
assurance accomplished, even if some minor changes occurred due to personnel, material and
process changes.
(http://www.sfda.gov.sa/NR/rdonlyres/E0A05984-1CCE-4168-87B9-
28D3A8545404/0/GuidelinesforProcessValidationofPharmaceuticalDosageForms_v21.pdf)
It is expected that during the development stage, the manufacturer of the product should gain
sufficient information about the behavior and the physical and chemical properties of the drug
substance, the composition of the product in terms of active ingredients and key excipients and
the manufacturing process to clearly define the critical steps in the manufacturing process.
Critical parameters of the product should be identified at an early stage; for example the
dissolution rate of an active substance and the effect of the presence, type and amount of
lubricant.
Information generated during the development stage should thus be used to identify and evaluate
the critical pharmaceutical process parameters which may need to be examined and possibly
controlled in order to ensure batch to batch reproducibility. In order to define these critical
parameters it may be necessary to challenge the process by making deliberate changes to
demonstrate the robustness of the process and define the limits of tolerance. Such parameters
will vary depending upon the nature of the product, the composition and the proposed method of
manufacture, as highlighted in the note for guidance “Development Pharmaceutics”. The choice
of the method of manufacture should be properly justified in the context of the development data
obtained
3.3.2 Relationship between method of manufacturing and process validation data
Having defined and justified a particular method of manufacture based on a consideration of the
physical and chemical properties of the active ingredient, the key excipients, the choice of
formulation and the impact of processing on the product quality and stability, the applicant
should progress to fully describe the manufacturing process.
Such a description should address also the need and value of in-process controls and the
manufacturer’s approach to process optimization. The evaluation of the process should provide
adequate proof of the feasibility of the process at the production scale thereby ensuring the
consistent quality of the product in line with the approved specification.
3.3.3 Relationship between Process Validation and the Specification of the Finished
Product
Data generated through process evaluation or validation can be used to justify why certain test
need not be conducted routinely on the finished product at release.
(http://www.ema.europa.eu/docs/en_GB/document_library/Scientific_guideline/2009/09/WC500
002913.pdf)
Process Validation and Quality Assurance (QA) have expanded to include not only technology
transfer but also some of the development activity; namely, Process Validation associated with
clinical supplies production. Another factor that has influenced the need to validate the
manufacturing process is the involvement of the contractor, whose site has become the primary
or alternate location for the sponsor to manufacture the clinical or commercial product. With this
expansion it was inevitable that organizations would formalize the master validation plan as a
building block of Total Quality Management. Furthermore, it is appropriate to include the
validation plan for each clinical production process in the master validation plan.
Quality Assurance is the activity of providing to all concerned the evidence needed to establish
confidence that the quality function is being performed adequately. The definition of process
validation is that it is the total activity, showing that the process will do what it is purported to
do. The relationship of Quality Assurance and Process Validation goes well beyond the
responsibility of any quality assurance function; nevertheless, it is fair to say that process
validation is a quality assurance tool because it establishes a quality standard for a specific
process.
Process validation verifies that the process will consistently produce the desired product each
time it is run. It must be remembered that process validation for the development process may
not contain as much supporting data as is collected for the process when the product’s New Drug
Application (NDA) is being reviewed. The development group must still view the validation
effort in a way that adds value to its work, however. The steps are as follows:
1. Define the process and determine which process steps are the critical ones. If the technologist
has progressed adequately from the checklist stage to the stage at which the process is known
and understood, these steps should be readily identified.
When the development function looks at the Process validation activity as a quality assurance
tool, it must view each process step very closely. The development plan must ensure that the
ability and limitations of the process design are known. This can come about only if sound
planning occurs at the beginning, which should include dissection of the process into discrete
parts and the ability to evaluate them.
2. Define which process variable will be used as the monitoring device of each process step.
3. Generate the data. During the development effort, the data generated while the process is
being qualified will determine what the specification limits will be for each test.
4. Statistically evaluate the data from the validation effort. Compare the data with the
specification limits listed in the protocol. Conformance to these limits is essential, because this
effort must also include the determination of whether failure signifies a missing link in the
scientists understands of the process. This exercise is especially important when the size of the
validation batch is significantly larger than the largest development batch made to date.
5. The validation function reviews the results of all the validation batches using the protocol as a
basis of comparison. In addition, the group will review the equipment qualification work and/or
its calibration program. This total effort will help to ensure the quality of the finished product.
3.4.2 Production
This department needs process validation for a number of reasons. First, the completed
validation program serves as the formal transfer of the process to the production function.
Through validation, it would be demonstrated that a controlled process was established. It
doesn’t guarantee that nothing will go wrong, but it will say what process was validated and it
will require that any change must be examined beforehand. In this way, it will require that the
organization formally evaluate whether or not a proposed change warrants a new development
and/or validation effort. This will also avoid the comment that the previous validated process is
no longer validated.
Process validation is also useful for the production function, because the data generated may be
used as a basis for SPC. Statistical process control is useful for collecting data, but there must be
useful limits to control the process variables by allowing standard equipment adjustments to
obtain quality product continuously. Validation data enable a company to develop a database to
do just that. Furthermore, when normal adjustments no longer control the process variables, the
validation data become the basis to judge whether there has been a statistical change in the
process. The rational process to such a finding would be a demonstrated need for process
improvement or a troubleshooting effort.
When production develops an operation plan, it will include quality standards that complement
the validation effort. These are as follows:
Quality assurance functions primarily to monitor the fact that the quality function is being
performed. Its role in Process Validation is readily associated with its main functions. For
example, it performs the tests that demonstrate the product’s content uniformity. It may also
perform the statistical evaluation of the test results to show that the process is reproducible.
Quality assurance initiates the action to dispose of nonconforming product. It implements the
inspection criteria and sets the specifications for product approval or rejection. It analyzes the
product complaints to learn how effective its test program has been in preventing rejectable
product from reaching the market place.
Quality assurance carries out the ongoing stability programs for each product at least once a year.
It performs the physical and chemical tests that are used as the basis for approval or rejection of
individual batches. In conjunction with setting specification limits as a basis for releasing or
rejecting product, it will carry out programs to determine whether or not the new information
indicates that a change in product or process has occurred. Finally, it performs the analytical tests
that are used to generate the validation data required by the protocol.
A written plan stating how validation will be conducted, including test parameters, product
characteristics, production and packaging equipment, and decision points on what constitutes
acceptable test results. This document should give details of critical steps of the manufacturing
process that should be measured, the allowable range of variability and the manner in which the
system will be tested.
The validation protocol provides a synopsis of what is hoped to be accomplished. The protocol
should list the selected process and control parameters, state the number of batches to be
included in the study, and specify how the data, once assembled, will be treated for relevance.
The date of approval by the validation team should also be noted.
In the case where a protocol is altered or modified after its approval, appropriate reasoning for
such a change must be documented.
The validation protocol should be numbered, signed and dated, and should contain as a minimum
the following information:
• A list of all equipment to be used; their normal and worst case operating parameters.
• Description of the processing steps: copy of the master documents for the product
• Validated test methods to be used in in-process testing and for the finished product.
• Format for presentation of results, documenting conclusions and for approval of study
results.
(http://www.sfda.gov.sa/NR/rdonlyres/E0A05984-1CCE-4168-87B9-
28D3A8545404/0/GuidelinesforProcessValidationofPharmaceuticalDosageForms_v21.pdf)
5. Revalidation
Analytical procedure validation is defined as the process of demonstrating that the analytical
procedure is suitable for its intended purpose, for example, identification, determination of
impurities, assay of active or other ingredients.( http://www.tga.gov.au/cm/startval.pdf)
The validation of an analytical procedure is the process of confirming that the analytical
procedure employed for a test of pharmaceutics is suitable for its intended use. In other word, the
validation of an analytical procedure requires us to demonstrate scientifically that risks in
decision by testing caused by errors from analytical steps are acceptably small. The performance
of an analytical procedure is established by various kinds of validation characteristics. The
validity of a proposed analytical procedure can be shown by demonstrating experimentally that
the validation characteristics of the analytical procedure satisfy the standards set up according to
the acceptable limits of testing.
(http://lib.njutcm.edu.cn/yaodian/jp/14data/Validation_of_Analytical_Pr.pdf)
The discussion of the validation of analytical procedures is directed to the four most common
types of analytical procedures:
• Identification tests;
(http://www.bioforum.org.il/Uploads/Editor/karen/q2_r1_step4.pdf)
A brief description of the types of tests considered in this document is provided below-
- Identification tests are intended to ensure the identity of an analyte in a sample. This is
normally achieved by comparison of a property of the sample (e.g., spectrum, chromatographic
behavior, chemical reactivity, etc) to that of a reference standard;
- Testing for impurities can be either a quantitative test or a limit test for the impurity in a
sample. Either test is intended to accurately reflect the purity characteristics of the sample.
Different validation characteristics are required for a quantitative test than for a limit test;
- Assay procedures are intended to measure the analyte present in a given sample. In the context
of this document, the assay represents a quantitative measurement of the major component(s) in
the drug substance. For the drug product, similar validation characteristics also apply when
assaying for the active or other selected component(s). The same validation characteristics may
also apply to assays associated with other analytical procedures (e.g., dissolution).
(http://www.fda.gov/downloads/Drugs/GuidanceComplianceRegulatoryInformation/Guidances/u
cm073381.pdf)
• Accuracy
The accuracy of an analytical procedure expresses the closeness of agreement between the value
which is accepted either as a conventional true value or an accepted reference value and the
value found. (http://www.bioforum.org.il/Uploads/Editor/karen/q2_r1_step4.pdf)
• Precision
- Repeatability
- Reproducibility.
Repeatability expresses the precision under the same operating conditions over a short interval
of time. Repeatability is also termed intra-assay precision.
Intermediate precision expresses variations within laboratories, such as different days, different
analysts, different equipment, and so forth.
(http://www.chem.agilent.com/Library/primers/Public/5990-5140EN.pdf)
• Specificity
Specificity is the ability to assess unequivocally the analyte in the presence of components which
may be expected to be present. Typically these might include impurities, degradants, matrix, etc.
(http://www.bioforum.org.il/Uploads/Editor/karen/q2_r1_step4.pdf)
• Detection limit
The detection limit of an individual analytical procedure is the lowest amount of analyte in a
sample which can be detected but not necessarily quantitated as an exact value.
• Quantitation limit
The quantitation limit of an individual analytical procedure is the lowest amount of analyte in a
sample which can be quantitatively determined with suitable precision and accuracy. The
quantitation limit is a parameter of quantitative assays for low levels of compounds in sample
matrices, and is used particularly for the determination of impurities and/or degradation products.
• Linearity
The linearity of an analytical procedure is its ability (within a given range) to obtain test results
which are directly proportional to the concentration (amount) of analyte in the sample.
• Range
The range of an analytical procedure is the interval between the upper and lower concentration
(amounts) of analyte in the sample (including these concentrations) for which it has been
demonstrated that the analytical procedure has a suitable level of precision, accuracy and
linearity.
• Robustness
Prospective Validation is conducted prior to the distribution of either a new product or a product
made under a modified production process, where the modifications are significant and may
affect the product’s characteristics. It is a pre-planned scientific approach and includes the initial
stages of formulation development, process development, setting of process specifications,
developing in-process tests, sampling plans, designing of batch records, defining raw material
specifications, completion of pilot runs, transfer of technology from scale-up batches to
commercial size batches, listing major process equipment and environmental controls.
(http://www.hc-sc.gc.ca/dhp-mps/alt_formats/pdf/compli-conform/gmp-bpf/validation/GUI-
0029-eng.pdf)
3.6.2.1 Organization
Product development usually begins when an active chemical entity has been shown to possess
the necessary attributes for a commercial product. The product development activities for the
active chemical entity, formulation, and process form the foundation upon which the subsequent
validation data are built. Generally, product development activities can be subdivided into
formulation and process development, along with scale-up development.
A. Formulation Development
Formulation development provides the basic information on the active chemical, the formula,
and the impact of raw materials or excipients on the product. Typical supportive data generated
during these activities may include the following:
6. Optimum formulation
Formulation development should not be considered complete until all those factors that could
significantly alter the formulation have been studied. Subsequent minor changes to the
formulation, however, may be acceptable, provided they are thoroughly tested and are shown to
have no adverse effect on product.
B. Process Development
The process development activities typically begin after the formulation has been developed,
they may also occur simultaneously. The majority of the process development activities occur
either in the pilot plant or in the proposed manufacturing plant. The process development
program should meet the following objectives:
a. Product specifications
b. Economic constraints
2. Identify the key process parameters that affect the product attributes
1. Design
As development activities progress and the process become more clearly defined, there must be a
parallel assessment of the capability to manufacture the product. The scope and timing of the
development of manufacturing capability will be dependent on the process and the need to utilize
or modify existing facilities or establish new ones.
The development of the final full-scale production process proceeds through the following steps:
2. Qualification trials
The transition from a successful pilot-scale process or research scale to a full scale process
requires careful planning and implementation. Although a large amount of information has been
gathered during the development of the process (i.e., process characterization and process
verification studies), it does not necessarily follow that the full-scale process can be completely
predicted. Many scale-up parameters are nonlinear. In fact, scale-up factors can be quite complex
and difficult to predict, based only on experience with smaller-scale equipment. For some
processes, the transition from pilot scale or research scale to full scale is relatively easy and
orderly. For others the transition is less predictable.
Qualification trials
Once the scale-up studies have been completed, it may be necessary to manufacture one or more
batches at full scale to confirm that the entire manufacturing process, comprising several
different unit operations, can be carried out smoothly. This may occur prior to or after the
regulatory submission, depending on the strategy used in filing.
Process validation runs
After the qualification trials have been completed, the protocol for the full-scale process
validation runs can be written. Current industry standard for the validation batches is to attempt
to manufacture them at target values for both process parameters and specifications. The
validation protocol is usually the joint effort of the following groups:
• Manufacturing
• Engineering
A process where current production batches are used to monitor processing parameters. It gives
assurance of the present batch being studied, and offers limited assurance regarding consistency
of quality from batch to batch.
Concurrent validation is carried out during normal production. This method is effective only if
the development stage has resulted in a proper understanding of the fundamentals of the process.
The first three production-scale batches must be monitored as comprehensively as possible. (This
careful monitoring of the first three production batches is sometimes regarded as prospective
validation.) The nature and specifications of subsequent in-process and final tests are based on
the evaluation of the results of such monitoring. Concurrent validation together with a trend
analysis including stability should be carried out to an appropriate extent throughout the life of
the product. (http://prismpharmatech.com/pdf/Validation.pdf)
• The product is a different strength of a previously validated product with the same ratio
of active/inactive ingredients
• The number of lots evaluated under the Retrospective Validation were not sufficient to
obtain a high degree of assurance demonstrating that the process is fully under control
• Process with low production volume per batch ( e.g. radiopharmaceuticals, anti-cancer)
• Process of manufacturing urgently needed drugs due to shortage (or absence) of supply.
It is important in these cases however, that the systems and equipment to be used have been fully
validated previously. The justification for conducting concurrent validation must be documented
and the protocol must be approved by the Validation Team. A report should be prepared and
approved prior to the sale of each batch and a final report should be prepared and approved after
the completion of all concurrent batches. It is generally considered acceptable that a minimum of
three consecutive batches within the finally agreed parameters, giving the product the desired
quality would constitute a proper validation of the process.
(http://www.sfda.gov.sa/NR/rdonlyres/E0A05984-1CCE-4168-87B9-
28D3A8545404/0/GuidelinesforProcessValidationofPharmaceuticalDosageForms_v21.pdf)
Retrospective validation is used when historical data is available for existing manufacturing
processes. Types of useful data include design drawings and specifications, operating procedures
and work instructions, manufacturing instructions, inspection reports, production logs,
production test data, material review reports, service records, customer complaints, and audit
reports. Retrospective validation may not be feasible if accumulated data is incomplete or
inadequate.
(http://www.clinivation.com/docs/procedures/mfgeng/ProcessValidation.doc?
PHPSESSID=575b6d4bdc5d472e955015b5e577e62b)
Retrospective validation is obviously not a quality assurance measure in itself, and should never
be applied to new processes or products. It may be considered in special circumstances only, e.g.
when validation requirements are first introduced in a company. Retrospective validation may
then be useful in establishing the priorities for the validation program. If the results of a
retrospective validation are positive, this indicates that the process is not in need of immediate
attention and may be individual accordance with the normal schedule. For tablets, which have
been compressed under individual pressure sensitive cells, and with qualified equipment,
retrospective validation is the most comprehensive test of the overall manufacturing process of
this dosage form. On the other hand, it should not be applied in the manufacture of sterile
products. (http://prismpharmatech.com/pdf/Validation.pdf)
For the purpose of retrospective validation studies, it is considered acceptable that data from a
minimum of ten consecutive batches produced be utilized. When less than ten batches are
available, it is considered that the data are not sufficient to demonstrate retrospectively that the
process is fully under control. In such cases the study should be supplemented with data
generated with concurrent or prospective validation.
• Batch size/strength/manufacturer/year/period.
(http://www.sfda.gov.sa/NR/rdonlyres/E0A05984-1CCE-4168-87B9-
28D3A8545404/0/GuidelinesforProcessValidationofPharmaceuticalDosageForms_v21.pdf)
3.6.5 Revalidation
Revalidation is needed to ensure that changes in the process and/or in the process environment,
whether intentional or unintentional, do not adversely affect process characteristics and product
quality.
• Changes in the starting material(s). Changes in the physical properties, such as density,
viscosity, particle size distribution, and crystal type and modification, of the active
ingredients or excipients may affect the mechanical properties of the material; as a
consequence, they may adversely affect the process or the product.
• Changes in the packaging material, e.g. replacing plastics by glass, may require changes
in the packaging procedure and therefore affect product stability.
• Changes in the process, e.g. changes in mixing time, drying temperature and cooling
regime, may affect subsequent process steps and product quality.
• Changes in equipment, including measuring instruments, may affect both the process and
the product; repair and maintenance work, such as the replacement of major equipment
components, may affect the process.
• Changes in the production area and support system, e.g. the rearrangement of
manufacturing areas and/or support systems, may result in changes in the process. The
repair and maintenance of support systems, such as ventilation, may change the
environmental conditions and, as a consequence, revalidation/requalification may be
necessary, mainly in the manufacture of sterile products.
3.6.5.2 Periodic revalidation. It is well known that process changes may occur gradually even if
experienced operators work correctly according to established methods. Similarly, equipment
wear may also cause gradual changes. Consequently, revalidation at scheduled times is advisable
even if no changes have been deliberately made.
The decision to introduce periodic revalidation should be based essentially on a review of
historical data, i.e. data generated during in-process and finished product testing after the latest
validation, aimed at verifying that the process is under control. During the review of such
historical data, any trend in the data collected should be evaluated.
In some processes, such as sterilization, additional process testing is required to complement the
historical data. The degree of testing required will be apparent from the original validation.
Additionally, the following points should be checked at the time of a scheduled revalidation:
• Have any changes in master formula and methods, batch size, etc., occurred? If so, has
their impact on the product been assessed?
• Have calibrations been made in accordance with the established program and time
schedule?
• Has preventive maintenance been performed in accordance with the program and time
schedule?
(http://pharmaceuticalvalidation.blogspot.com/2008/01/types-of-process-validation.html)
Cleaning Validation is the documented act of demonstrating that cleaning procedures for the
equipment used in fabricating/packaging will reduce to an acceptable level all residues
(products/cleaning agents) and to demonstrate that routine cleaning and storage of equipment
does not allow microbial proliferation.
(http://www.hc-sc.gc.ca/dhp-mps/alt_formats/pdf/compli-conform/gmp-bpf/validation/GUI-
0029-eng.pdf)
Pharmaceutical products and active pharmaceutical ingredients (APIs) can be contaminated by
other pharmaceutical products or APIs, by cleaning agents, by micro-organisms or by other
material (e.g. air-borne particles, dust, lubricants, raw materials, intermediates, auxiliaries). In
many cases, the same equipment may be used for processing different products. To avoid
contamination of the following pharmaceutical product, adequate cleaning procedures are
essential.
Cleaning procedures must strictly follow carefully established and validated methods of
execution. This applies equally to the manufacture of pharmaceutical products and active
pharmaceutical ingredients (APIs). In any case, manufacturing processes have to be designed and
carried out in a way that contamination is reduced to an acceptable level.
Objective of the Cleaning Validation is the confirmation of a reliable cleaning procedure so that
the analytical monitoring may be omitted or reduced to a minimum in the routine phase.
(http://www.cptu.com.cn/bbs/attachment.aspx?attachmentid=2540)
3.6.6.1 Sampling
In developing the sampling plan for a validation study, it makes scientific sense to incorporate an
understanding of the acceptance criteria and the limitations of the sampling method relative to
the surface to be sampled.
• Swab method
• Rinse method
Swab:
• Swab sampling does not cover the entire equipment surface area therefore sites must be
chosen with care. It is important that, as a minimum, the swab sites represents worst case
locations on the equipment and that the result is then extrapolated to account for the total
product contact surface area. This calculation makes it possible to make a worst case
determination of potential carryover into subsequent product.
• Due to the nature of this method which employs physical forces as well as chemical
forces it may be necessary to perform sampling technique evaluation.
• It is necessary to ensure that extractable of the swab do not interfere with the sampling
method.
• Using this technique it is possible to sample insoluble residues due to the physical action
associated it.
Rinse:
• This method is not as direct as swabbing but will cover the entire surface area (and parts
inaccessible to swabs)
• It is important to ensure chosen solvent has appropriate recovery for residues being
quantified
(http://apic.cefic.org/pub/4CleaningVal9909.pdf)
A Cleaning Validation Protocol is required laying down the procedure on how the cleaning
process will be validated. It should include the following:
• Cleaning procedures to be used for each product, each manufacturing system or each
piece of equipment,
• Sampling procedures, including the rationale for why a certain sampling method is used,
• Analytical methods including the limit of detection and the limit of quantitation of those
methods,
• The acceptance criteria, including the rationale for setting the specific limits,
• Other products, processes, and equipment for which the planned validation is valid
according to a “bracketing” concept,
The Cleaning Validation Protocol should be formally approved by the Plant Management, to
ensure that aspects relating to the work defined in the protocol, for example personnel resources,
are known and accepted by the management. Quality Assurance should be involved in the
approval of protocols and reports.
(http://www.cptu.com.cn/bbs/attachment.aspx?attachmentid=2540)
Clearly defined procedure is required in order to control any changes in the production
processes. These procedures should control all the planned changes and ensure the presence of
sufficient supporting data that show that modified process will result in a product of the desired
quality. Significant changes to process (e.g. mixing time, drying temperature, etc.), using new
equipments with different operating parameters.
(http://www.sfda.gov.sa/NR/rdonlyres/E0A05984-1CCE-4168-87B9-
28D3A8545404/0/GuidelinesforProcessValidationofPharmaceuticalDosageForms_v21.pdf)
Written procedures should be in place to describe the actions to be taken if a change is proposed
to a product component, process equipment, process environment, processing site, method of
production or testing or any other change that may affect product quality or support system
operations.
All changes must be formally requested, documented and accepted by the Validation Team. The
likely impact/risk of the change on the product must be assessed and the need for the extent of
re-validation should be determined.
Commitment of the company to control all changes to premises, supporting utilities, systems,
materials, equipment and processes used in the fabrication/packaging of pharmaceutical dosage
forms is essential to ensure a continued validation status of the systems concerned.
The change control system should ensure that all notified or requested changes are satisfactorily
investigated, documented and authorized. Products made by processes subjected to changes
should not be released for sale without full awareness and consideration of the change by the
Validation Team. The Team should decide if a re-validation must be conducted prior to
implementing the proposed change.
(http://www.hc-sc.gc.ca/dhp-mps/alt_formats/pdf/compli-conform/gmp-bpf/validation/GUI-
0029-eng.pdf)
4. CONCLUSION
It is necessary, before approval of a new drug, that an accurate and reliable assessment for its
effectiveness and safety for the intended indication and target patient population is demonstrated.
Pharmaceutical validation which includes assay validation, cleaning validation, equipment
validation as well as the overall process validation is crucial in stability analysis, animal studies
and early phases of clinical development such as bioavailability/bioequivalence studies. After the
drug is approved, pharmaceutical validation and process control are necessary to ensure that the
drug product will meet/set pharmaceutical standards for identity, strength, quality, purity,
stability, evaluation safety and efficacy.
In general, pharmaceutical validation and process control provide a certain assurance of batch
uniformity and integrity of the product manufactured. Process validation is a major requirement
of cGMP regulation for finished pharmaceutical products. It is a key element in assuring that the
quality goals are met. Successfully validating a process may reduce the dependence upon
intensive in process and finished product testing.
Finally, it can be concluded that Process validation is a key element in the quality assurance of
pharmaceutical product as the end product testing is not sufficient to assure quality of finished
product.