Professional Documents
Culture Documents
Qualification Benchmarking
Educational Track #1
Agenda
Part 1
(8:30 10:00)
Wrap-up
(10:00 10:30)
My Background in Subject
Official trainer for ISPE Baseline
Commissioning and Qualification
Guide
Member of team that wrote ASTM
E2500
Terminology
Qualification practices
Focusing the effort
Roles and responsibilities
Managing changes during the project
Terminology
C&Q Baseline guide
Commissioning
Qualification
ASTM E2500
Verification
Qualification Practices
C&Q Baseline Guide
To meet the demands of the regulators
ASTM E2500
Not mentioned
V-model
ASTM E2500
Risk assessment -> critical aspects
ASTM E2500
Quality involved in process requirements, risk
assessments, critical aspects, and acceptance and
release
Subject matter experts used throughout
Managing Change
C&Q Baseline Guide
QA pre-approved change control
implemented at start of IQ/OQ
ASTM E2500
QA pre-approved change control
implemented at start of manufacture of
product for distribution
Common Elements
Steve Connelly
Overview
Where Abbott Is Today
C&Q Approach
Commissioning & Qualification Activities
How We Manage Cost
Lessons Learned
START
User
Requirements
Direct
Impact
Systems
VCR Submitted
w/Assessment
Report and
Rationale
Functional Design
Evaluate Risk/
Impact
Assessment
Does system
directly impact
product quality?
Yes
No
Science &
Quality Risk
Management
Qualification
Process
Flow
Design
Qualification
Does system
support a direct
impact system?
No
Impact
Systems
Commissioning
Plan
Indirect
Impact
Systems
Yes
VCR Submitted
w/Assessment
Report and
Rationale
No
VCR Submitted
w/Assessment
Report and
Rationale
Commissioning
Plan
Pre-Qualification
Engineering tests /
FAT as applicable
Engineering tests /
FAT as applicable
Process
Complete
VCR Closed
Yes
Installation
Qualification
No
System have
operational
functions?
Yes
Operational
Qualification
Support of
CPPs tested in
PV?
No
Performance
Qualification
Maintenance
Engineering change management
Training to aid site support (implementation)
Commissioning
When supporting Qualification, Commissioning must
include or address:
Engineering Change Management (ECM)
After point commissioning data intended to support
Qualification
Testing
Methods described in sufficient detail for repeatability
Documentation confirms critical elements met criteria
Acceptance criteria documented prior to execution
Criteria based on User Requirements
Documentation of observed results
Commissioning & Qualification (C&Q) Plans typically
contain run rules for project
Qualification Equipment
User requirements
Product and Process User Requirement (PURS)
General User Requirements (GURS)
Qualification
When approved, commissioning reports complete the
IQ/OQ phase of Qualification with no additional protocol
testing
Holistic Approach
Integrated Qualification document (IOQ for
equipment/controls; as applicable)
Qualification Facilities
Qualification HVAC
Categorization
Qualification Utilities
ENGINEERING
FEP 1-3
User Requirements
Functional Specification (Draft)
Preliminary Design
Detailed Design
Construction
Loop Tuning
Equipment Installation/Alignment
COMMISSIONING
Risk Assessment
Failure Mode Effect Analysis
I/O checkout
Calibration
Functional Specification (Revisions)
Factory Acceptance Testing
Startup
Trouble Shooting
Sequence Testing
As-Builts (Non Qualified Systems)
QUALIFICATION (CERTIFICATION)
Validation Plan
Design Qualification
Equipment Installation Qualification
Equipment Operational Qualification
Computer Hardware Installation Qualification
Computer Software Installation Qualification
Controller Modification Qualification
HVAC Installation/Operational Qualification
Utility Installation Qualification
Process Qualification
Validated Drawings
Samples/Testing
Cleaning/Passivation
Inspections
Lessons Learned
Risk-Based C&Q is an iterative process (one
tiny
step at a time)
Application:
Site readiness tools - identifying opportunities for closing gaps
Lessons Learned
Listen, Speak, Deliver. Communication is key.
Quality may wonder:
What if engineering doesnt do its job?;ensure compliance
Engineering may wonder:
Quality = police & spell checkers; right the first tyme
Application:
Regular/frequent communication with VRB & project team
Lessons Learned
Sustainable Paradigm Shift
Sites: Implementation, accountability & ownership a must for
sustainability
Resources: People, time & money, site retaining technical
knowledge
Application:
Training & support implementation as applicable
Thank you!
Questions will be addressed during
the Panel Q&A session (after break)
Profile
Approve
CQMP
System
Classification
DQ/DR
Component
Classification
Planning
Design
Construction
QA
Requirements
Initial Cals
Procurement
Loops
Construction/
Installation
Simulation/
Offline Testing
Commissioning
Package
Project
Commissioning
IQ OQ PQ
Qualification
Owner
IV
FT
SAT
FAT Startup
Approve Systemlevel Plans
RV
Validation
Operations/
Maintenance
C&Q Metrics
Schedule Metrics
Cost Metrics
Discrepancy Metrics
25%
20%
10%
10%
5%
5%
No C&Q prog
1998- 2001
3% GOAL
Average:
Commissioning - Subcategory
FAT development
FAT execution
Receipt Verification development
Receipt Verification execution
Installation Verification development
Installation Verification execution
SAT development
SAT execution
Construction turnover packages
Qualification - Subcategory
IQ development
IQ execution
OQ development
OQ execution
PQ development
PQ execution
Administration - Subcategory
Training
Project management
C&Q resource travel
Administrative assistance
Audits
CSV support
Procedures 2%
OQ 2%
IQ 2%
CCs 2%
Training
1%
Impact Assessment
SAT
RI 1%
FAT
1%
1%
1%
Doc Revs 1%
Scheduling 0%
Doc mgmt 12%
DQ/EDR 3%
Project mgmt 11%
URs 3%
CSV Support 3%
FT 11%
Construction QA 4%
IV 7%
Planning 5%
SU 9%
Travel 10%
RV 10%
# of Discrepancies
700
600
500
400
300
200
100
0
RV
SIM FAT
IV
SU
SAT
IL
IC
FT
CP
IQ
OQ
C&Q Activities
PQ
CQP
US
Pr
ot Aut
oc
om
ol
De atio
ve n/S
lo
pm oftw
M
ar
en
iss
e
t
Er
in
g/
r
M
In
ec ors
co
I
rre nco han
ic
ct
r
Do rec al
cu t D
a
m
en ta
Tr
ac tatio
kin
n
g
To
Ta ol
M
gg
od
Pr
e
l N ing
ot
oc
De
u
ol
cis mb
E
er
i
M
iss xec on T
ut
in
oo
io
g
M nE l
od
rr
Un el N ors
u
av
a i mb
la
bl er
e
Pr
da
oc
Sy
ed
Vo ta
st
em
ur
id
a
l
Ch ed
M
/P
at
er lan ang
ial
D
e
of evi s
Co ati
on
n
M stru s
isc
c
el tion
la
ne
ou
De s
sig
n
# of Discrepancies
800
700
600
500
400
300
200
100
Accepted
Corrective Action
GDP SOP
Change Management SOP
Transfer of Care, Custody and Control SOP
Discrepancy Management Best Practice
(last 2 years)
(cont.)
Vendor risk
Technology risk
Automation strategy
Questions?
Q&A
Chris Beltz
Senior Manager/Team Leader
Pfizer Quality Operations
Kalamazoo, MI
Agenda
Basis of C&Q Practices
C&Q Program Management
Approach
C&Q Cost Management
Key Lessons
Agenda
Part 1
(8:30 10:00)
Wrap-up
(10:00 10:30)
Thank You!!