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Government regulation in pharmaceutical validation
1. GOVERNMENT
REGULATIONS IN
PHARMACEUTICAL
VALIDATION
Guided By:
Dr. Kamlesh Wadher
(M.Pharm, PH,d)
Hod of Pharmaceutis
Dept.
Presented By:
Vaishnavi S. Raut
(M.Pharm 1st Year)
Pharmaceutics Dept.
SMT. KISHORITAI BHOYAR COLLEGE OF PHARMACY, NEW KAMPTEE
DIST- NAGPUR. 441002
2. CONTENT
ďź DEFINATION AND IMPORTANCE
ďź HISTORY
ďź REGULATION UNDER US FDA
ďź REGULATION UNDER cGMP
ďź REGULATION UNDER WHO
ďź REGULATION UNDER EU
ďź REGULATION UNDER PIC/S
ďź VALIDATION MASTER PLAN
ďź VALIDATION REPORT
ďź CONCLUSION
ďź REFERENCE
3. DEFINITION
ďValidation - Process validation is the establishment of
documented evidence, which provide a high degree of assurance
that a specific process (manufacturing of pharmaceutical dosage
form) will consistently produce a product meeting its
predetermined specifications.
4. IMPORTANCE OF
VALIDATION
ď Quality assurance
ď Cost reduction
ď Customer satisfaction
ď Product liability
ďFewer product recall
ď Fewer batch failures
ď Decreases risk of regulatory non compliance
ďSmooth running of process
ď Less in process control and end product testing
5. WHAT IS REGULATION ?
⢠A regulation is a binding instruction issued by an agency (in our case, the
FDA) that tells you how to interpret and comply with law.
⢠Regulations are MUST FOLLOWS that is , if you fail to follow a regulation,
and you have an inspection, the FDA inspector must write up your failure on
483; failures to follow regulation usually end up in the âissued warning
letterâ section of the FDA Web site, not a good place to be.
⢠The most important regulations applying to validation are good
manufacturing practices(GMP), good clinical practices (GCPs) and good
laboratory practices (GLP) .
⢠The best âknown quality standards are the ISO 9000 series, which provide
generic standards for development, manufacturing and service. The most
frequently used quality and accreditation standard in chemical testing
laboratories is the ISO17025 std.
6. HISTORICAL BACKGROUND FOR
THE REGULATORY BASIS
⢠The emphasis on validation began in the late 1970s, the requirement has
been set at 1963 as cGMP regulations for finished pharmaceuticals.
⢠Validation is an integral part of Quality Assurance & its meaning is âAction of
providing an evidenceâ.
⢠Validation is necessarily include process qualification (qualification of raw
materials, equipment, system) under the section 21 CFR 211.100 which
states:
âThere shall be written procedures for production
and process control designed to assure that the drug products have the
identity, strength, quality, and purityâ.
7. HISTORY
ď§ The Kefauver-Harris Amendments to the FD&C Act were approved
in1962 with Section 501(a)(2)(B) as an amendment.
ď§ The result of The amendments Provided an additional powerful regulatory
tool to FDA to stop particular manufacturing process when the drug
product is deemed to adulteration.
ď§ The Drug Product Quality Assurance Program of the 1960s and 1970s
involved first conducting a massive sampling and testing program of
finished batches.
ď§ The investigation of clinical failures of several products(including Digoxin,
Digitoxin, Prednisolone, and Prednisone) by FDA found significant content
uniformity problems that were the result of poorly controlled
manufacturing processes
8. REGULATORY BASIS
ďśThe regulatory basis validation program of process validation is embodied
within the regulations & guidelines provided by cGMP & FDA.
ďśThe ultimate legal authority is Sec501(a)(2)(B) by the FD&C Act, which
states âDrug is deemed to be adulterated due to the methods/ facilities
used for the manufacturing, processing, packing/holding fails to
administer in conformity â cGMPâ
ďśValidation-Process validation is not just an FDA or U.S. requirement.
Similar requirements included in the World Health Organization (WHO),
the Pharmaceutical Inspection Co-operation Scheme (PIC/S), and the
European Union(EU).
9. REGULATION FOR
VALIDATION UNDER USFDA
ď§ Section211.100(a): Written procedures/deviations.
âThere shall be written procedures for production and process control designed to assure that
the drug products have the identity, strength, quality, and purity.â
ď§ Section 211.110: Sampling and testing of in-process materials and drug products
"....control procedures shall be established to monitor the output and Validate the performance
of those manufacturing processes that may be responsible for causing variability in the
characteristics of in-process material and the drug productâ
ď§ 21CFR211.133: Control of Microbiological Contamination
" Appropriate written procedures, designed to prevent microbiological contamination of drug
products purporting to be sterile, shall be established and followed. Such procedures shall
include Validation of any sterilization process.â
ď§ FDA must inspect every drug manufacturing establishment at least once every 2 years .
10. REGULATION FOR VALIDATION
UNDER CGMP
⢠Owing to the dynamic nature of the GMPs, In the year 1976, the term cGMP came
into existence. The next revision of the cGMP took place in 1978, and these are in
effect at present.
⢠In fact , the word âcurrentâ in reference to suggest that they are dynamic and the
regulatory agency constantly updates and maintains them in relation to the
current state of the art and science of drug manufacturing practice in the revision
.
⢠Regulation defined the âGMP as a system for ensuring that product are
consistently produced and controlled according to quality standard. It is
designed to minimize the risk involved in any pharmaceutical production that
cannot be eliminated through testing the final product.â
⢠The first cGMP regulations, based largely on the Pharmaceutical Manufacturers
Associationâs-manufacturing control guidelines .
⢠the Medicines Act (1968) covers most aspects of cGMP in what is commonly
referred to as "The Orange Guide" Validation under document of cGMP covers
procedure, process qualification, equipment,& facilities.
11. ⢠Validation under document of cGMP covers procedure, process
qualification, equipment and facilities.
⢠The current regulations are covered in Code of Federal Regulations(CFR)
211.68 :validation of automated process.
211.84(d)(2): validation of supplierâs test results for components.
211.84(d)(3): validation of supplierâs test results for container and
closures.
211.110(a) : validation of manufacturing process to ensure content
uniformity& integrity.
211.1113(b): validation of sterilization process.
211.165 : validation of analytical methods. By June 2010, the same
GLP/GMP Validation requirements will apply to all manufacturers of dietary
supplements.
12. PLANS OF FDA CGMP
ďźThe FDA plans to oversee 591 national GMP inspections in 2014 and 2015,
reduced from 967 performed last year.
ďź Consequently the agency plans to perform 30 percent more foreign GMP
inspections, increasing last yearâs total of 604 to a new grand total of 843
inspections.
ďź Companies will now be chosen for inspection using the agencyâs risk-based
inspection model that equates inspection periodicity to company quality
practices and procedures.
ďź This risk based model develop specifically for FDA GMP PLANS use, takes
into account risk factors; such as, Class I recalls, adverse events, as well as
compliance history as it assigns an appropriate inspection cycle.
13. VALIDATION REQUIREMENT
FOR WHO
ď WHO (World Health Organization) cGMP Guidelines state Validation studies
are an essential part of current good manufacturing practice (cGMP) and
should be conducted in accordance with predefined protocols.
ď WHO validation definition:
âThe documented act of proving any procedure, process, equipment,
material, activity or system which actually leads to the expected results.â
ď DQ: Design Qualification IQ: Installation Qualification
ď OQ : Operational qualification. PQ: Performance qualification
14. ďą DQ: The compliance of the basic design (location plan) with the user
requirements & regulatory requirements should be submitted & documented.
ďą IQ: Documentary evidence to prove that the premises & equipment have
been built & installed in compliance with their specifications.
ďąIQ include:
1.Preventive maintenance.
2 .Equipment info.
3. Calibration.
4.Verification of the equipment.
ďą OQ: A series of tests to measure the performance capability of equipment.
The OQ for HPLC system is the operation of pump, injector & detector will be
tested at this stage.
ďą PQ: Process to verify that the system is repeatable & capable for consistently
producing a quality product.
15. VALIDATION REQUIREMENT
FOR EU
⢠The European Union requirements for validation is an extract from ICH Q8, Q9 and
Q10 documented guidelines and helps to study continuous process verification
⢠EU Validation Definition:
â Documented evidence that the process, operated within
established parameters, can perform effectively and reproducibly, To produce a
medicinal product meeting its predetermined specifications and quality attributes.â
⢠Strategies of validation under EU includes:
1) Traditional process verification
2) Continuous process validation.(CPV)
3) Critical process parameter.(CPP)
4) Critical quality attributes.(CQA)
16. 1. Traditional process verification : process validation should focus on the
control strategy, which primarily includes critical process parameters and
other relevant studies demonstrating that the process is capable of
delivering the desired product quality.
2. Continuous process validation(CPV): an alternative approach to process
validation in which manufacturing process performance is continuously
monitored & evaluated.
3. Critical process parameter(CPP): a process parameter whose variability
has an impact on a critical quality attribute and therefore should be
controlled to ensure the process produce the desired quality.
4. Critical quality attributes.(CQA): a physical ,chemical, biological or
microbiological property should be within an appropriate limit, range to
ensure product quality.
17. VALIDATION REQUIREMENT
UNDER PIC/S
ďAccording the EU Guidelines to Good Manufacturing Practice for
Medicinal Products in Annex 15 the principles of qualification &
validation of the PIC/S is given under document PIC/S PI 006-3:
â Doc states: GMP for medicinal products Recommendations on
Validation Master Plan Installation and Operational Qualification(
Non-Sterile Process Validation Cleaning Validation) can assist with the
interpretation and the implementation.â
ďThis document applies primarily to inspectorates of the PIC/S
member for whom it is intended as instruction for preparing an
inspection, and as an advanced training aid for
qualification/validation .
19. VALIDATION MASTER PLAN
⢠The complete overview of validation operation, organization structure,
content &planning in the form of a document is the VMP.
⢠VMP should contain following data:
A. Validation policy of company, location & schedule
B. List of product, processes & system to be validated.
C. Installation & qualification for new equipment.
D. Key acceptance criteria.
E. Documentation format used for protocols &report.
F. Time planning & scheduling of project.
20. ď§ The Validation Master Plan is a top layer document and should not go
into specific detail; but present an overall picture of the company facility,
organisation and capability.
ď§ It must give a clear and concise overview, to a reviewer, of how the
company has integrated all the applicable cGMP requirements into every
aspect of its operations.
ď§ It must define validation activities and allot responsibilities for
authoring, reviewing, approving, and executing validation
documentation and tasks.
21. VALIDATION REPORT
ď The validation report should be approved prior to product distribution and
kept permanently on file in quality assurance.
ď The validation report should have a conclusion that explains the
manufacturing specialistâs (preparerâs) statement and opinion.
ďThe validation report should contain the approved validation protocol,
tabulated or graphical results, process monitoring (forms), and all analytical
results of the validation batches.
22. CONCLUSION
ď Regulatory authorities working on strategies to reduce the cost of
process validation and incorporate validation consideration during
product design and development.
ď New technologies under development for 100% analysis of drug
products and other innovations in pharmaceutical industry may also have
a significant effect on Validation & basic regulatory authority's
acceptance.
ď The future of process validation is also of great interest, especially with
the worldwide expansion of pharmaceutical manufacturing & for
harmonizing in international standards and requirements.
23. REFERENCES
⢠Pharmaceutical Process Validation by R. Berry & Robert A. Nash.
⢠P. P. Sharma, Validation in Pharmaceutical Industry, Vandana
Publication Pvt. Ltd. Dehli.
⢠www.fda.gov/cder/guidance/pv.htm (US FDA).
⢠http://www.fda.gov/iceci/enforcementactions/warning letters/2013 ďľ
www.emea.eu.int/ (EU Audit Agency). ďľ http://www.validation-
online.net/ 35