new annex 15 - gmp consultants, validation · eu gmp guide annex 15 ‘qualification &...

18
New Annex 15 Updated Requirements & Approach to Validation Presented by Ashley Isbel 10 th August 2015

Upload: others

Post on 22-Aug-2020

33 views

Category:

Documents


0 download

TRANSCRIPT

Page 1: New Annex 15 - GMP Consultants, Validation · EU GMP Guide Annex 15 ‘Qualification & Validation’ 2001 . Current version of Annex 15 published. Nov 2012 . Concept paper from the

New Annex 15 –Updated Requirements & Approach to ValidationPresented by Ashley Isbel10th August 2015

Page 2: New Annex 15 - GMP Consultants, Validation · EU GMP Guide Annex 15 ‘Qualification & Validation’ 2001 . Current version of Annex 15 published. Nov 2012 . Concept paper from the

Slide 2 © PharmOut 2015

EU GMP Guide Annex 15 ‘Qualification & Validation’2001 Current version of Annex 15 published

Nov 2012 Concept paper from the EMA outlined various reasons for the revision of Annex 15.

Feb 2014

Draft Annex was released for public comment

Mar 2015

Final version released

Oct 2015

Implementation in EU and automatic PIC/S adopters

??? TGA implementation has not yet been announced

Page 3: New Annex 15 - GMP Consultants, Validation · EU GMP Guide Annex 15 ‘Qualification & Validation’ 2001 . Current version of Annex 15 published. Nov 2012 . Concept paper from the

Slide 3 © PharmOut 2015

Drivers for the revision

Key drivers:

• ICH Q8, Q9, Q10, and Q11

‒ Indirectly, FDA process validation guidance

• Advancements in manufacturing technology (eg. PAT)

• Changes to other Chapters, Sections and Annexes

• Industry standard practice

Page 4: New Annex 15 - GMP Consultants, Validation · EU GMP Guide Annex 15 ‘Qualification & Validation’ 2001 . Current version of Annex 15 published. Nov 2012 . Concept paper from the

Slide 4 © PharmOut 2015

Drivers for the revision

Page 5: New Annex 15 - GMP Consultants, Validation · EU GMP Guide Annex 15 ‘Qualification & Validation’ 2001 . Current version of Annex 15 published. Nov 2012 . Concept paper from the

Slide 5 © PharmOut 2015

Overview of changes

Page 6: New Annex 15 - GMP Consultants, Validation · EU GMP Guide Annex 15 ‘Qualification & Validation’ 2001 . Current version of Annex 15 published. Nov 2012 . Concept paper from the

Slide 6 © PharmOut 2015

Overview of changes

Key Updates:

• Significant additional guidance on Planning and documentation • Added information on the qualification stages for equipment,

facilities

• Major revision for Process Validation

• Major revision for Cleaning Validation

• New topics added, including verification of transport and method validation

Page 7: New Annex 15 - GMP Consultants, Validation · EU GMP Guide Annex 15 ‘Qualification & Validation’ 2001 . Current version of Annex 15 published. Nov 2012 . Concept paper from the

Slide 7 © PharmOut 2015

Planning & Documentation for Qualification & Validation

8 clauses expanded to 18 in new Annex 15 – Focus on clarity and removal of ambiguity

Explicit permission to utilize vendor and third party testing and documentation – provided ‘appropriate personnel at the manufacturing site confirm suitability and compliance …’

Risk management approach mandated, including life cycle approach to risk assessment

Data integrity is also mentioned were ‘appropriate checks’ needs to be built into qualification and validation tasks ‘to ensure the integrity of all data obtained’

Page 8: New Annex 15 - GMP Consultants, Validation · EU GMP Guide Annex 15 ‘Qualification & Validation’ 2001 . Current version of Annex 15 published. Nov 2012 . Concept paper from the

Slide 8 © PharmOut 2015

Documentation & Qualification stages

Now Mandatory

Now expectedFor complex/novelsystems

Page 9: New Annex 15 - GMP Consultants, Validation · EU GMP Guide Annex 15 ‘Qualification & Validation’ 2001 . Current version of Annex 15 published. Nov 2012 . Concept paper from the

Slide 9 © PharmOut 2015

Process Validation

Annex 15 ‘required’ to be used with relevant’ PV guidelines

Explicit reference to all three phases described in FDA PV guidance (although little information on process development phase)

Detailed information on various aspects of PV – batch sizes, tech transfer, bracketing, use of CQA and CPP, etc.

Clear instructions on retrospective validation (no longer acceptable) and concurrent validation …

New section on ‘Ongoing Process Validation’ included (equivalent to ‘Continued Process Verification’ in FDA guidance.

Page 10: New Annex 15 - GMP Consultants, Validation · EU GMP Guide Annex 15 ‘Qualification & Validation’ 2001 . Current version of Annex 15 published. Nov 2012 . Concept paper from the

Slide 10 © PharmOut 2015

Process Validation

Page 11: New Annex 15 - GMP Consultants, Validation · EU GMP Guide Annex 15 ‘Qualification & Validation’ 2001 . Current version of Annex 15 published. Nov 2012 . Concept paper from the

Slide 11 © PharmOut 2015

Process Validation

Design Space

Page 12: New Annex 15 - GMP Consultants, Validation · EU GMP Guide Annex 15 ‘Qualification & Validation’ 2001 . Current version of Annex 15 published. Nov 2012 . Concept paper from the

Slide 12 © PharmOut 2015

New sections

Entirely new sections:

• Ongoing Process Verification during Lifecycle (phase 3)

• Verification of Transportation

• Validation of Packaging

• Qualification of Utilities

• Validation of Test Methods

Page 13: New Annex 15 - GMP Consultants, Validation · EU GMP Guide Annex 15 ‘Qualification & Validation’ 2001 . Current version of Annex 15 published. Nov 2012 . Concept paper from the

Slide 13 © PharmOut 2015

Cleaning Validation

‘The cleaning procedure should be performed an appropriate number of times based on a risk assessment and meet the acceptance criteria in order to prove that the cleaning method is validated’

Risk Assessment

Meet Acceptance Criteria

ProofAppropriate Number

Page 14: New Annex 15 - GMP Consultants, Validation · EU GMP Guide Annex 15 ‘Qualification & Validation’ 2001 . Current version of Annex 15 published. Nov 2012 . Concept paper from the

Slide 14 © PharmOut 2015

Cleaning Validation

• ‘Visually clean’ not generally acceptable on its own

• ‘Limits should be based on a toxicological evaluation’ and refers to the EMA Guideline on setting health-based exposure limits.

‘Limits for the carryover of product residues should be based on a toxicological evaluation. The justification for the selected limits should be documented in a risk assessment which includes all the supporting references.’

Page 15: New Annex 15 - GMP Consultants, Validation · EU GMP Guide Annex 15 ‘Qualification & Validation’ 2001 . Current version of Annex 15 published. Nov 2012 . Concept paper from the

Slide 15 © PharmOut 2015

Cleaning Validation

‘Therapeutic macromolecules and peptides are known to degrade and denature when exposed to pH extremes and/or heat, and may become pharmacologically inactive.

A toxicological evaluation may therefore not be applicable in these circumstances. If it is not feasible to test for specific product residues, other representative parameters may be selected, e.g. total organic carbon (TOC) and conductivity’.

Also where a cleaning process is ineffective or is not appropriate for some equipment, ‘dedicated equipment or other appropriate measures should be used for each product’ .

Page 16: New Annex 15 - GMP Consultants, Validation · EU GMP Guide Annex 15 ‘Qualification & Validation’ 2001 . Current version of Annex 15 published. Nov 2012 . Concept paper from the

Slide 16 © PharmOut 2015

Cleaning Validation

• No longer looks for ‘3’ consecutive batches

• ‘Concurrent’ validation not acceptable for process, but may be acceptable, in some form, for cleaning validation.

‘It is recognised that a cleaning validation programme may take some time to complete and validation with verification after each batch may be required for some products’

Page 17: New Annex 15 - GMP Consultants, Validation · EU GMP Guide Annex 15 ‘Qualification & Validation’ 2001 . Current version of Annex 15 published. Nov 2012 . Concept paper from the

Slide 17 © PharmOut 2015

Take Home Points

New Annex 15 is more descriptive and has been developed with current industry behaviors in mind

Approach is easily aligned with 3 stage FDA PV guidance, while remaining easily relatable for current Annex 15 users.

For most companies, new requirements should not pose a dramatic shift

Instruction now available for activities previously not addressed

We are one step closer to harmonization …

Cleaning validation implementation is a significant challenge

Page 18: New Annex 15 - GMP Consultants, Validation · EU GMP Guide Annex 15 ‘Qualification & Validation’ 2001 . Current version of Annex 15 published. Nov 2012 . Concept paper from the

Slide 18 © PharmOut 2015

Thank you for your time.

Questions?

Ashley Isbel

[email protected]

Lead Consultant

www.pharmout.net