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Reduce Risks and Costs for Laboratory Equipment Qualification
Gary Powers Global Compliance Program Manager
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Aspects of Instrument Qualification
4 Q Model for Instrument Qualification
PQ DQ OQ IQ
Does it Meet your USER
REQUIREMENTS
Design Qualification
Installation Qualification
Has it been INSTALLED CORRECTLY
Operational Qualification
Performance Qualification
Does it WORK as YOU
EXPECTED
Will it CONTINUE to
work CORRECTLY
But there are no set rules, and people do not agree on:
WHAT content is in each of the stages HOW often an OQ should be performed WHO performs the stages (OQ / PQ) WHAT needs to be done during the lifecycle
Company Confidential
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DQ
Use OQ
IQ Maintenance
Re-Qualification (Justification)
Breakdown
Repair Re-Qualification (Justification)
Is the instrument suitable for use?
Is it installed correctly?
Is there an SOP? Are people trained? Calibrated? Validated method?
Maintenance Routine?
Failure management Impact of failure CAPA?
Re-Qualification / Calibration
What do you want the system to do?
- Write it down - Why is it suitable?
Does it work?
- Installed correctly - In your laboratory
What about the future?
Audit Focus
Re-Qualification (Justification)
Re-Qualification (Justification)
Frequent Questions
Justification:
OQ – How Often RQ – What to include
Company Confidential
Instrument Lifecycle
Search “FDA Warning Letters”
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http://www.fda.gov/ICECI/EnforcementActions/WarningLetters/default.htm
Basic Search Engine
Company Confidential
Search for “HPLC”
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A B C
D E
Company Confidential
FDA Warning Letters by Technique
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• KF – 2 • NMR - 2 • FTIR – 3 • FT-IR – 7 • Infrared – 47 • GC – 14 • Chromatography - 26 • Dissolution – 38 • UV – 43 • HPLC – 60 • Qualification – 303 • Calibration – 405 • Training – > 1,000 • Agilent - 0
• Pharmaceutical Manufacture
• Medical Devices
• Food Imports (3,000, 128,000, 48,000,000) (Updated M. Hamburg Speech, 4th Oct. 2011)
• Neutraceuticals (Fundamental cGMP)
• Cosmetics
• Tobacco Products
Searched 26 Feb 2013
Manufacturing Process Qualification
Supplier Qualification
Company Confidential
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725
535 538 471 445 474
673
1720
0
200
400
600
800
1000
1200
1400
1600
1800
2000
2200
2400
2600
2800
3000
2002 2004 2006 2008 2010 2012 2014
2767 www.fda.gov/downloads/ICECI/EnforcementActions
Margaret Hamburg joins FDA
FDA
War
ning
Let
ters
Trend down to flat
Trend sharply up
FDA Audits: 97 % of US Facilities [pharmaceutical, every 2 years]
FDA Audits: 7 % of Non US Facilities [pharmaceutical every year]
[Source: Journal of Validation Technology; D. W. Vincent, Winter 2012 edition]
Mutual recognition audits [Tougher “National” Audits]
Risk-based audit triggers…… Whistle blowers….
Company Confidential
FDA Warning Letters FY 2004-2012
FDA HPLC Warning Letters
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0 1 2 3 4 5 6 7 8 9 10 11 12
Data Integrity - No Electronic Review
Data Integrity - Security
Data Integrity - Incomplete Records
Data Integrity - Data Deletion
Deficient HPLC Method
HPLC Method Validation
Chromatography - Unknown Peak
Problems With System Suitability
Repeat Work - No Justification
Repair Impact Assessment
OOS Problems
N/A
No Data Backup
No Calibration
Calibration Defeciencies
No HPLC - But Chromatograms !
1
7
3
1
5
8
3
3
1
2
2
4
1
8
10
1
92% related to Data Integrity
0 1 2 3 4 5 6 7 8 9 10 11 12
Data Integrity - No Electronic Review
Data Integrity - Security
Data Integrity - Incomplete Records
Data Integrity - Data Deletion
Deficient HPLC Method
HPLC Method Validation
Chromatography - Unknown Peak
Problems With System Suitability
Repeat Work - No Justification
Repair Impact Assessment
OOS Problems
N/A
No Data Backup
No Calibration
Calibration Defeciencies
No HPLC - But Chromatograms !
1
7
3
1
5
8
3
3
1
2
2
4
1
8
10
1
Calibration: Biggest Single Category (30 %)
Decisions & Justification
Using the Method
Data Integrity
Capability of the Method
Would you trust these data ?
Poor Compliance SOP’s
Poor HPLC Use / Training
HPLC Methods
Would you trust these data ?
From 2001
Company Confidential
Most concern validity of analytical results
FDA “HPLC” Warning Letters last 12 years
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More HPLC warning letters issued than any other year!
0
1
2
3
4
5
6
7
8
99
5
6
3
4 4
3
2 2
4
5 5
Year
FDA HPLC Warning Letters
Company Confidential
FDA GC Warning Letters
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Most concern validity of analytical results 86% related to Data Integrity
Read Evaluate Risks Categorize Knowledge
0 1 2 3 4 5 6
Data Integrity - No Raw Data
Data Integrity - Security
N/A
Defecient GC Method
GC Method Validation
System Suitability
Calibration Deficiencies
No Calibration
No GC
1
1
2
1
1
1
2
4
1
0 1 2 3 4 5 6
Data Integrity - No Raw Data
Data Integrity - Security
N/A
Defecient GC Method
GC Method Validation
System Suitability
Calibration Deficiencies
No Calibration
No GC
1
1
2
1
1
1
2
4
1
Poor GC Use / Training
GC Methods
Calibration: Biggest Single Category (43 %)
Using the Method
Data Integrity
Capability of the Method
Would you trust these data ?
Would you trust these data ?
Company Confidential
HPLC/GC FDA Warning Letters vs. Lifecycle
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Calibration 24
Method Use 7
Method Capability 15
Data Integrity 14
Impact Assessment 2
Company Confidential
What are the most common deficiencies in
calibration / qualification?
Review of FDA Warning Letters what OQ / Calibration Problems does FDA Find ?
• OQ not good enough - Critical parts of system not qualified adequately or did not qualify range of use [27 % HPLC, 36 % GC of warning letters on these techniques] Example:
• People not adequately trained – FDA observe people doing the work [High feature in EIR Data Review]
• No raw data for the work – Firm could not show inspectors the raw data [More common in India and China] Example:
• Tools used were not calibrated – Tools used in an OQ must be calibrated. Example:
• OQ failures not detected – By person doing the work or managers checking it. Example:
• Data integrity – Data not assured or not secure - could have been tampered with [Most significant area, includes all the above]. Example:
http://www.fda.gov/ICECI/EnforcementActions/WarningLetters/2009/ucm183410.htm [Ion Labs. 2009]
http://www.fda.gov/ICECI/EnforcementActions/WarningLetters/2010/ucm249641.htm [Nanjing Pharmaceuticals, 2010]
http://www.fda.gov/ICECI/EnforcementActions/WarningLetters/2010/ucm236841.htm [Yuki Gosei Kogyo, 2010]
http://www.fda.gov/ICECI/EnforcementActions/WarningLetters/2009/ucm136661.htm [Time-Cap Labs., 2006]
http://www.fda.gov/ICECI/EnforcementActions/WarningLetters/2010/ucm249641.htm [Nanjing Pharmaceuticals, 2010]
http://www.fda.gov/ICECI/EnforcementActions/WarningLetters/2012/ucm298187.htm [UNAM, 2012]
Laboratory Compliance Risk
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“Too Little” Compliance
(High Risk)
Laboratory Compliance Risk is about “getting it right ”
• Damage to reputation • Loss of accreditation
• Cost of “Cost Savings” • What are “Real Costs” Many companies don’t know
“Too Much” Compliance
(High Cost)
Risk Implications to consider:
• High “visibility” of non-compliance + “risk rating” • Low Risk – Faster Review / High Risk - AIP (FDA - Application Integrity Program)
• Now much wider than laboratory cost savings……
Laboratory Compliance
Company Confidential
May 15, 2014 Confidentiality Label
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Data Integrity
Data
Prove your data are not fraudulent
• ALCOA…. (understand) • Build lab workflow • Compare results to electronic • Data Integrity audits
• All electronic • Not tampered with • Implement reviews
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• Scientific “Validity” • ICH Q9, Q10, Q11 support
• FDA Part 11 “add-on” Audits • Jan. 2011
• Data Integrity has always been an FDA focus
• 1997 Implementation • 2003 Guidance
Science Based GMP Decisions
(e.g. cGMP for 21st Century)
Fundamental Data Integrity
21 CFR Part 11
Part 11 Add on Audits
FDA focus on data integrity
[ PAI, Consent Decree, Data Integrity Training… etc. ]
Company Confidential
Data Integrity drives Harmonization
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1. Sample Receipt
2. Booked into LIMS
3. Schedule Tests
4. Sample Preparation
5. Chromatograph Sample
6. Calculate Results
8. Compare Against Specification
7. Check / Report Results
“21 CFR Part 11 = Good Document Practice for Electronic Data”
A ttributable [Who did it]
L egible [Can you read it]
C ontemporaneous [Done in “Real Time”]
O riginal [Is it original]
A ccurate [Is it Accurate]
Electronic Log Vs. Ink Signature
Print Vs. Handwriting
Electronic Log Vs. Written Data
Secure Electronic File Vs. Paper “Photocopy”
Validated Electronic Output Vs. Paper….
Electronic Vs. Paper
Greater Risk (easier to manipulate) ?
More Secure (harder to manipulate) ?
Company Confidential
How to Balance – Costs Vs. Risks
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Costs
Costs
As long as laboratory compliance is perceived as a cost burden, a cost saving mind set will prevail
Generally, compliance risks are based on perceptions, while costs savings are based on a spreadsheet
Costs Compliance
Company Confidential
Laboratories that Follow Compliance Best Practice:
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Good Defense
Robust, well structured, understood, rehearsed “why are your results valid”?
this is the starting point….
Are Aware and Manage
Any gaps around their history, use, origins, qualification, problems “show me…..” ?
Can explain and defend instrument control strategy
Are Proactive
Prepared for future compliance trends that will affect them “what if…..”?
Perform gap analysis against those trends
Company Confidential
Laboratories that Follow Compliance Best Practice:
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Minimize
Instrument down time using efficient, coordinated maintenance and qualification processes such as Agilent Enterprise Edition
ROI for LC-MS, GC-MS and UHPLC
Range of Use
Qualify the range where their instruments are used no additional awkward qualification or justification
Linked to the methods they use
Understand
Traceability of raw data in their qualification reports and can demonstrate this
Supported by fully integrated electronic reports
Company Confidential
Agilent Enterprise Edition
22 Agilent Confidential
Agilent Enterprise Edition analytical instrument qualification is automated, paperless and compatible with instruments from all leading vendors
Innovation in Compliance
Enterprise Edition reduces regulatory risk: • Harmonization across instruments • Flexibility to configure testing to SOP requirements • Full automation to assure adherence to protocol • Electronic reports and signatures
Equipment Qualification Plan – Universal Protocol
23 Agilent Confidential
Harmonization
• Single protocol per technique
• Protocols compatible with systems from all leading vendors – Waters, PerkinElmer, Thermo, Shimadzu, Dionex, many more
• One protocol for QA to approve saves time
Testing Flexibility
• Specify set points/limits, add/remove tests without interfering with test design
• Specify testing based on your SOP requirements
Configurable Testing
24 Agilent Confidential
Agilent Enterprise Edition Innovation
Paperless Reports
25 Agilent Confidential
Single locked .pdf report • More secure GxP record • One single signature required
All-electronic information • Legible data entries, results and signatures • Electronic Routing for review • Export to external ECM and data bases
Reports burned to CD-ROM • Total integrity, 21 CFR Part 11, ISO compliant format • Less storage space and lower archival costs
Agilent Enterprise Edition Innovation
Automated Compliance Engine
26 Agilent Confidential
Agilent Enterprise Edition Innovation
ACE efficiently enforces compliance to procedure
• Fully automated protocol
• Validated calculations
• Simultaneous qualification
• Results fully traceable to raw data
• Reports free of transcription errors
• Automated pass/fail report
ACE Partner Edition
27 Agilent Confidential
• Access to all Agilent-developed and -tested protocols: (IQ, OQ, RQ, MQ, PQ, FV, PM)
• Assurance of auditability following approved and locked test methodology
• Customize protocol using the EQP Editor • ACE qualifies the latest technologies
including GC, LC, MS, Disso, UV, ICP-MS, AA, more
• Training and support for more effective teams
• Agilent-mentored deliveries help ensure success
• Far more robust compared to smart pdf’s and spreadsheets, especially in an audit
Agilent Compliance Innovation
ACE Partner Edition
28 Agilent Confidential
• Simple OQ setup typically takes less than 10 minutes move immediately to protocol execution
• Multiple sessions run simultaneously easy to duplicate, restore • Previous session recall without fear of losing past work • Parallel services run multiple simultaneous compliance services • Parallel processes complete documentation while running OQ • Task-based working instructions now include GC and GC/MS • Direct data retrieval from PC
Agilent Compliance Innovation
Process Data
Run Qualification
Documentation
Attachments
Agilent Compliance
29 Agilent Confidential
Agilent Compliance Innovation
Questions? For more information
please visit us online at
www.agilent.com