Risk Based Validation (RBV) was sanctioned by the FDA (along with EC and WHO) as soon as it became obvious that the scope of any validation task must be allowed to be adjusted to avoid over burdening companies with repetitive and or unnecessary tasks. However this was not meant to reduce validation intensity; only to render it more appropriate and targeted. The final defined scope of risk based validation activities must still be reviewed to verify it's adequacy.
We are all aware that risk assessment’s come in many formats; for instance, we have on our site a fully detailed; Failure mode and effects analysis (FMEA) template, which we use for all aspects of concept development and design development.
The Validation Online risk based validation - Online Risk Assessment (VRA) is a very different document and was specifically designed to assess and define the appropriate scope of any validation task. As such; it is a very important document which is mandated by the FDA and regularly reviewed by them.Is the scope of your validation adequate? Is probable the most important question in validation and the VRA must give assurance that it is.
The pit-fall(s) of using multiple event Risk Assessments (such as FMEA’s) is simply that there are not (in validation) multiple variations or answers available. At the validation stage the system / process / equipment / program has already been bought / built / written / installed and commissioned. All aspects of design / functionality / safety / operability will have been fully debated and integrated at the URS stage and reviewed and approved at the DQ stage.
Validation is the number one priority in most modern facilities, fall down on your validation and the regulators (FDA / MHRA / EMEA) can fine you, remove your approval to manufacture, or even close you down. Losing your manufacturing rights for a drug that has taken hundreds of millions to develop, is catastrophic, even to the major international companies. Good risk based validation ensures that this does not happen.
Validation is a mixture of skills, and the manual is designed to interlink with your existing skills and add the required mix of Quality, Instrument, electrical and mechanical knowledge to enable you to work as a validation technician or engineer or consultant in the pharmaceutical or biotechnological or API or Medical Device, industries. In validation you are not designing, you are verifying that equipment or installation conform to certain standards.
This involves authoring a document train that starts with the URS follows with IQ / OQ and usually finishes with the PQ, normally difficult and complex documents - but in your case - they are all in the manual Corporate Validation Manual DVD, ready for you to download. Using the manual is a great way to receive training while maintaining full time employment, and to feel confident that the manual has the answers or can point to where the answers are for any validation problem you may run into.
Whenever a new installation or changes or modifications are to be made to equipment used within a 21 CFR Part 210/211/820 compliant manufacturing, testing and or storage facility; a Validation Planᴬ⁴ (VP) must be initiated in order to document and authorize all the attendant responsibilities, scopes and associated requirements. This VP will also define whether the proposed change will use a single User Requirements Specificationᴬ¹ (URS) document for the change, or individual URS documents for all associated equipment allied to this proposed change.
The URS is such an important document that you can always be certain that time spent ensuring it is put together correctly, will pay dividends later in the risk based validation process. Initially the document will contain the high level requirements of the end user; laid out in a clear and unambiguous manner. In the URS each of these requirements must be detailed in a manner that will render them verifiable by the execution of a testing or inspection procedure. This high level document is titled URS-Level-1. The requirements in this Level 1 document must subsequently be broken down into activities. Then these activities must be further broken down into direct tasks and support tasks. This is an engineering responsibility and produces URS-Level-2. If the system uses software, the tasks detailed in URS-Level-2, must be translated into lines of code by the software writer, these lines of code must be attributed and constitute URS-Level-3.
These URS Level 2 and 3 documents were once part of the Functional Specificationᴬ⁷ (FS), however the mandated requirement for traceabilityᴬ⁷ from each requirement in the URS to the actual verification of compliance inspections or tests in the Performance Qualificationᴬ² (PQ), forced a step change to be initiated to enable compliance with the Full Life Cycle Requirements in risk based validation. Prior to this change; detailed traceability between the URS and the Design Specificationᴬ⁵ (DS) had become difficult if not impossible to achieve. The use of levels of URS now reinstates the required traceability and engenders good testing between design and protocol verifications. During these activities the URS must be maintained as an active document with each (of the 2 or 3) stages being reviewed and approved on completion.
With the URS completed and approved, the procurement process can commence. When the successful design (or product, if off the shelf item is chosen) is known, its design must be subjected to the execution of a Design Qualificationᴬ³ (DQ) which will be used to verify that this proposed procurement will satisfy all the documented requirements in the URS.
The completion of the DQ allows the procurement process to complete and the ’hands on’ stage of the risk based validation process to commence. Next we must execute a Validation Risk Assessmentᴬ⁶ (VRA). This is often the most abused and misunderstood document in the validation process. The VRA is in place because the regulators have decreed that we must produce, and hold for regulatory inspection, a documented justification for the scope of validation activities we have deemed to be appropriate in our planned risk based qualification. They expect this justification to take the form of a risk assessment. This makes the VRA a very meaningful document. Your VRA must consider all the regulatory requirements and define a level of risk based validation intensity that is cost effective to the end user, while being appropriate to the sophistication of the equipment and acceptable to the regulatory authorities.
Since the execution of the VRA will define the scope of validation; its execution, will allow the protocol authors to commence authoring the Installation Qualificationᴬ³ (IQ), the Operational Qualificationᴬ⁵ (OQ) and the Performance Qualification (PQ). All based on the findings of the risk based qualification execution.
When goods or services are purchase by a cGMP approved organization from a none cGMP approved vendor; it is a legal requirement that the would-be purchaser audits the supplier to establish the scope of any work required to render the item or process cGMP compliant
This elevates the Vendor Audit (VA) Document to a “Must be in Place” status. So, your list of pre validation doc's must include: (VA) + (FAT) + (SAT)
These are mandatory & available as a package;
This Validation, Risk & Requirements Plan (VrrP) is one document designed specifically to replace three. The contents of the three original documents were completely revised and edited into a more compact and interactive format. Resulting in the document becoming notably easier to use and quicker to review and amend. This new format will make a very significant difference to the man hours required to produce and execute these documents. There will also be a very noticeable reduction in the time required for the reviewing and approving tasks. This new document titled the VrrP replaces the VP, VRA & URS and now compliments our equally new 4Q Protocol, which integrates the DQ/IQ/OQ/PQ into one document. This is an essential step forward for companies seeking to reduce validation costs without sacrificing regulatory compliance.
4Q Equipment Validation Protocol (4Q-Equip) has been designed specifically to replace four standard protocols. By taking the contents of the four protocol and carefully weaving them into one notably easy to use protocol, we have made a significant advance in the task of streamlining validation documentation by reducing protocol numbers by close to 75%. The new bang up to date 4Q protocol replaces the DQ, IQ, OQ & PQ and now compliments our equally new VrrP Protocol. By integrating the old style DQ/IQ/OQ/PQ into one 4Q document there will be enormous savings in man hours in the authoring, reviewing, updating and approving tasks. For everyone's convenience, it is still written in word.
This quite revolutionary two document package is all that is required to fully validate; to cGMP standards, equipment used in a regulated facility. A lot of effort has gone into ensuring that repetitive instructions and actions have been designed out and innovative and intuitive risk-based methodologies have been incorporated. Both documents are prefaced with a methods Standard Operating Practice (SOP) document. These SOP’s lead you through the task of converting these highly detailed templates into your very own company bespoke protocols. The hyperlinks and cross-references within the package are; not only unique, but also highly cost effective and intuitive to use. Each document is preloaded with the test scripts (complete with acceptance criteria). All test and inspection scripts are written in MS word, to facilitate simple editing of text, layout, tables and schematics.