The key takeaways are that the document outlines First Class Pharmaceuticals' approach and requirements for validation of facilities, equipment, systems and processes to ensure compliance with cGMP regulations.
The main systems and processes expected to be validated according to the plan include facility qualification, utilities like HVAC and water systems, equipment, computer systems, cleaning and sanitation programs, laboratory equipment, and manufacturing processes.
Some of the validation guidelines listed include guidelines for design qualification, installation qualification, operational qualification, process validation, equipment cleaning programs, validation of quality control testing procedures, and more.
Validation Master Plan
Doc # VMP 001
Version 1.0
June 2006 First Class Pharmaceuticals Pty Ltd Page 1 of 33
First Class Pharmaceuticals
VALIDATION MASTER PLAN
Version No 3 June 2006
Approval of the Validation Master Plan
Validation Master Plan Doc # VMP 001 Version 1.0
June 2006 First Class Pharmaceuticals Pty Ltd Page 2 of 33
Sign here after reviewing and approving the document, standards and schedules
Title Name Signature Date Written By: Validation Manager Approved By: Engineering Manager Production Manager Quality Assurance Manager Quality Regulatory Environmental Manager
Distribution List
Name Copy Quality Assurance Manager Original Engineering Manager 1 Production Manager 2 Quality Regulatory Environmental Manager 3 Laboratory Manager 4 IT Manager 5
Validation Master Plan Doc # VMP 001 Version 1.0
June 2006 First Class Pharmaceuticals Pty Ltd Page 3 of 33
Validation Master Plan - Change History Record Ver No. Section Amended Amendment Details Approved By Date of Approval 01 N/A Original
Validation Master Plan Doc # VMP 001 Version 1.0
June 2006 First Class Pharmaceuticals Pty Ltd Page 4 of 33
Table of Contents 1. Introduction .................................................................................................................... 5 2. Purpose and Scope.......................................................................................................... 5 3. Risk Management and Establishment of Validation Priorities....................................... 9 4. Validation Phases ........................................................................................................... 9 4.1 Design Qualification (DQ) ........................................................................................... 10 4.2 Installation Qualification (IQ) ...................................................................................... 10 4.3 Operation Qualification (OQ)....................................................................................... 11 4.4 Performance Qualification (PQ).................................................................................. 11 4.5 Certification.................................................................................................................. 11 5. Validation Documentation............................................................................................ 12 6. Validation Plans for New Projects, Products or Processes .......................................... 12 7. GMP Systems Expected to be Validated...................................................................... 13 8. Retrospective Validation Programs (Retrospective Reviews) .................................... 14 8.1 General Requirements .................................................................................................. 14 8.2 Services Retrospective Validation............................................................................... 14 8.3 Equipment Retrospective Qualification ....................................................................... 14 8.4 Existing Product Manufacturing Validation................................................................. 14 8.5 Filling/Packaging Process Retrospective Validation ................................................... 14 8.6 Establishment of Validation Priorities Risk Assessment .......................................... 14 8.7 Retrospective Validation of Computer Systems.......................................................... 14 9. Revalidation Programs (Routine Validation) .............................................................. 14 10. GMP Computer Systems .............................................................................................. 14 11. Cleaning Validation...................................................................................................... 14 12. Documentation Control and Archiving ........................................................................ 14 13. Validation Schedules .................................................................................................... 14 14. Change Control............................................................................................................. 14 15. Glossary of Terms ........................................................................................................ 14 16. Validation Guidelines List............................................................................................ 15 17. List of Attachments ..................................................................................................... 15 1 Organisational Chart 2 IQ Template 3 OQ Template 4 PQ Template 5 Validation Supplement/Change 6 Validation Deviation
Validation Master Plan Doc # VMP 001 Version 1.0
June 2006 First Class Pharmaceuticals Pty Ltd Page 5 of 33
1. Introduction
The key document in an organisation's validation program is its Validation Master Plan (VMP). It is divided into three parts:
Part A Validation philosophy, scope, responsibilities, guidance documents, training requirements, validation phases, plans and documentation overview. Part B Guidelines for validation plans and protocol preparation Part C Schedules of Work. This Validation Master Plan (VMP) summarises the overall intentions and approach to the validation of the FCP site. It is intended to be a working document and should be periodically updated by site management responsible for the execution of validation.
The Validation Master Plan:
Identifies which items are subject to validation, periodic review or routine validation. Provides schedules of validation. Identifies appropriate standards and guidelines to be referenced. Describes functional responsibilities. Defines protocol preparation, execution and reporting responsibilities. Provides general guidance for validation document format.
2. Purpose and Scope
2.1 Scope The validation master plan covers services installation and commissioning, equipment qualification, computer systems validation and process validation for a range of existing processes. This includes: critical (product contact) equipment qualification critical computer systems validation critical utility and services qualification facility qualification capital works projects (prospective validation) validation of new, or changed, products and processes QC laboratory equipment qualification
Validation Master Plan Doc # VMP 001 Version 1.0
June 2006 First Class Pharmaceuticals Pty Ltd Page 6 of 33
QC laboratory test method validation retrospective (annual) review of critical systems and processes routine revalidation of critical systems
The validation master plan does not include specific methods, laboratory test programs or specific acceptance criteria. These items should be covered in individual protocols.
2.2 Regulatory Standards Validation and operations should be capable of meeting the following regulatory GMP standards. Australian Therapeutic Goods Administration (TGA) cGMP The PIC/S Guide to Good Manufacturing Practices and associated Annexes.
GMP Guidelines and cGMPs PICS Recommendations on Preparation of Validation Master Plans, Installation and Operational Qualification, Non Sterile Process Validation and Cleaning Validation 2001 PIC/S Guidance Good Practices for Computerised Systems in Regulated GXP Environments Annex 15 EU cGMP - Qualification and Validation ISPE baseline Guide Pharmaceutical Water and Steam Guide ISPE GAMP (Good Automated Manufacturing Practices) Guidelines Edition 4 Other Industry Standards and Guides British Pharmacopoeia - current, European Pharmacopoeia - current, United States Pharmacopoeia - current, FDA Guideline on General Principles of Process Validation FDA Guide - Inspection of High Quality Water Systems FDA Guide - Inspections of Validation of Cleaning Processes FDA Guide - Inspection of Quality Control Laboratories PDA Guide to the Validation of Computerised Systems
Validation Master Plan Doc # VMP 001 Version 1.0
June 2006 First Class Pharmaceuticals Pty Ltd Page 7 of 33
2.3 Organisation, Authority and Responsibility 2.3.1 Validation Organisation Validation is managed by the Quality Management Group. Validation schedules and performance to validation plan(s) are presented at the Quality Meetings for review and action as appropriate.
The personnel shaded in the Organisational Chart shown in Attachment 1 take primary responsibility for management of the validation. Validation teams are established as required to carry out specific validation projects.
2.3.2 Authority and Responsibility The Quality Assurance Manager takes overall responsibility for the validation program in consultation with the Production Manager.
The following table details the authority and responsibility for each phase of the plan.
Table 1 Authorisations List Activity Protocol & Document Prepn Protocol & Document Approval IQ Reports OQ Reports PQ Reports Final Report Approval & Certificatn Design Qualification Project Team
Project Team QA Manager Prodn Mgr
-
-
- Project Team QA Manager Prodn Mgr Facility, Services, Equipment Qualification Project Team Project Team QA Manager Prodn Mgr Project Team Contractor QA Mgr Project Team Contractor QA Mgr
- Project Team QA Manager Prodn Mgr Process Validation Project Team Project Team QA Manager Prodn Mgr
-
- Project Team Contractor QA Mgr Project Team Contractor QA Manager GMP Computer Systems User Group PC & LAN Administrator QA Manager User Group PC & LAN Administrator PC & LAN Administrator Contractor QA Manager User Group PC & LAN Administrator Contractor QA Mgr User Group PC & LAN Administrator Contractor QA Mgr User Group PC & LAN Administrator QA Manager Cleaning & Sanitation Programs Project Team QA Manager
June 2006 First Class Pharmaceuticals Pty Ltd Page 8 of 33
2.3.3 Validation Training
Validation Principles Training
Validation training will be undertaken on an as needs basis but prior to the commencement of validation activities such as executing protocol. The training will cover the following: content, intent and scope of the VMP (this document) preparing protocols - layout and content executing protocols recording and maintenance of raw data making changes during validation projects preparing validation reports - content and standards
Validation training will be given to all people involved in the above activities. It will also ensure that personnel are familiar with the operation of plant and equipment.
GMP Training
Staff will be trained in the principles of GMP and on the job application of GMP as part of orderly start up of process lines. Specialist training in the operation of equipment and performance of test methods will be conducted as required.
The training will include, where applicable: Regulatory Standards Principles of Cleaning and Sanitation Personnel Hygiene Good Laboratory Practices Good Manufacturing Practices Company Documentation (SOPs and Batch Records)
Specific instructions on equipment operation and safety shall be conducted as part of Operational Qualification.
Standard Procedures Training
Training in the application of specific Standard Operating Procedures (SOP) will occur as part of the start up of operations. Training will be verified as part of equipment qualification, cleaning validation and process validation.
Validation Master Plan Doc # VMP 001 Version 1.0
June 2006 First Class Pharmaceuticals Pty Ltd Page 9 of 33
3. Risk Management and Establishment of Validation Priorities
The scope of the validation activities relates directly to the risk assessment. The following definitions are used to identify priorities in the Validation Schedules (Part C): Validated Validation Not Required or Not Applicable. To Be Assessed in the next 12 months (TBA) Requires Validation in the current planning period (RV)
These decisions, and all assumptions upon which they were made, should be documented and filed by Quality Assurance. 4. Validation Phases Validation is an activity that involves establishing documented evidence that a process does what it purports to do based on a plan. Prospective Validation usually takes place in five distinct phases: 1. Design Qualification (DQ) 2. Installation Qualification (IQ) 3. Operation Qualification (OQ) 4. Performance Qualification (PQ) 5. Certification
User Requirements (Process oriented descriptions ) PQ OQ IQ Design Specification (Detailed Technical Documentation ) Functional Requirements ( What? How?) Implementation DQ (Audits & Reviews) is based on is based on is based on Commissioning
Validation Master Plan Doc # VMP 001 Version 1.0
June 2006 First Class Pharmaceuticals Pty Ltd Page 10 of 33
IQ (Installation Qualification) ensures that what has actually been provided complies with the Design Specification. IQ establishes that: operational and maintenance documents are present and registered, product contact surfaces are finished to pharmaceutical standards and clean support utilities and lubricants are reviewed and compliant, installation, hookup is complete and satisfactory (as determined by a physical inspection), safety and inspection are complete and satisfactory (as determined by a physical inspection),, software interfaces and controllers are documented and connected, instrument calibration is complete, preventative maintenance requirements are documented and complete, training on equipment and safety is complete, deficiency reports are reviewed and closed out Installation Qualification (IQ) protocols are customised from a general template (refer Attachment 2). Specific IQ protocols should be prepared for major utilities, computerised systems and for individual items of equipment. Guidelines are included in Section B of this document.
A report summarising the results of IQ should be written, reviewed and approved.
Validation Master Plan Doc # VMP 001 Version 1.0
June 2006 First Class Pharmaceuticals Pty Ltd Page 11 of 33
4.3 Operation Qualification (OQ)
OQ (Operation Qualification) verifies that the equipment or process does operate as described in the Functional Requirements. It may commence before IQ reports are written but should not commence before the IQ is substantially completed. Allowance for what minimum checks are required before OQ can commence shall be stipulated in the Validation Plan and/or IQ Protocol.
OQ establishes that: utilities and services have been installed and qualified, critical instruments have been calibrated, equipment control function tests have been qualified, control over critical operating variables have been established and all tests have passed, final commissioning trials under operational conditions are satisfactory and all tests have passed, standard operating procedures have been published, safety conditions, alarms and controls have been qualified, deficiency reports have been reviewed and closed out, IQ report has been prepared and completed. Operational Qualification (OQ) protocols are customised from a general template (refer Attachment 3). The test case/test plans must be specific for the item under qualification. Specific OQ protocols should be prepared for major utilities, computerised systems and for individual items of equipment. Guidelines are included in Section B of this document.
IQ and OQ may be combined into the one document. This is suitable when the work is being carried out by the same people and immediately following IQ.
A report summarising the results of IOQ should be written, reviewed and approved.
4.4 Performance Qualification (PQ)
4.5 Certification Before the facility, equipment or process can be handed over to Production for routine operations, a formal report must be written summarising the results of all validation activities, and a validation status assigned and a Certificate issued.
It may be that not all results are available, or that some deficiencies or other issues are still outstanding when production requirements necessitate using the facility, equipment or process. These situations must be foreseen and allowed for within the Validation Plan or Protocol, an Interim Report prepared and an Interim Certificate Released.
Validation Master Plan Doc # VMP 001 Version 1.0
June 2006 First Class Pharmaceuticals Pty Ltd Page 12 of 33
5. Validation Documentation 5.1 Preparation of Protocols and Specifications.
5.2 Support Documentation 5.2.1 Protocol Supplement or Variation (refer Attachment 5) During the course of validation there may be a need to update or amend protocols. This shall be done via protocol supplements, rather than re-issue of new protocols.
5.2.2 Deficiency Report (refer Attachment 6) During the course of validation activity deficiencies may arise. These should be documented according to a deficiency report.
6. Validation Plans for New Projects, Products or Processes
6.1 Introduction 6.2 Publication and Control of Validation Schedules
Validation Master Plan Doc # VMP 001 Version 1.0
June 2006 First Class Pharmaceuticals Pty Ltd Page 13 of 33
7. GMP Systems Expected to be Validated
Area or GMP System List of GMP Critical Systems Expected to be Validated Facility Qualification (GMP Room Commissioning) As required by new project plans. The following rooms should be qualified: Raw materials and finished products storage Dispensaries and sampling areas Equipment washing, preparation and storage rooms Component (bottles, caps etc) preparation areas Manufacturing areas Filling areas Packaging area Services Qualification
Process Equipment Qualification
Process Validation
GMP Computer Systems
Cleaning & Sanitation Programmes
Laboratory Equipment Qualification
Test Methods
Validation Master Plan Doc # VMP 001 Version 1.0
June 2006 First Class Pharmaceuticals Pty Ltd Page 14 of 33
8. Retrospective Validation Programs (Retrospective Reviews) 8.1 General Requirements 8.2 Services Retrospective Validation 8.3 Equipment Retrospective Qualification 8.4 Existing Product Manufacturing Validation 8.4.1 General Strategy 8.5 Filling/Packaging Process Retrospective Validation 8.6 Establishment of Validation Priorities Risk Assessment 8.7 Retrospective Validation of Computer Systems
9. Revalidation Programs (Routine Validation) 10. GMP Computer Systems 11. Cleaning Validation 12. Documentation Control and Archiving 13. Validation Schedules 14. Change Control 14. Glossary of Terms
Validation Master Plan Doc # VMP 001 Version 1.0
June 2006 First Class Pharmaceuticals Pty Ltd Page 15 of 33
15. Validation Guidelines List Part B of this document provides validation guidelines to assist protocol writers in the preparation of protocols. The guidelines are NOT mandatory standards but represent the current expectations of Quality Assurance. Alternative approaches are acceptable. The guidelines should be updated as experience is gained or industry expectations change. The list of validation guidelines include the following:
Guideline # Title 1 Design Qualification GMP Design Review and Qualification of Specifications 2 Construction Documentation and Quality Assurance New Facilities 3 Installation Qualification and GMP Room Finishes New Facilities 4 Operational Qualification of GMP Manufacturing Rooms 5 Critical Utilities - Heating, Ventilation and Air Conditioning (HVAC) 6 Qualification of Process and Purified Water Systems 7 Qualification of Compressed Gases Systems (Air and CO 2 ) 8 Qualification of New Manufacturing Equipment General Approach 9 (Re) Qualification of Existing Manufacturing Equipment General Approach 10 Computer Validation 11 Guidelines for Process Validation 12 Guidelines for Conducting Retrospective Process/Product Review and Verifications 13 Guidelines for the Content of Process Validation Protocols 14 Guidelines for the Content of Process Validation Reports/Executive Summaries 15 Support Systems - Calibration and Preventative Maintenance Programs 16 Guidelines for Equipment Cleaning Programs - CIP and Manual 17 Validation of Quality Control Testing Procedures
17. List of Attachments 1 Organisational Chart 2 IQ Template 3 OQ Template 4 PQ Template 5 Validation Supplement/Change 6 Validation Deviation