Leveraging Inspection Manuals for GMP Inspection Readiness

The various agency inspection manuals are critical tools for inspection readiness. I want to lay out where to find some of these manuals and then go deep into pre-approval inspections, focusing on data integrity.

European Medicines Agency

The European Medicines Agency (EMA) has established detailed procedures and work instructions for coordinating and conducting Good Clinical Practice (GCP), Good Manufacturing Practice (GMP), and pharmacovigilance inspections. Here are the key points regarding EMA’s inspection procedures:

GCP Inspection Procedures

EMA identifies applications for GCP inspections based on risk assessment criteria and exchanges information on shared applications with the FDA.
Inspections can be joint (conducted concurrently by EMA and FDA inspectors) or sequential (conducted separately by each agency).
EMA notifies the applicant/marketing authorization holder (MAH) and inspects sites about upcoming inspections through the IRIS industry portal instead of formal letters.
Applicants/MAHs must provide a signed statement accepting the inspection and granting direct access to documents and medical records.
Requested documents should be provided directly to inspectors in electronic format after consulting the reporting inspector.
After the inspection, EMA receives the draft inspection report, finalizes it with the inspectee’s responses, and publishes it in IRIS.

GMP Inspection Procedures

EMA coordinates GMP inspections based on risk assessment for marketing authorization applications, variations, and routine re-inspections.
Work instructions cover areas such as inspection announcement, fee calculation, product sampling/testing, and report circulation.

Pharmacovigilance Inspection Procedures

EMA has specific procedures for coordinating pharmacovigilance inspections and managing non-compliance notifications from MAHs.
Work instructions detail the inspection program creation, data entry in databases, and interactions with third-country inspectorates.

The EMA aims to harmonize inspection processes with the FDA and other regulatory bodies to streamline collaboration and information sharing while ensuring clinical trial subject protection and product quality.

FDA

The FDA Investigations Operations Manual (IOM) is the primary inspection manual used by FDA personnel when performing inspections and investigations.

The key points about the IOM are:

It provides comprehensive instructions, procedures, and policies for FDA investigators and inspectors to follow when conducting inspections, surveys, and investigations.
It covers inspectional activities for foods, drugs, medical devices, biologics, cosmetics, and other FDA-regulated products.
The manual details procedures for inspections of manufacturing facilities, sampling, import operations, recalls, consumer complaints, and other compliance activities.
It aims to ensure inspections are conducted consistently across FDA field offices and provide clear guidance to the industry on the FDA’s inspection approach.
The IOM is updated periodically to incorporate new laws, regulations, policies, and technological changes impacting FDA’s operations.
While not legally binding, the IOM represents the FDA’s current thinking and policies on inspections and investigations.

The FDA Investigations Operations Manual serves as the comprehensive inspection reference and procedure manual for FDA field staff carrying out the agency’s oversight and enforcement activities across all regulated product areas.

Pre-Approval Inspections

For new facilities, CPGM 7346.832, the FDA’s Compliance Program Guidance Manual for Pre-Approval Inspections (PAIs) of drug manufacturing facilities, is critical to spend time with. It outlines the objectives and procedures for FDA inspectors to evaluate a facility’s readiness for commercial manufacturing before approving a new drug application.

The key objectives of CPGM 7346.832 are:

Assess if the facility has a quality system capable of controlling commercial manufacturing operations.
Verify that the manufacturing processes, formulation, and analytical methods conform to the application details.
Audit raw data integrity to authenticate the data submitted in the application.
Evaluate the facility’s commitment to quality in pharmaceutical development (new objective added in 2022 revision).

The guidance instructs inspectors on evaluating the firm’s quality systems, process validation, data integrity, laboratory controls, change management, investigations, batch release procedures, and compliance with current Good Manufacturing Practices (cGMPs). It aims to ensure the facility can reliably produce the drug product described in the application.

Data Integrity

CPGM 7346.832 has specific requirements for data integrity audits during drug manufacturing facility pre-approval inspections (PAIs). Utilizing this document is an excellent way to evaluate your data integrity program.

The key points are:

Objective 3 of the guidance is “Data Integrity Audit”—auditing and verifying raw data associated with the product to authenticate the data submitted in the application.
Inspectors must audit the accuracy and completeness of data reported by the facility for the product. This involves verifying the factual integrity (data matches what was submitted) and contextual integrity (supporting data is complete).
Inspectors should examine raw data, such as chromatograms, analyst notebooks, electronic data, etc., and compare it to the summary data in the application’s Chemistry, Manufacturing, and Controls (CMC) section.
The data integrity audit should focus on finished product stability, dissolution, content uniformity, API impurities, etc.
Inspectors must identify any unreported relevant data, data falsification, improper invalidation of results, or unexplained data discrepancies.
Indications of data integrity issues include altered raw data, references to failing studies, discrepancies between samples, and missing records.

The data integrity audit aims to ensure the CMC data submitted to FDA is complete, reliable, and can be fully authenticated from the raw data at the manufacturing site. Robust data integrity is critical for the FDA to decide on the application’s approval.

Commissioning, Qualification and Validation

Commissioning, qualification, and validation are three distinct but interrelated processes in the pharmaceutical and biotechnology industries that ensure facilities, equipment, systems, and processes meet regulatory requirements and produce products of the desired quality. Here are the key differences:

Commissioning

Commissioning is a systematic process of ensuring that equipment, systems, and facilities are designed, installed, and functioning according to operational and engineering requirements.
It involves design reviews, installation verification, functional testing, and handover to operations.
Commissioning primarily focuses on satisfying engineering requirements and does not have direct regulatory requirements.

Qualification

Qualification is a regulated and documented process that demonstrates that equipment, systems, and facilities are installed correctly and operate as intended for their specific use.
It applies only to equipment, systems, and utilities that directly or indirectly impact product quality and patient safety.
Qualification activities include Installation Qualification (IQ), Operational Qualification (OQ), and Performance Qualification (PQ).
Qualification is focused on by regulatory authorities like the FDA and EMA to ensure compliance.

Validation

Validation is a broader concept establishing documented evidence that a process consistently produces a product that meets its predetermined specifications and quality attributes.
It encompasses the entire process lifecycle, including process design, qualification of equipment/systems, and continued process verification.
Validation ensures that the equipment and systems are qualified and the entire process is controlled to produce the desired final product.

In summary, commissioning verifies engineering requirements, qualification demonstrates suitability for intended use, and validation provides a high degree of assurance that the process will consistently produce a quality product. These activities are interconnected, with commissioning often leveraged during qualification and qualification being a subset of the overall validation process.

FDA’s Framework for Process Validation

The FDA’s Process Validation Guidance is a core document outlining a lifecycle approach with outlines a lifecycle approach with three main stages:

Stage 1: Process Design

Establish a process design based on knowledge gained through development and scale-up activities.
Identify critical quality attributes (CQAs) and critical process parameters (CPPs) using risk assessment and multivariate studies like Design of Experiments (DoE).
Develop a control strategy to ensure CQAs are met.

Stage 2: Process Qualification

Evaluate the process design through facility, utility, and equipment qualification.
Conduct performance qualification (PQ) by running production batches to confirm the process design has reproducible commercial manufacturing.
Establish scientific evidence that the process meets all defined requirements and product specifications.

Stage 3: Continued Process Verification

Maintain the validated status and monitor performance to ensure a state of control.
Identify sources of variation and implement process improvements through an ongoing program.
Conduct product quality reviews periodically to evaluate process performance.

The guidance emphasizes using a science and risk-based approach throughout the lifecycle, leveraging process understanding and knowledge gained from development through commercial production. Effective process validation requires good planning, documented evidence, and a robust quality system.

Crafting Good User Requirements

The User Requirements are a foundational document identifying the system’s product and process requirements. These product quality-related user requirements are based on product knowledge (CQAs), process knowledge (CPPs), regulatory requirements, and organization/site quality requirements. Writing a good user requirement for quality requirements involves several critical steps to ensure clarity, specificity, and effectiveness.

Understand the User Needs

Start by thoroughly understanding the user’s needs. This involves engaging with the end users or stakeholders to gather insights about their expectations, pain points, and the context in which the system will be used. This foundational step ensures that the requirements you develop are aligned with actual user needs and business goals.

Be Specific and Use Clear Language

Requirements should be specific and clearly stated to avoid ambiguity. Use simple, direct language and avoid technical jargon unless it is widely understood by all stakeholders. Define all terms and ensure that each requirement is phrased in a way that leaves no room for misinterpretation.

Make Requirements Measurable and Testable

Each requirement should be measurable and testable. This means stating requirements so one can verify whether they have been met. For example, instead of saying, “The system should load fast,” specify, “The system should load within 3 seconds when the number of simultaneous users is less than 10,000”.

Avoid Using Ambiguous Terms

Avoid terms open to interpretation, such as “user-friendly” or “fast.” If such terms are necessary, clearly define what they specifically mean in the context of your project. For instance, “user-friendly” is “the user can complete the desired task with no more than three clicks”.

Use the SMART Criteria

Employ the SMART criteria to ensure that each requirement is Specific, Measurable, Achievable, Relevant, and Time-bound. This approach helps set clear expectations and facilitates easier validation and verification of the requirements.

Make Requirements Concise but Comprehensive

While keeping each requirement concise and to the point is important, ensure all necessary details are included. Each requirement should be complete and provide enough detail for designers and developers to implement without making assumptions.

Prioritize Requirements

Not all requirements are equally important. Prioritize them based on their impact on the users and the business objectives. This helps manage the project scope and focuses on delivering maximum value.

It is good to categorize the user requirements here, such as:

Quality
Business
Health, Safety, and Environmental (HSE)

Review and Validate with Stakeholders

Review the requirements regularly with all stakeholders, including end-users, project managers, developers, and testers. This collaborative approach helps identify gaps or misunderstandings early in the project lifecycle.

Maintain a Living Document

Requirements might evolve as new information emerges or business needs change. Maintain your requirements document as a living document, regularly update it, and communicate changes to all stakeholders.

Use Models and Examples

Where applicable, use diagrams, mock-ups, or prototypes to complement the written requirements. Visual aids can help stakeholders better understand the requirements and provide feedback.

When writing user requirements for quality requirements, it’s crucial to avoid common pitfalls that can lead to misunderstandings, scope creep, and, ultimately, a product that does not meet the needs of the users or stakeholders. Here are some of the most common mistakes to avoid:

Ambiguity and Lack of Clarity

One of the most frequent errors in writing requirements is ambiguity. Requirements should be clear and concise, with no room for interpretation. Using vague terms like “user-friendly” or “fast” without specific definitions can lead to unmet expectations because different people may interpret these terms differently.

Incomplete Requirements

Another common issue is incomplete requirements that do not capture all necessary details or scenarios. This can result in features that do not fully address the users’ needs or require costly revisions later in development.

Overlooking Non-Functional Requirements

Focusing solely on what the system should do (functional requirements) without considering how it should perform (non-functional requirements), such as performance, security, and usability, can jeopardize the system’s effectiveness and user satisfaction.

Failure to Involve Stakeholders

Not involving all relevant stakeholders in the requirements gathering and validation process can lead to missing critical insights or requirements important to different user groups. This often results in a product that does not fully meet the needs of all its users.

Scope Creep

Without a clear definition of scope, projects can suffer from scope creep, where additional features and requirements are added without proper review, leading to delays and budget overruns. It’s important to have a well-defined project scope and a change management process in place.

Not Prioritizing Requirements

Not all requirements are equally important. Failing to prioritize requirements can misallocate resources and efforts on less critical features. Using prioritization techniques like MoSCoW (Must have, Should have, Could have, Won’t have this time) can help manage and focus efforts on what truly matters.

Lack of Validation and Verification

Skipping the validation (ensuring the product meets the intended use and needs of the stakeholders) and verification (ensuring the product meets the specified requirements) processes can lead to a final product not aligned with user needs and expectations.

Poor Documentation and Traceability

Inadequate documentation and lack of traceability can lead to confusion and errors during development. Maintaining detailed documentation and traceability from requirements through to implementation is crucial to ensure consistency and completeness.

Ignoring the Importance of Clear Communication

Effective communication is essential throughout the requirements process. Miscommunication can lead to incorrect or misunderstood requirements being developed. Regular, clear communication and documentation updates are necessary to keep all stakeholders aligned.

Not Considering the Testing of Requirements

Considering how requirements will be tested during the definition phase is important. This consideration helps ensure that requirements are testable and that the final product will meet them. Planning for testing early can also highlight any potential issues with clarity or feasibility of requirements.

Validation Planning – A visual approach

Validation Planning in the Quality System

Normally, when I write a blog post, I include the graphics, but I decided to separate them out to show some of my thought processes for designing slides.

Powerpoint Slides

I start with a nice slide that introduces the topic I am going to discuss, introducing the main concept, the Validation Master Plan (VMP), and the Validation Plan (VP.)

My next slide details the Validation Master Plan in more depth, covering the VMP’s core characteristics.

Then dive into the reasons for having a VMP.

Then cover the Validation plan characteristics.

These are still rather wordy, and I think the last slide can be divided into two. But I have a pretty good training here.

Validation Planning in the Quality System

The Validation Master Plan (VMP) and Validation Plan (VP) are integral to the validation process but differ significantly in their scope, detail, and application. The VMP provides a strategic and comprehensive outline for validation activities (often capturing the whole commissioning/qualification/validation lifecycle) across an organization, ensuring compliance and coherence. The VP, derived from the VMP, focuses on specific validation projects, detailing the procedures, responsibilities, and requirements needed to achieve compliance for those specific systems or projects.

Validation Master Plan (VMP)

A Validation Master Plan is a high-level document that outlines the overall validation strategy for an entire site or organization. It is comprehensive and covers all aspects of validation activities across various departments and systems within the organization. The VMP is designed to ensure that all components of the validation process are appropriately planned, executed, and maintained to meet regulatory compliance requirements.

Key characteristics of a VMP include:

Scope and Purpose: It defines the scope and objectives of all validation activities within the organization.
Strategy and Approach: It outlines the validation strategy and approach, including integrating Good Manufacturing Practices (GMP).
Responsibilities: It details the organizational structure and responsibilities for validation activities.
Documentation: It references all applicable protocols, reports, and related documents.
Compliance and Review: It includes compliance requirements and specifies the frequency of reviews and updates to ensure the plan remains current.

A Subvalidation Master Plan (sVMP) is a deep dive into a specific area or validation, such as the analytical method lifecycle.

The purpose of a Validation Master Plan (VMP) is multifaceted, primarily serving as a comprehensive document that outlines the strategy for validation activities within an organization. It is designed to ensure that all validation processes are conducted correctly and comply with regulatory standards.

Here are the key purposes of a VMP:

Documentation of Compliance Requirements: The VMP documents the organization’s compliance requirements, ensuring that all validation activities meet the necessary regulatory standards.
Strategic Planning: Acts as a roadmap for validation, detailing what, how, and when validation activities will be executed. This includes the lifecycle of the manufacturing validation process and integrates Good Manufacturing Practices (GMP).
Resource Planning: The VMP identifies anticipated resource needs and provides key input into scheduling project timelines, which is crucial for efficient validation execution.
Control and Direction: The VMP controls and defines different parts of the production process to ensure consistency over time and directs validation strategies for instruments and systems.
Risk Mitigation: The VMP helps mitigate risks associated with product manufacturing by outlining the validation approach and specific validation activities.
Educational Tool: The VMP informs and educates senior management and other stakeholders about the importance of validation in terms of its impact on product quality, thereby fostering an understanding and support for validation activities.
Regulatory Audit Support: It provides essential documentation regulators require during an audit, demonstrating the organization’s control over quality and compliance with GMPs.
Organizational Alignment: The VMP enables stakeholders within the organization to unify around the details of the validation strategy, eliminating ambiguity and justifying validation activities internally and externally.

The Validation Master Plan is crucial for ensuring that all aspects of validation are planned, executed, and documented in accordance with regulatory requirements and organizational goals. It serves as a compliance tool and a strategic guide for managing and conducting validation activities effectively.

Validation Plan (VP)

A Validation Plan (VP) is more specific and detailed than a VMP and is typically written for a particular validation project or system. The VP focuses on the specific validation activities for individual pieces of equipment, systems, or processes and is derived from the broader directives set out in the VMP.

Key characteristics of a VP include:

Detailed Scope and Objectives: It describes what is to be validated, the specific tasks to be performed, and the expected outcomes.
Project-Specific Details: These include timelines, specific procedures, and responsibilities for the particular validation project.
Risk Assessments and Requirements: It details the risk assessments, quality parameters, and regulatory requirements specific to the system or project being validated.

Differences and Relationship

Level of Detail: The VMP is a high-level document that provides an overarching framework and strategy for validation activities across an organization. In contrast, a VP is a detailed, project-specific document that outlines the execution of validation activities for specific systems or projects.

Purpose and Use: The VMP sets the stage for all validation efforts within an organization and ensures consistency and compliance with industry standards. The VP, derived from the VMP, focuses on specific validation tasks and how they will be accomplished.

Scope: While the VMP covers an organization’s entire validation program, a VP is limited to a particular project or system.

Periodic Review and Updates

A Validation Master Plan (VMP) should be reviewed and updated regularly to remain current and effective. The specific frequency of these reviews can vary depending on the organization’s needs, the complexity of the systems, and regulatory requirements. However, it is generally recommended that a VMP be reviewed at least annually.

This annual review is crucial to address any changes in the manufacturing process, regulatory updates, or modifications in the validation strategy. The review process should include evaluating the progress of validation activities, assessing the impact of any changes in the process or equipment, and updating the plan to reflect new or altered validation requirements.

Additionally, the VMP should be updated whenever significant changes occur that could affect the validation status of the systems or processes described in the plan. This could include major equipment upgrades, product design changes, or regulatory standard shifts.

Validation Plans (VP) should be revised based on changes in the project’s scope. Sometimes, a VP may be opened for an extended period of time for a complex project, in which case it should be evaluated for accuracy and completeness based on the project lifecycle.