Facility design and control considerations for mitigating viral contamination risk is a holistic approach to facility design and controls, considering all potential routes of viral introduction and spread. A living risk management approach should be taken to identify vulnerabilities and implement appropriate mitigation measures.
Facility Considerations
Segregation of areas: Separate areas for cell banking, small-scale and large-scale upstream cell culture/fermentation, downstream processing, media/buffer preparation, materials management, corridors, and ancillary rooms (e.g. cold rooms, freezer rooms, storage areas).
Traffic flow: Control and minimize traffic flow of materials, personnel, equipment, and air within and between areas and corridors. Implement room segregation strategies.
Air handling systems: Design HVAC systems to maintain appropriate air quality and prevent cross-contamination between areas. Use HEPA filtration where needed.
Room Classifications
For open operations:
Open sterile and aseptic operations must be performed in an environment where the probability of contamination is acceptably low, i.e. an environment meeting the bioburden requirements for a Grade A space.
Open bioburden-controlled processing may be performed in an ISO Grade 8/EU Grade C or EU Grade D environment as appropriate for the unit operation.
Open aseptic operations require a Grade A environment. Maintaining a Grade A cleanroom for large bioreactors is not feasible.
For closed operations:
Closed systems do not require cleanroom environments. ICH Q7 states that closed or contained systems can be located outdoors if they provide adequate protection of the material.
When all equipment used to manufacture a product is closed, the surrounding environment becomes less critical. The cleanroom requirements should be based on a business risk assessment and could be categorized as unclassified.
Housing a closed aseptic process in a Grade C or Grade B cleanroom would not mitigate contamination risk compared to an unclassified environment.
For low bioburden closed operations, the manufacturing environment can be unclassified.
Equipment Considerations
Closed vs. open processing: Utilize closed processing operations where possible to prevent introduction/re-introduction of viruses. Implement additional controls for open processing steps.
Closure Level
Description
Closed Equipment
Single use, never been used, such as irradiated and autoclaved assembles; connections are made using sterile connectors or tube wielders/sealers
Functionally closed equipment: cleaned and sterilized
Open vessels or connections that undergo cleaning and sterilization prior to use and are then aseptically connected. The connection is then sterilized after being closed and remains closed during use.
Functionally closed equipment: cleaned and sanitized
Open vessels or connections that are CIPed including bioburden reducing flushes, but not sterilized before use and remain closed during use
Open
Connections open to the environment without subsequent cleaning, sanitization or sterilization prior to use
Operational Practices
Personnel controls: Implement rigorous training programs, safety policies and procedures for personnel working in critical areas.
Cleaning and sanitization: Establish frequent and thorough cleaning protocols for facilities, equipment, and processing areas using appropriate cleaning agents effective against viruses.
Material and equipment flow: Define procedures for disinfection and transfer of materials and equipment between areas to prevent contamination spread.
Storage practices: Implement proper storage procedures for product contact materials, intermediates, buffers, etc. Control access to cold rooms and freezers.
Additional Controls
Pest control: Implement comprehensive pest control strategies both inside and outside facilities, including regular treatments and monitoring.
Water systems: Design and maintain water systems to prevent microbial growth and contamination.
Process gases: Use appropriate filtration for process air and gases.
Organizational competencies are the skills, abilities, and knowledge that allow an organization to be successful in achieving its goals. They form the foundation of an organization’s culture, values, and strategy.
Organizational competencies can be broadly divided into two main categories:
Technical Competencies
Non-Technical Competencies (also called General Competencies)
Technical Competencies
Technical competencies are specific skills and knowledge required to perform particular jobs or functions within an organization. They are directly related to the core business activities and technical aspects of the work. For technical competencies:
They cover various fields of expertise relevant to the specific work carried out in the organization
They are at the heart of what the organizational employees do
They allow an organization to produce products or services efficiently and effectively
They often require ongoing training and reinforcement to stay current
Non-Technical Competencies
Non-technical competencies, also known as general competencies or soft skills, are broader skills and attributes that are important across various roles and functions. They include:
These competencies are crucial for effective interaction, collaboration, and overall organizational success.
Organizational Competencies for Validation (an example)
For an organization focusing on validation the following competencies would be particularly relevant:
Technical Competencies
Skill Area
Key Aspects
Proficiency Levels
Beginner
Intermediate
Advanced
Expert
General CQV Principles
Modern process validation and
guidance
Validation design and how to
reduce variability
Able
to review a basic protocol
Able
to review/approve Validation document deliverables.
Understands
the importance of a well-defined URS.
Able to be QEV lead in a small
project
Able to answer questions and
guide others in QEV
Participates in process
improvement
Able to review and approve
RTM/SRs
Able
to be QEV lead in a large project project
Trains
and mentors others in QEV
Leads
process improvement initiatives
Able
to provide Quality oversight on the creation of Validation Plans for complex
systems and/or projects
Sets
overall CQV strategy
Recognized
as an expert outside of JEB
Facilities
and Utilities
Oversee Facilities, HVAC and
Controlled Environments
Pharma Water and WFI
Pure Steam, Compressed Air,
Medical Gases
Understands
the principles and GMP requirements
Applies the principles,
activities, and deliverables that constitute an efficient and acceptable
approach to demonstrating facility fitness-for-use/qualification
Guide
the Design to Qualification Process for new facilities/utilities or the
expansion of existing facilities/utilities
Able
to establish best practices
Systems
and Equipment
Equipment, including Lab
equipment
Understands
the principles and GMP requirements
Principles, activities, and
deliverables that constitute an efficient and acceptable approach to
demonstrating equipment fitness-for-use/qualification
Able
to provide overall strategy for large projects
Able
to be QEV lead on complex systems and equipment.
Able
to establish best practices
Computer
Systems and Data Integrity
Computer lifecycle, including
validation
Understands
the principles and GMP requirements
Able to review CSV documents
Apply GAMP5 risk
based approach
Day-to-day quality oversight
Able
to provide overall strategy for a risk based GAMP5 approach to computer
system quality
Able
to establish best practices
Asset Lifecycle
Quality
oversight and decision making in the lifecycle asset lifecycle: Plan,
acquire, use, maintain, and dispose of assets
Can
use CMMS to look up Calibrations, Cal schedules and PM schedules
Quality
oversight of asset lifecycle decisions
Able
to provide oversight on Cal/PM frequency
Able
to assess impact to validated state for corrective WO’s.
Able
to establish asset lifecycle for new equipment classes
Establish
risk-based PM for new asset classes
verification
Establish
asset lifecycle approach
Serves
as the organization’s authority on GMP requirements related to asset
management in biotech facilities
Cleaning, Sanitization and Sterilization Validation
Evaluate
and execute cleaning practices, limit calculations, scientific rationales,
and validation documents
Manage
the challenges of multi-product facilities in the establishment of limits,
determination of validation strategies, and maintaining the validated state
Differentiate
the requirements for cleaning and sterilization validation when using manual,
semi-automatic, and automatic cleaning technologies
Review
protocols
Identify
and characterize potential residues including product, processing aids,
cleaning agents, and adventitious agents
Understand
Sterilization principles and requirements
Create,
review and approve scientifically sound rationales, validation protocols, and
reports
Manage
and remediate the pitfalls inherent in cleaning after the production of
biopharmaceutical and pharmaceutical products
Define
cleaning/sterilization validation strategy
Implements
a lifecycle approach to validation, ensuring continued process verification
Implements
a lifecycle approach to validation, ensuring continued process verification
Quality Risk Management
Apply
QRM principles according to Q9
Understands
basic risk assessment principles
Can
identify potential hazards and risks
Familiar
with risk matrices and scoring methods
Participate
in a risk assessment
Conducts
thorough risk assessments using established methodologies
Analyzes
risks quantitatively and qualitatively
Prioritizes
risks based on likelihood and impact
Determine
appropriate tools
Establish
risk-based decision-making tools
Leads
complex risk assessments across multiple areas
Develops
new risk assessment methodologies
Provides
expert guidance on risk analysis techniques
Serves
as the organization’s authority on regulatory requirements and expectations
related to quality risk management
Builds
a proactive risk culture across the organization, fostering risk awareness at
all levels
Process Validation
Demonstrating
that the manufacturing process can consistently produce a product that meets
predetermined specifications and quality attributes.
Understanding
of GMP principles and regulatory requirements
Basic
understanding of GMP principles and regulatory requirements
Can
independently write, approve and execute validation protocols for routine
processes
Ability to develop validation master plans
and protocols
Understanding
of critical process parameters (CPPs) and critical quality attributes (CQAs)
Expertise
in designing and implementing complex validation strategies
Ability
to troubleshoot and resolve validation issues
Deep
understanding of regulatory expectations and industry best practices
Leads
cross-functional validation teams for high-impact projects
Develops
innovative validation approaches for novel bioprocesses
Serves
as an organizational authority on validation matters and regulatory
interactions
Reflective learning is a powerful tool that organizations can leverage to build competency and drive continuous improvement. At its core, this approach involves actively analyzing and evaluating experiences and learning processes to enhance understanding and performance across all levels of the organization.
The process of reflective learning begins with individuals and teams taking the time to step back and critically examine their actions, decisions, and outcomes. This introspection allows them to identify what worked well, what didn’t, and why. By doing so, they can uncover valuable insights that might otherwise go unnoticed in the day-to-day rush of business activities.
One of the key benefits of reflective learning is its ability to transform tacit knowledge into explicit knowledge. Tacit knowledge is the unspoken, intuitive understanding that individuals develop through experience. By reflecting on and articulating these insights, organizations can capture and share this valuable wisdom, making it accessible to others and fostering a culture of collective learning.
To implement reflective learning effectively, organizations should create structured opportunities for reflection. This might include regular debriefing sessions after projects, dedicated time for personal reflection, or the use of learning journals. Additionally, leaders should model reflective practices and encourage open and honest discussions about both successes and failures.
It’s important to note that reflective learning is not just about looking back; it’s also about looking forward. The insights gained through reflection should be used to inform future actions and strategies. This forward-thinking approach helps organizations to be more adaptable and responsive to changing circumstances, ultimately leading to improved performance and innovation.
By embracing reflective learning as a core organizational practice, companies can create a dynamic environment where continuous learning and improvement become ingrained in the culture. This not only enhances individual and team performance but also contributes to the overall resilience and competitiveness of the organization in an ever-changing business landscape.
Implement Regular After-Action Reviews
After-action reviews (AARs) or Lessons Learned are critical to provide a structured way for teams to reflect on projects, initiatives, or events. To implement effective AARs:
Schedule them immediately after key milestones or project completions
Focus on what was planned, what actually happened, why there were differences, and what can be learned
Encourage open and honest discussion without blame
Document key insights and action items
Create a Supportive Environment for Reflection
Foster a culture that values and encourages reflection:
Provide dedicated time and space for individual and group reflection
Model reflective practices at the leadership level
Recognize and reward insights gained through reflection
By systematically implementing these practices, organizations can build a strong competency in reflective learning, leading to improved decision-making, innovation, and overall performance. Utilizing a model always helps.
Kolb’s Reflective Model
Kolb’s reflective model, also known as Kolb’s experiential learning cycle, is a widely used framework for understanding how people learn from experience. The model consists of four stages that form a continuous cycle of learning:
The Four Stages of Kolb’s Reflective Model
Concrete Experience: This is the stage where the learner actively experiences an activity or situation. It involves direct, hands-on involvement in a new experience or a reinterpretation of an existing experience.
Reflective Observation: In this stage, the learner reflects on and reviews the experience. They think about what happened, considering their feelings and the links to their existing knowledge and skills.
Abstract Conceptualization: Here, the learner forms new ideas or modifies existing abstract concepts based on their reflections. This stage involves analyzing the experience and drawing conclusions about what was learned.
Active Experimentation: In the final stage, the learner applies their new knowledge and tests it in new situations. This involves planning how to put the new learning into practice and experimenting with new approaches.
Create Opportunities for Concrete Experiences: Provide employees with hands-on learning experiences, such as job rotations, simulations, or real-world projects.
Encourage Reflection: Set up regular reflection sessions or debriefings after significant experiences. Encourage employees to keep learning journals or participate in group discussions to share their observations.
Facilitate Conceptualization: Provide resources and support for employees to analyze their experiences and form new concepts. This could involve training sessions, mentoring programs, or access to relevant literature and research.
Support Active Experimentation: Create a safe environment for employees to apply their new knowledge and skills. Encourage innovation and provide opportunities for employees to test new ideas in their work.
Integrate the Model into Learning Programs: Design training and development programs that incorporate all four stages of Kolb’s cycle, ensuring a comprehensive learning experience.
Personalize Learning: Recognize that individuals may have preferences for different stages of the cycle. Offer diverse learning opportunities to cater to various learning styles.
Measure and Iterate: Regularly assess the effectiveness of knowledge management initiatives based on Kolb’s model. Use feedback and results to continuously improve the learning process.
By incorporating Kolb’s reflective model into knowledge management practices, we can create a more holistic and effective approach to learning and development. This can lead to improved knowledge retention, better application of learning to real-world situations, and a more adaptable and skilled workforce.
– Expands on Kolb’s work – Recognizes various responses to potential learning situations
Backward Design
Grant Wiggins, Jay McTighe
1. Identify desired results 2. Determine acceptable evidence 3. Plan learning experiences and instruction
– Starts with learning outcomes – Focuses on designing effective learning experiences
Applying the Experiential Learning Model to Validation Competencies
To apply Kolb’s experiential learning model to building an organization’s competency for validation, we can structure the process as follows:
Concrete Experience
Have employees participate in actual validation activities or simulations
Provide hands-on training sessions on validation techniques and tools
Assign validation tasks to teams in real projects
Reflective Observation
Conduct debriefing sessions after validation activities
Encourage employees to keep validation journals or logs
Facilitate group discussions to share experiences and observations
Review validation results and outcomes as a team
Abstract Conceptualization
Offer formal training on validation principles, methodologies, and best practices
Encourage employees to develop validation frameworks or models based on their experiences
Analyze validation case studies from other organizations or industries
Create validation guidelines and standard operating procedures
Active Experimentation
Implement new validation approaches in upcoming projects
Encourage employees to propose and test innovative validation methods
Set up pilot programs to trial new validation tools or techniques
Assign employees to different types of validation projects to broaden their skills
To make this process continuous and effective:
Create a validation competency framework with clear learning objectives and skill levels
Develop a mentoring program where experienced team members guide less experienced colleagues
Establish regular knowledge-sharing sessions focused on validation topics
Implement a system for capturing and disseminating lessons learned from validation activities
Use technology platforms to support collaborative learning and information sharing about validation
Regularly assess and update the organization’s validation processes based on learning outcomes
Encourage cross-functional teams to work on validation projects to broaden perspectives
Partner with external experts or organizations to bring in fresh insights and best practices
Recognize and reward employees who demonstrate growth in validation competencies
Integrate validation competency development into performance reviews and career progression paths
By systematically applying Kolb’s model, we can create a robust learning environment that continuously improves our validation capabilities. This approach ensures that employees not only gain theoretical knowledge but also practical experience, leading to a more competent and adaptable workforce.
I hasn’t been difficult to notice that a whole lot of biological new drug applications have been rejected in the last few years, many for CMC reasons. Recently CDER Director Patrizia Cavazzoni spoke on the matter at a recent at a Duke University and FDA event at the National Press Club iin the video above.
“Our standards have not changed. We have exactly the same standards as we had in 2018 and 2019,” she said, before going on to talk about how the quality related issues the FDA is seeing: contamination, overall oversight, manufacturing controls or insufficient quality management systems.
Max Van Tassell, a senior pharmaceutical quality assessor in CDER’s Office of Pharmaceutical Quality, provided insights from analyzing 100 complete response letters (CRLs) for Biologics License Applications (BLAs) issued between 2014 and 2024. He noted that facility-related deficiencies in CRLs typically stem from inadequate demonstration that proposed corrective and preventive actions would effectively mitigate risks identified during on-site inspections.
It should be a key takeaway from this presentation that:
When undertaking a project to enhance your validation program, it’s crucial to have a robust method for measuring success. This is especially important as you aim to increase maturity and address organizational challenges, with a significant focus on training and personnel qualification. The Kirkpatrick model, originally designed for evaluating training programs, can be effectively adapted to assess the success of your validation program improvements.
Level 1: Reaction
This level measures how participants react to the validation program.
Survey validation team members on their satisfaction with the validation approach
Gather feedback on the clarity of risk-based validation concepts
Assess perceived relevance and applicability of the new validation methodology
Level 2: Learning
This level evaluates the knowledge and skills acquired.
Conduct assessments to measure understanding of key principles
Test ability to perform risk assessments and develop verification strategies
Evaluate comprehension of good engineering practices (GEP) and their integration into validation activities
Level 3: Behavior
This level examines how participants apply what they’ve learned on the job.
Observe validation team members implementing risk-based approaches in actual projects
Review documentation to ensure proper application of methodologies and assess the quality of user requirements, risk assessments, and verification plans. This is where I would use a rubric.
Create some key behavior indicators, such as right-the-first time.
I use IMPACT as a tool here.
And then come up with a set of leading and lagging quality and behavioral indicators.
Leading
Measure and report attendance at risk assessments and project team meetings
Number of employee/team improvement suggestions implemented
This level measures the impact on the organization.
Track reduction in validation cycle times and associated costs
Monitor improvements in product quality and reduction in deviations
Assess regulatory inspection outcomes and feedback on validation approach
Evaluate overall efficiency gains in the validation process
By applying the Kirkpatrick Model to a validation program improvements we can systematically evaluate the effectiveness of their implementation and identify areas for continuous improvement.
A rubric is a tool used primarily in educational settings to evaluate and assess student performance. It provides a clear set of criteria and standards that describe varying levels of quality for a specific assignment or task. Rubrics are designed to ensure consistency and objectivity in grading and feedback, making them a valuable resource for both teachers and students.
Rubrics are useful in assessing competencies and skills within organizations, providing a structured way to evaluate strengths and weaknesses, which makes them perfect for knowledge based activities to gauge appropriate training and execution. They can really help demonstrate that an outcome is a good one.
Key Features of a Rubric
Criteria: Rubrics list specific criteria that are important for the assignment. These criteria outline what is expected from the intended work, such as clarity, organization, and mechanics in a writing assignment.
Performance Levels: Rubrics define different levels of achievement for each criterion, often using descriptive language (e.g., excellent, good, needs improvement) or numerical scores (e.g., 4, 3, 2, 1).
Feedback and Guidance: Rubrics provide detailed feedback, helping individuals understand their strengths and areas for improvement. This feedback can guide executors in revising their work to meet learning objectives more effectively.
Types of Rubrics
Analytic Rubrics: These break down the assignment into several components, each with its own set of criteria and performance levels. This type provides detailed feedback on specific areas of the work.
Holistic Rubrics: These assess the work as a whole rather than individual components. They provide a single overall score based on the general quality of the work.
Single-Point Rubrics: These focus on a single level of performance for each criterion, highlighting areas that meet expectations and those that need improvement.
An example from a deviation rubric
Benefits of Using Rubrics
Clarity and Consistency: Rubrics help clarify expectations for students, ensuring they understand what is required to be good. They also promote consistency across activities.
Self-Assessment: Rubrics encourage individuals to reflect on their own work and understand the standards they need to meet. This can lead to improved learning outcomes as individuals become more aware of their progress and areas needing improvement.
I love rubrics. They are great for all quality systems. They can be used for on-the-job training, for record writing and review, for re-qualifications. By creatin rubrics you define what good looks like by providing a structured and objective framework that improves clarity, consistency, and specificity in evaluations. It holds both the writer and the reviewer accountable.