Good Engineering Practices Under ASTM E2500

ASTM E2500 recognizes that Good Engineering Practices (GEP) are essential for pharmaceutical companies to ensure the consistent and reliable design, delivery, and operation of engineered systems in a manner suitable for their intended purpose.

Key Elements of Good Engineering Practices

  1. Risk Management: Applying systematic processes to identify, assess, and control risks throughout the lifecycle of engineered systems. This includes quality risk management focused on product quality and patient safety.
  2. Cost Management: Estimating, budgeting, monitoring and controlling costs for engineering projects and operations. This helps ensure projects deliver value and stay within budget constraints.
  3. Organization and Control: Establishing clear organizational structures, roles and responsibilities for engineering activities. Implementing monitoring and control mechanisms to track performance.
  4. Innovation and Continual Improvement: Fostering a culture of innovation and continuous improvement in engineering processes and systems.
  5. Lifecycle Management: Applying consistent processes for change management, issue management, and document control throughout a system’s lifecycle from design to decommissioning.
  6. Project Management: Following structured approaches for planning, executing and controlling engineering projects.
  7. Design Practices: Applying systematic processes for requirements definition, design development, review and qualification.
  8. Operational Support: Implementing asset management, calibration, maintenance and other practices to support systems during routine operations.

Key Steps for Implementation

  • Develop and document GEP policies, procedures and standards tailored to the company’s needs
  • Establish an Engineering Quality Process (EQP) to link GEP to the overall Pharmaceutical Quality System
  • Provide training on GEP principles and procedures to engineering staff
  • Implement risk-based approaches to focus efforts on critical systems and processes
  • Use structured project management methodologies for capital projects
  • Apply change control and issue management processes consistently
  • Maintain engineering documentation systems with appropriate controls
  • Conduct periodic audits and reviews of GEP implementation
  • Foster a culture of quality and continuous improvement in engineering
  • Ensure appropriate interfaces between engineering and quality/regulatory functions

The key is to develop a systematic, risk-based approach to GEP that is appropriate for the company’s size, products and operations. When properly implemented, GEP provides a foundation for regulatory compliance, operational efficiency and product quality in pharmaceutical manufacturing.

Invest in a Living, Breathing Engineering Quality Process (EQP)

The EQP establishes the formal connection between GEP and the Pharmaceutical Quality System it resides within, serving as the boundary between Quality oversight and engineering activities, particularly for implementing Quality Risk Management (QRM) based integrated Commissioning and Qualification (C&Q).

It should also provide an interface between engineering activities and other systems like business operations, health/safety/environment, or other site quality systems.

Based on the information provided in the document, here is a suggested table of contents for an Engineering Quality Process (EQP):

Table of Contents – Engineering Quality Process (EQP)

  1. Introduction
    1.1 Purpose
    1.2 Scope
    1.3 Definitions
  2. Application and Context
    2.1 Relationship to Pharmaceutical Quality System (PQS)
    2.2 Relationship to Good Engineering Practice (GEP)
    2.3 Interface with Quality Risk Management (QRM)
  3. EQP Elements
    3.1 Policies and Procedures for the Asset Lifecycle and GEPs
    3.2 Risk Assessment
    3.3 Change Management
    3.4 Document Control
    3.5 Training
    3.6 Auditing
  4. Deliverables
    4.1 GEP Documentation
    4.2 Risk Assessments
    4.3 Change Records
    4.4 Training Records
    4.5 Audit Reports
  5. Roles and Responsibilities
    5.1 Engineering
    5.2 Quality
    5.3 Operations
    5.4 Other Stakeholders
  6. EQP Implementation
    6.1 Establishing the EQP
    6.2 Maintaining the EQP
    6.3 Continuous Improvement
  7. References
  8. Appendices

Preventive Maintenance and Calibration

I find that folks often confuse preventive maintenance and calibration. While both processes contribute to overall asset reliability and performance, preventive maintenance focuses on maintaining general functionality, while calibration ensures measurement accuracy. In many cases, calibration can be considered a specialized form of preventive maintenance for measuring instruments. Some equipment may require preventive maintenance and calibration to ensure optimal performance and accuracy. Understanding the difference can be vital to the asset lifecycle. Misunderstanding can lead to poor asset control (and maybe an audit finding or two).

Preventive Maintenance

Preventive maintenance (PM) is a proactive approach to equipment and asset management involving regularly scheduled inspections, cleaning, lubrication, adjustments, repairs, and replacement parts. The goal is to prevent unexpected breakdowns and extend the lifespan of assets.

Purpose

  • Prevent equipment failures before they occur
  • Extend asset lifespan
  • Reduce unplanned downtime
  • Improve overall equipment reliability and efficiency

Types

  • Time-Based Maintenance (TBM): This involves performing maintenance tasks at fixed time intervals, regardless of the asset’s condition. For example, servicing equipment every 3 months or annually.
  • Usage-Based Maintenance: Maintenance is scheduled based on an asset’s actual utilization or operational hours.
  • Condition-Based Maintenance (CBM): This approach involves monitoring the actual condition of assets to determine when maintenance should be performed.
  • Predictive Maintenance (PdM): This uses data analysis tools and techniques to predict when an asset will likely fail and should be maintained.
  • Failure-finding maintenance (FFM) detects hidden failures, typically in protective devices and backup systems.
  • Risk-Based Maintenance (RBM): Maintenance activities are prioritized based on the risk assessment of equipment downtime and its impact.
  • Prescriptive Maintenance: This predicts when failure will occur, analyzes why, and determines different options to mitigate risks.
  • Meter-Based Maintenance: Similar to usage-based maintenance, this type schedules tasks based on equipment meter readings.

These different types of preventive maintenance can be used individually or in combination, depending on the organization’s specific needs, the criticality of the assets, and the available resources. The goal is to prevent unexpected breakdowns, extend equipment life, and optimize maintenance costs

Key components

  • Regular inspections
  • Cleaning and lubrication
  • Adjustments and calibrations
  • Minor repairs and parts replacements

Benefits

  • Reduced unexpected breakdowns and associated costs
  • Improved equipment reliability and performance
  • Extended asset lifespan
  • Enhanced safety for operators and employees
  • Better compliance with warranties and regulations
  • Increased productivity due to reduced downtime

Implementation

  • Identify critical assets requiring PM
  • Develop maintenance schedules based on manufacturer recommendations and historical data.
  • Use preventive maintenance software or CMMS (Computerized Maintenance Management System) to manage schedules and work orders.
  • Train maintenance staff on PM procedures
  • Regularly review and optimize the PM program.

Calibration

Calibration is the act or process of comparing an instrument’s measurements to be calibrated against a traceable reference standard of known accuracy. It involves establishing a relationship between the measurement values of the device under test and those of the calibration standard.

Purpose

  • To ensure the accuracy and precision of measuring instruments
  • To determine and minimize measurement errors
  • To maintain the reliability of measurement results

Process:

  • Comparing the device under test with a calibration standard
  • Documenting the comparison results
  • Adjusting the device if necessary (although, strictly speaking, adjustment is not part of the formal definition of calibration)

Key components

  1. Traceability: Calibration standards should be traceable through an unbroken chain of comparisons to national or international standards, each with stated uncertainties.
  2. Uncertainty: Calibration includes the concept of measurement uncertainty, which defines the range of probable values of the measurand and indicates the “goodness” of the calibration process.
  3. Applications: Calibration is used in various fields, including metrology, engineering, science, and industry. It applies to a wide range of measuring instruments, from simple thermometers to complex electronic devices.
  4. Frequency: Instruments may require calibration for various reasons, including:
  • When new or after repairs
  • After a specified time period or usage
  • Before critical measurements
  • After exposure to conditions that might affect accuracy

Documentation: Calibration procedures are typically documented in specific test methods, capturing all the steps needed to perform a successful calibration.

      AspectPreventive MaintenanceCalibration
      PurposePrevent equipment failures and extend asset lifespanEnsure accuracy and precision of measuring instruments
      ScopeWide range of activities to keep equipment in good working conditionFocused on measurement accuracy of instruments and devices
      FrequencyRegular schedule based on time intervals or usageSpecific intervals, after repairs, or when accuracy is critical
      OutcomeImproved reliability, reduced downtime, extended asset lifeAccurate and reliable measurements within acceptable tolerances
      ProcessCleaning, lubrication, parts replacement, visual inspectionsComparing readings to known standards, making adjustments
      ApplicabilityWide range of equipment and machinerySpecific to measuring instruments and devices
      comparison of the key differences between preventive maintenance and calibration