The FDA initiative Pharmaceutical Quality for the 21st Century - A Risk Based Approach introduced in 2002 is driving the biotech/pharma industry to a new risk-based validation paradigm.
The challenge is to provide a "science-based" and "risk-based" approach to testing.
It is not just that "risk" is considered. The testing should also be based on the "science" of the process, and testing should "challenge" the scientific design assumptions.
The "risk-based" approach maximizes risk mitigation for patients. Thus it might either minimize a risk or mitigate it.
One of the goals is the elimination of unnecessary IQ, OQ, and PQ deviations. Many of these are just "paper chases". If a deviation does not actually lead to a change in the system (or perhaps in documentation or training), then it hasn’t done anything to improve the system or reduce patient risk. In one sense this test is a waste because the patient outcome will be the same even if the test was never performed. If nothing is changed, the outcome is the same whether there is one sentence or 50 pages of deviation documentation. The goal then should be to quickly determine whether a change is required. If not, then quickly move on.
"Science-based" testing implies having an understanding of the internal characteristics of a system. The “black box” must be “opened” (either by the vendor’s tests or by user tests). Control Systems theory spent much of the first half of the 20th Century learning that complex technology can not be successfully employed without understanding the internal characteristics of the “black box” (technology perfected by the MIT Servomechanisms Laboratory and the NDRC during World War II).
Duplicate testing (e.g., repeating the same tests at the vendor and user sites) is not more or better testing - just duplication. Of course some tests (e.g., Installation Qualifications) may legitimately need to be repeated for each item or site (because an installation mistake can occur after 999 successful installations).Arbitrary testing (without a scientific basis for the tests conducted) will probably no longer be accepted as valid best practice.
Once upon a time, "alchemy" was considered to be real science and “magic spells” a valid lab technique. The witches in Macbeth were perhaps doing primitive biochemistry.
"Science-Based" testing requires the use of meaningful tests developed by, and with results evaluated by, subject matter experts. Otherwise the testing has little more scientific validity than the use of “magic spells”. Traditional validation has worked fairly well because dedicated, experienced, knowledgeable people have implicitly built good tests into their protocols. Often this has been in spite of, rather than a result of, the validation methodology.
As systems become more complex, industry can’t rely on this implicit coverage to catch everything.
The new "science-based" and "risk-based" approaches are necessary to reduce costs and maintain quality.
This new approach is described in
- ASTM E2500-07 Standard Guide for Specification, Design, and Verification of Pharmaceutical and Biopharmaceutical Manufacturing Systems and Equipment
- ISPE GAMP(r) 5: A Risk-Based Approach to Compliant GxP Computerized Systems
However, this type of analysis has been a feature of traditional/conventional engineering (e.g., civil, structural, mechanical, electrical) development for decades.
GSC has been including "Design for Verification/Validation" in its biotech/pharma products and projects since the 1980's. Forensic products have included concepts that anticipate legal challenges during courtroom cross-examination.
Let GSC help you transition to this new validation paradigm on your next project.
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Flyer about Risk-based Validation (PDF)
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