Quality Assurance

Change Control Procedure

Change Control, Purpose:

Change Control, The purpose of this SOP is to define the requirements that all planned changes which have potential to impact the quality of the product are controlled through a systematic, standard and effective approach. This approach of controlling change will ensure:
[][]Safeguard of quality (Safety and efficacy of the product)
[][]Ensure compliance with legal and regulatory requirements
[][]Traceability of changes made through the lifecycle of a product or facility
[][]Assessment and management of all risks (Quality, Business and EHS) associated with the implementation of changes.

Change Control, Scope:

Applies to all planned changes (including emergency/temporary/permanent changes) that have the potential to affect GMP, Product Quality, Safety, Efficacy, Stability, EHS and the Validation status of Processes, Facilities and Systems of General Block and Sterile Block at XX Pharmaceuticals Ltd.
[][]Few examples of planned changes within the scope of this SOP are:

Production

GMP Documents :
Validation protocol.

Processes :

[][]Manufacturing or Packaging processes
[][]Process (time, mixing speed, temperature, order of addition etc).
[][]Removal/replacement/addition of API or excipients (Formula amounts, overage)
[][]Batch size, production scale
[][]In process controls
[][]Cleaning methods or processes.
[][]Coating weight of tablets, weight of capsule shell, fill weights or volumes.
[][]Any trial (machine/process) work.
[][]Shelf life, expiry (including hold times at intermediate production stages).

Manufacturing Facilities & Equipment :

[][]Equipment, critical device.
[][]Manufacturing/packaging suite/ location.
[][]Introduction of new product/ machinery.
[][]Change of critical spare parts of machineries.
[][]Product & materials
[][]Shape or dimension of product.
[][]Imprints/embossing or other markings on product.
[][]Colour of the product
[][]Packaging Components
[][]Intermediate/Primary/Secondary packs
[][]Product contact components
[][]Disinfectants / Detergents
[][]Product Contact Lubricants

Quality Assurance

Control Documents :

[][]Specification (product, API, excipients, packaging) and Control Direction
[][]Stability protocol.
[][]Artworks.
[][]Qualification protocol
[][]Technical agreements with third party or any service provider.
[][]Colour shades.
[][]Approved supplier list

Methods & procedure :

[][]Sampling or Testing processes
[][]Test parameters (time, run time, temperature, solvent etc).
[][]Removal/replacement/addition of tests.

[][]Environmental monitoring system.
[][]Microbiological monitoring location, frequency and limits

Facilities & Equipment :

[][]Laboratory equipment.
[][]Critical spare parts of equipment.
[][]Introduction of new equipment.

Supplier :

[][]Supplier of API, excipients or packaging components
[][]Change in supplier, manufacturing location, material, pack size or mode of packaging.

Engineering Services

GMP Documents :

[][]Qualification protocol
[][]Drawing & facility layout
[][]Master Calibration list

Facilities & Equipment :

[][]New/additional location for assembly, manufacturing, packaging and testing.
[][]Building Management e.g. Building Management system, pest control.
[][]Calibration frequency or limits/tolerance.
[][]Utilities such as facilities cleaning, compressed air, vacuum, electricity and water.
[][]Building / structural work (e.g. new facility, or installation of utility equipment).
[][]Any change in equipment design
[][]Substitution of any engineering parts.

Services /Utilities :

[][]Water Generation and Distribution
[][]Steam Generation and Distribution
[][]HVAC, vacuum and compressed air modification

Others

[][]Any change relating to a product manufactured at third party
[][]Change relating to product/technology transfer.
[][]Any activity that have the potential to affect EHS
[][]Format change of any controlled documents such as Batch Manufacturing Record, Batch Packaging Record & Control Direction

The process does not apply to the following as these are managed separately by individual SOPs:

[][]Any unplanned incident/changes
[][]Engineering replacement with identical/equivalent parts (procured from the approved sources having the same functionality , specification and serial number)
[][]Routine servicing or preventive maintenance.
[][]Changes during Product Development/trial
[][]Routine revision of any controlled documents (e.g. SOP, BMR, Test methods etc)
[][]SOP/BMR/BPR change to comply with any requirements where the reason and history of changes are mentioned in the revision details.
[][]Like for Like Change

Definitions / Abbreviation:

[][]Change Control Procedure: A formal controlled documented process by which qualified representatives from appropriate discipline, review, propose and make changes to an approved system.
[][]Temporary change: A change (departure from any established procedure/system/process) initiated for the evaluation of proposed procedure/system/process, which has been taken with prior approval to achieve the desired output, allowed for one time change and limited to a particular batch or campaign batches. For example change in manufacturing equipment.
[][]Permanent change: A change initiated based upon scientific rational or historical cGMP data or data generated through temporary changes.

[][]Minor Change: A change unlikely to have a detectable impact on the critical attributes of a system, process, material, product or procedure. (For example: equivalent rewording of instructions or batch record format changes
[][]Major Change: A change that could have a significant impact on the critical quality attributes of a system, process, material, product or procedure. (For example: packaging design change, order of addition of components, mixing parameters in a process).
[][]Critical Change: A change that would be likely to have a significant impact on the critical attributes of a system, process, materials, product or procedure. (For example: a change in critical equipment or change in manufacturing site.)

[][]Planned Change: A change that is planned and given the associated lead time.
[][]Unplanned Change: An unplanned change is a change that occurs unexpectedly on an individual batch or process and is documented via the deviation system.
[][]Engineering replacement with identical parts: Parts that meet the following criteria are known as identical parts and replacement for these Change Control is not required:
=>Same functionality.
=>Same specification.
=>Same manufacturer.
=>Same part number.
[][]Engineering replacement with equivalent parts: Parts that meet the following criteria are known as equivalent parts and replacement for these Change Control is not required:
=>Same functionality.
=>Same specification.
=>Could be a different manufacturer.
=>Could be a different part number from the same manufacturer.

Responsibilities:

[][]The roles and responsibility is as follows:

Concern Department (change initiator)

[][]To propose the change.
[][]Assess if the change is within scope of the change control process.
[][]Provide sufficient supporting information necessary for initial assessment of the change.
[][]To intimate Quality Compliance for issuance of the change control form.
[][]To make necessary entries in the change control form.
[][]To take approval of Department Head and send the form to Quality Compliance for review.
[][]To take approval from Manager, Quality Assurance
[][]To take execution approval from Manager, Quality Assurance prior to execute the change.
[][]To generate relevant supporting data in consultation with related department for compliance of the recommendation provided in reference to change implemented.

Quality Assurance Personnel

[][]To make necessary entries in the change control register.
[][]To issue change control form after assigning change control number and making necessary entries.
[][]To review the change control form and provide the recommendations as impact analysis against the change initiated.
[][]To review actionable mentioned in the impact analysis that are required to be in place prior to implement proposed change and to provide execution approval.
[][]To send the change control for approval to Manager, Quality Assurance in case of impact on regulatory aspects and to obtain approval.
[][]To intimate third party for changes related to their products.
[][]To intimate the changes related to customer, in accordance with the provision as defined in the quality agreement.
[][]To generate and issue corrective action and preventive action (CAPA) form if required for recommendations provided to complete the activity in concern to change implemented.
[][]To review and evaluate the data / assessment report generated during study in consultation with Manager, Quality Assurance.
[][]To close the change control after ensuring implementation and to make necessary entries in change control register.
[][]To retain all change controls in Quality Assurance department.
[][]To circulate a list of change controls which are in issued status for follow up and progress review. The list shall be circulated on monthly basis

Concern Department Head

[][]To review and evaluate filled change control form and give approval.
[][]To recommend possible impact in change control form.
[][]To send the filled change control form for review to Quality Compliance.
[][]To revise the document in consultation with all respective department.
[][]To arrange and ensure generation of the supporting data/ assessment report to comply the recommendations.
[][]To take execution approval from Manager, Quality Assurance prior to execution of the changes.

Manager, Quality Assurance

[][]To provide recommendations / review the adequacy of impact analysis for recommendation provided in respect to change initiated.
[][]To decide change review level of changes proposed.
[][]To approve the change control.
[][]Ensure all relevant changes are managed according to SOP.
[][]Trending of change controls.
[][]Assess, review and approve a proposed change for implementation

Procedure:

Checking of scope for Planned Change:

[][]Before initiating the process the initiator will check if the planned change is within the scope defined in this SOP. If there is any doubt about the scope of change then the initiator will discuss with Quality Assurance Department.
[][]Before initiating the proposal the initiator will check whether any change proposal on the similar subject (Product/equipment/process/materials) still remains open that need to be implemented.

Procedure for Change Initiation :

[][]Upon identification of need of change(s), concern person shall ask Quality Assurance personnel to issue “Change Control Form” (Refer Annexure-I).
[][]Quality Assurance personnel shall make following entries in “Change Control Form” while issuance and similar entries in “Change Control Register” (Refer Annexure-II).
[][]Change Control No. :
[][]Change control No. shall be assigned as per below explained numbering system.
[][]Change control number shall be changed every year.

[][]Change control number shall be alphanumeric system containing 11 characters. Numbering breakdown is as follows: CCyy/Area code/xxx.
Area Code is as follows:
=>General Issues GI, Common issues that affects more than one area.
=>General Block : GB
=>Sterile Block : SB
=>For example: CCXX/GB/001.

[][]The first two alphabets shall stand for Change control
[][]Next two numeric characters shall stand for year code XX shall denote year 20XX.
[][]Next character is slash (/), followed by two capital letter stands for area code of General Block at XX Pharmaceuticals Ltd.
[][]Next character is slash (/), followed by three numerical shall stand for serial number, which shall start every year from 001. For example first change control no CCXX/GB/001 and second CCXX/GB/002, third CCXX/GB/003 ….. for any change.
[][]In case of Sterile block, Change control number shall be SC13/CB/001 and so on. Two capital letter CB stands for area code of Sterile block at XX Pharmaceuticals Ltd.

[][]The number will be unique; if proposal is withdrawn/ rejected the same number will never be used again.
[][]Initiator: Name of the person to whom the change control is issued shall be written.
[][]Originating Department: The name of the department to whom the change control is issued shall be written.
[][]Issued By: The Quality Assurance Personnel who is issuing the change control shall put his/her initial with signature.
[][]Date of Issuance: Date on which the change control is issued shall be written.
[][]Product / Material / Document Name / SOP Title: Name of product/ material/ document title whatever applicable shall be mentioned for which the change is initiated and rest shall be stricken out.

[][]Batch no. /Lab control no. / Document No. : In case of temporary change, batch number of the product or Lab control No. of material for which the change is initiated shall be written.
In case of permanent change, document number (Master BMR No., SOP No., Specification No. etc. with version number) for which change is initiated shall be written.
[][]Type of Product (Country): Whether product is for domestic market or export market shall be mentioned. Specify the name of country as applicable, If the change is related to export product, name of region or country for which the product is being manufactured shall be mentioned.

[][]Change Type: Put the tick mark on appropriate change type.
[][]Concern person shall further fill the change control form as explained under below. In case space provided in change control form is not sufficient to accommodate the changes, below details shall be given on separate sheet in following type of table. This attachment shall be prepared and checked by concern department and reviewed by Quality Assurance.

Sl. No.Existing SystemProposed ChangeReason/ Justification Impact analysisChange review level
Prepared by/date
(Change Initiator )
Checked by/date:
(Department Head)
Reviewed by/date:
(Manager, Quality assurance)

[][]Existing System: Write details of existing process / formula / procedure / equipment or specification that is being followed.
[][]Description of Proposed Change: Write details of proposed process / formula / procedure / equipment or specification that is to be followed.
[][]Reason/Justification/Benefits for proposed change :In case of Direct Change, write the clear reason (wherever possible) for change initiated along with justification based on supporting data like history, trend, stability data, scientific rationale, event / audit observations and experience or any other to ensure no adverse impact on product quality.
[][]Temporary changes: Confirm that a search for similar changes been performed. Put the tick mark on appropriate box and write the date of expiry for temporary change.
Evaluation for Requirement of Change: If not justifiable
[][]The filled change control shall be reviewed by Concern Department Head and Manager, Quality Assurance or Designee. If the requirement for change is not justifiable or not agreed, either to Concern Department Head or Manager, Quality Assurance or Designee, they shall include justification to close the change control.
[][]The change control form and register shall be updated for closure by Quality Assurance personnel and change control form shall be retained in Quality Assurance department.
[][]Evaluation for Requirement of Change: If justifiable.
[][]Upon evaluation, if the requirement for change is justifiable or agreed, Concern Department Head and Quality Assurance personnel, they shall further allow carrying forward change control by signing it, for approval of GM, Plant and Manager, Quality Assurance.

Recommendations for Impact Analysis :

[][]Concern Department Head and Manager, Quality Assurance or his Designee shall provide recommendations for impact analysis to support ultimate output.
[][]The respective impacted Department Head shall be informed for the recommendations provided under each impact and approval for the same shall be taken from the impacted Department Head.
[][]Change control shall be informed to customer, in accordance with the provision as defined in the quality agreement.
[][]Based on feedback obtained further course of change control implementation shall be decided.
[][]If change control is not approved by third party or not acceptable to third party as per quality agreement, then change control shall be closed with the justification that particulate batch cannot be dispatched to respective third party but it can be sent to different third party if it fulfills requirements of different third party.
[][]If that particular drug product has to be dispatched to the third party with current formula then different product Item Code shall be given.
[][]While batch release Quality Assurance shall ensure that product requirement is fulfilled as per quality agreement during dispatch to different third party.
[][]Adequacy of impact analysis through recommendation shall be approved by Manager, Quality Assurance or Designee.
[][]For new system introduction change control shall be raised upon finalization of draft SOP.

Approval :

[][]All change controls shall be approved by Manager, Quality Assurance.
[][]Upon ensuring all approval, the originating department shall initiate preparatory work as recommendation provided to execute the changes proposed.
[][]The Quality Assurance Executive or his Designee shall review / verify all required actionable mentioned in the impact analysis(possible impact) that are required to be in place before implementation of proposed changes and provide execution approval by signing the change control.
[][]Originating department shall start to execute or implement the change only after getting approval for execution from Quality Compliance. The approved change control shall be provided to change initiator for execution of changes.

CAPA (Corrective Action and Preventive Action) Issuance and Monitoring :

[][]Quality Assurance shall issue CAPA form for long term corrective action and preventive action(s) to the concern impacted Department Head to monitor the recommendation as applicable.
[][]The CAPA shall be issued based on discretion of Manger, Quality Assurance.

Execution :

[][]Details of changes shall be explained by Quality Assurance personnel to concern persons either through mail or by conducting training as recommended in impact analysis / by sending scanned copy of change control form through mail.
[][]The concern person shall execute the change in coordination with Quality Assurance & shall prepare assessment report / data.

Review of Recommendations :

[][]After execution of the change the Concern Department Head and the impacted Department Head shall submit the CAPA form along with respective supporting data / assessment report if applicable to Quality Assurance for review of recommendations.

Impact Evaluation and Conclusion :

[][]Based on review of data / assessment report / outcome / results (satisfactory / not satisfactory) Quality Assurance shall make final conclusion, whether the change was executed successfully or not and shall close the same.

Time Line for Closure of Change Control Form :

[][]After the change is implemented, then the CC form shall be closed by Quality Assurance personnel, within 30 calendar days.
[][]Quality Assurance shall track the open change controls while issuing new change control to initiating department.
[][]New change control shall not be issued if for a same system/equipment/material/product/document and same stage about 3 change controls are already open.

Updating of Change Control Register :

[][]After closing the Change Control Quality Assurance shall update the Change Control register.
[][]All the Change Controls – Permanent / Temporary shall be retained in Quality Assurance Department.
[][]Note: In case of a change initiated for one document which may impact other document(s), the respective document(s) can be revised with reference to the same change control initiated for mother change. The document dedicated change control number system shall not applicable in this case.
[][]In addition to mother changes other changes if required can be clubbed and a separate attachment can be attached to mother change control and all persons who have involved in approval of mother change control shall sign the addendum of mother change control.

Batch release of Change Control impacted batch:

[][]Change Control impacted batch will not be released until formal closing.
[][]Any validation/trial batches produced as supporting evidence for the change proposal will be quarantined until formal closing of Change Control proposals.
[][]In some circumstances, to allow batch release, Manager, Quality Assurance may approve concurrent release of the impacted batches through a risk assessment by the owner.

Annexure:

Annexure-I: Change Control Form
Annexure-II: Change Control Register

Change Control Procedure Read More »

SOP for SOP Preparation and Handling Procedure

SOP for SOP, Purpose :

SOP for SOP, The purpose of this SOP is to define the stages, responsibilities and structure for the creation, distribution, handling, controlling, revision & retrieval of all operating procedures of XX Pharmaceuticals Ltd.

SOP for SOP, Scope :

This SOP applies to all functions in order to prepare, review, control and authorize/approve any procedure.

Definitions / Abbreviation:

[][]Standard Operating Procedure (SOP): A written authorized procedure, which gives instructions for performing operations.

Responsibilities:

[][]The roles and responsibility is as follows:

Author(Who prepares the SOP)

[][]Ensure that the document is technically correct and reflects the required working practices.
[][]Initiate the preparation of SOP through the inputs from the employees directly concerned with the activity.
[][]Responsible for circulation of SOP for comment and resolution of any differences of opinion.

Technical Expert

(Any person who has basic understanding on the subject matter)
[][]Review the SOP and formally notify their agreement to SOP owner within a stipulated time.

Functional Head

[][]To confirm the content, accuracy and detailing about of SOP.
[][]Verify the SOP against XX Pharmaceuticals Ltd. master documents and current regulatory requirements and approve it.

Quality Assurance Executive

[][]To maintain the original copy of the SOP.
[][]To issue controlled copy of the SOP and maintain issuance record.
[][]To retrieve the controlled copy of the SOP when it is superseded.
[][]To destroy the SOP as per procedure.
[][]To control and monitor the review process of the SOP.

Manager, Quality Assurance

[][]Approve all SOPs that have direct/indirect impact on product quality.

Procedure:

[][]Note: It will be applicable for any SOP of general precautions or operational safety.
[][]The process for developing and managing any SOP includes picking of right format, number generation, drafting, review, approval, issuance, distribution, periodic review, revising, withdrawing, archiving and destruction.

[][]Layout Designing for SOP: Before preparation of a SOP, following preliminary requirements are to be meet:

Format of SOP

[][]Standard Format (Annexure-I) shall be used for preparing any Standard Operating Procedure.
[][]The format of this SOP should be used to maintain the same text fonts, page borders, and general document format as explained here.

ParticularsFont sizeFont Font Style
In Header: Company LogoN/AN/APosition is ‘Left side’
In Header: Company Name14ArialBold, All Letters in Capital, Position is ‘Centered’ (both in Horizontally & Vertically)
In Header: Plant Address08ArialAll words are Regular but “Plant” is in bold. Position is ‘Centered’ (both in Horizontally & Vertically)
SOP Title10ArialBold & Uppercase
Heading10ArialBold
Text10ArialRegular
In footer10ArialBold, Position is ‘Left (indent)’ in Horizontally & ‘Centered’ in Vertically

Page Set Up

Margin:

[][]Top : 0.75

[][]Bottom : 0.75

[][]Right : 0.75

[][]Left : 0.75

[][]Gutter : 0.00

[][]Header : 0.5

[][]Footer : 0.5

Note: All Measurements at Inch.

[][]Paper size: A4 size, offset paper

[][]Orientation: Portrait (However landscape orientation may be used for annexure or if required).

[][]Header: Same for all pages [Annexure-I]

[][]Footer: Same for all pages except first. In first page there is no footer. [Annexure-I].

[][]Heading of the main content should use appropriate heading number such as 1, 2, 3 etc.
[][]Subheading may be included in any of the content sections using appropriate heading numbering such as 1.1, 1.2 etc.
[][]Further subheading may be included in any of the sub content sections using appropriate heading numbering such as 1.1.1, 1.1.2 etc.
[][]Header & Footer: Each page header must contain the following information:
[][]Title: Mention title of the SOP, which is expressive of the subject of the SOP.
[][]SOP Number: All the SOP numbers must be unique, unambiguous and unanimous. Referencing should be done in such a manner that it reflects either the function or purpose of this SOP. Standard format of SOP number is as – ‘SOP /Sectional Ref/Sequential SOP No. / Version No.’
[][]Sectional Reference is the predefined department/Section code to identify the SOP controlling department.

The following ‘Sectional Ref’ numbers must be used at the time of preparation of SOPs.

[][]Production (General):  PRO
[][]Production (Sterile): S-PRO
[][]Packaging (General): PKG
[][]Packaging (Sterile): S-PKG
[][]Warehouse (General): WH
[][]Warehouse (Sterile): S-WH
[][]Quality Assurance (General): QA
[][]Quality Assurance(Sterile): S-QA
[][]Quality Control(General): QC
[][]Quality Control(Sterile): S-QC
[][]Microbiology(General): MIC
[][]Microbiology(Sterile): S-MIC
[][]Product Development(General): PD
[][]Product Development(Sterile): S-PD
[][]Engineering: ENG
[][]HR & Admin: HR
[][]Supply Chain: SC
[][]Information Technology: IT
[][]Environment, Health &safety: EHS

A three digit Sequential number shall be assigned to the SOP. This number cannot be reassigned to any other SOP even after deletion of that SOP. The sequential number will be followed by two digit Version number which indicates the number of the revision of the respective SOP.

[][]Version No: In case of new SOP, mention “01” in this column. In case of revision, mention number of version in this column.
[][]Superseded: In case of new SOP, mentions “N/A” in this column. In case of revision, SOP No. of old version shall be written in this column.
[][]Page No.: Mention page No. in this column. It shall be mentioned in “Page X of Y” format.
[][]Prepared By (Signature in Blue Ink on Every Page): Signature of a person, who has written the SOP, shall appear in this column. The signature shall be done using a blue ink to identify the copy as master copy.
[][]Checked By (Signature in Blue Ink on Every Page): Signature of Head of SOP Controlling Department /User department head or any concerned reviewer, who has checked the SOP, shall appear in this column.
[][]Agreed By: Signature of Head of other departments excluding SOP owner /User department head or any concerned reviewer, who has checked & agreed the SOP, shall appear in this column.

[][]Define Content of SOP: Every SOP must contain the following standard sections and contents. Guide line to write these contents is in below:
[][]Issue Date: This is the date when the SOP is issued for signature/approval. This should be in the day-month-year (dd-month-yyyy) format i.e. 30-August-2012.
[][]Effective Date: Mention the effective date from which the SOP shall be implemented after proper training. This should be within 7 working days of approval.
[][]Review Date: It will be 36 months from the issue date in day-month-year (dd-month-yyyy) format. However, revision may be made as and when required before schedule.
[][]Review and Approval: This section must include the printed name, signature, job title, and signing date for the following four disciplines:
[][]Prepared by
[][]Checked by
[][]Agreed by( it would be included where necessary)
[][]Approved by
[][]Distribution List: This section will have a list with job title of individual or sectional name to which the SOP will be distributed for execution.
[][]Purpose: The purpose must state why the SOP is needed

[][]Scope: Mention the application of the SOP in this section. It shall describe the extent of areas covered by the SOP. If the same SOP is used in different location, mention the location in the scope of that SOP.
[][]Definition / Abbreviation: Definitions of words, abbreviations, or actions that may not be readily understandable.
[][]Responsibility: Briefly describes the detailed responsibilities of individuals/departments for implementation of the SOP.
[][]Revision Details: In case of revision, point out the specific changes of current version with previous version. For a new SOP the Revision Details text must read: “First issue”.
[][]Annexure: The mandatory features of an annexure are:

Annexure-I: Format of SOP
Annexure-II: SOP Issue Register
Annexure-III: Request for Issuance of Additional copy of SOP
Annexure-IV: Authorization for Discontinuation of SOP

Procedure:

[][]Note: It will be applicable for any SOP of general precautions or operational safety.
[][]The process for developing and managing any SOP includes picking of right format, number generation, drafting, review, approval, issuance, distribution, periodic review, revising, withdrawing, archiving and destruction.
[][]Layout Designing for SOP: Before preparation of a SOP, following preliminary requirements are to be meet:
[][]Format of SOP
[][]Standard Format (Annexure-I) shall be used for preparing any Standard Operating Procedure.
[][]The format of this SOP should be used to maintain the same text fonts, page borders, and general document format as explained here.

ParticularsFont sizeFont Font Style
In Header: Company LogoN/AN/APosition is ‘Left side’
In Header: Company Name14ArialBold, All Letters in Capital, Position is ‘Centered’ (both in Horizontally & Vertically)
In Header: Plant Address08ArialAll words are Regular but “Plant” is in bold. Position is ‘Centered’ (both in Horizontally & Vertically)
SOP Title10ArialBold & Uppercase
Heading10ArialBold
Text10ArialRegular
In footer10ArialBold, Position is ‘Left (indent)’ in Horizontally & ‘Centered’ in Vertically

Page Set Up

Margin:
[][]Top: 0.75
[][]Bottom: 0.75
[][]Right: 0.75
[][]Left: 0.75
[][]Gutter: 0
[][]Header: 0.5
[][]Footer: 0.5
[][]Paper size: A4 size, offset paper
[][]Orientation : Portrait (However landscape orientation may be used for annexure or if required).
[][]Header : Same for all pages [Annexure-I] [][]Footer: Same for all pages except first. In first page there is no footer. [Annexure-I].
[][]Heading of the main content should use appropriate heading number such as 1, 2, 3 etc.
[][]Subheading may be included in any of the content sections using appropriate heading numbering such as 1.1, 1.2 etc.
[][]Further subheading may be included in any of the sub content sections using appropriate heading numbering such as 1.1.1, 1.1.2 etc.
[][]Header & Footer: Each page header must contain the following information:
[][]Title: Mention title of the SOP, which is expressive of the subject of the SOP.

[][]SOP Number: All the SOP numbers must be unique, unambiguous and unanimous. Referencing should be done in such a manner that it reflects either the function or purpose of this SOP. Standard format of SOP number is as – ‘SOP /Sectional Ref/Sequential SOP No. / Version No.’
[][]Sectional Reference is the predefined department/Section code to identify the SOP controlling department.

The following ‘Sectional Ref’ numbers must be used at the time of preparation of SOPs.

[][]Production (General): PRO
[][]Production (Sterile): S-PRD
[][]Packaging (General): PKG
[][]Packaging (Sterile): S-PKG
[][]Warehouse (General): WH
[][]Warehouse (Sterile)S-WH
[][]Quality Assurance (General): QA
[][]Quality Assurance(Sterile)S-QA
[][]Quality Control(General): QC
[][]Quality Control(Sterile): S-QC
[][]Microbiology(General): MIC
[][]Microbiology(Sterile): S-MIC
[][]Product Development(General): PD
[][]Product Development(Sterile):S-PD
[][]Engineering: ENG
[][]HR & Admin: HRD
[][]Supply Chain: SC
[][]Information Technology: IT
[][]Environment, Health & Safety: EHS

A three digit Sequential number shall be assigned to the SOP. This number cannot be reassigned to any other SOP even after deletion of that SOP. The sequential number will be followed by two digit Version number which indicates the number of the revision of the respective SOP.

[][]Version No: In case of new SOP, mention “01” in this column. In case of revision, mention number of version in this column.
[][]Superseded: In case of new SOP, mentions “N/A” in this column. In case of revision, SOP No. of old version shall be written in this column.
[][]Page No.: Mention page No. in this column. It shall be mentioned in “Page X of Y” format.
[][]Prepared By (Signature in Blue Ink on Every Page): Signature of a person, who has written the SOP, shall appear in this column. The signature shall be done using a blue ink to identify the copy as master copy.
[][]Checked By (Signature in Blue Ink on Every Page): Signature of Head of SOP Controlling Department /User department head or any concerned reviewer, who has checked the SOP, shall appear in this column.

[][]Agreed By: Signature of Head of other departments excluding SOP owner /User department head or any concerned reviewer, who has checked & agreed the SOP, shall appear in this column.
[][]Define Content of SOP: Every SOP must contain the following standard sections and contents. Guide line to write these contents is in below:
[][]Issue Date: This is the date when the SOP is issued for signature/approval. This should be in the day-month-year (dd-month-yyyy) format i.e. 30-August-2012.
[][]Effective Date: Mention the effective date from which the SOP shall be implemented after proper training. This should be within 7 working days of approval.
[][]Review Date: It will be 36 months from the issue date in day-month-year (dd-month-yyyy) format. However, revision may be made as and when required before schedule.
[][]Review and Approval: This section must include the printed name, signature, job title, and signing date for the following four disciplines:

[][]Prepared by
[][]Checked by
[][]Agreed by( it would be included where necessary)
[][]Approved by
[][]Distribution List: This section will have a list with job title of individual or sectional name to which the SOP will be distributed for execution.
[][]Purpose: The purpose must state why the SOP is needed.
[][]Scope: Mention the application of the SOP in this section. It shall describe the extent of areas covered by the SOP. If the same SOP is used in different location, mention the location in the scope of that SOP.
[][]Definition / Abbreviation: Definitions of words, abbreviations, or actions that may not be readily understandable.

[][]Responsibility: Briefly describes the detailed responsibilities of individuals/departments for implementation of the SOP.
[][]Revision Details: In case of revision, point out the specific changes of current version with previous version. For a new SOP the Revision Details text must read: “First issue”.
[][]Annexure: The mandatory features of an annexure are:
[][]No annexure can be updated without updating the SOP.
[][]No need to update Annexure during only updating the SOP.

[][]Procedure: This section provides the detailing about the step-wise activities to be performed within a system.
[][]Preparation of SOP:
[][]SOP author will prepare a procedure in clear unambiguous language which describes the process to be conducted against the SOP in sufficient detail that they can be performed in a reproducible, systematic and consistent manner. During preparation of SOP author must consider the following:
[][]Understand the full process first and then write the procedure/SOP.
[][]Write procedure using simple, clear, concise & easy sentences.

[][]Abbreviations must be defined in full on the first occasion of use. All the resources that can give ideas about preparing the procedure shall be explored.

[][]It is preferable to use positive sentence structure in the SOP.
[][]High level process flowcharts or diagrams must be used for clear understand of the process
[][]User Department Head confirms the content, accuracy and detailing of SOP.
[][]Review of the Documents:
[][]The author collect all comments from the review of the document and update the document as appropriate and be able to provide the Approvers with a justification for any comments from key reviewers that are not accepted.

[][]Approval of SOP:
[][]After final verification, All SOP’s must be approved by Manager, Quality Assurance.
[][]Training on SOP:
[][]After final sign off the originator or controlling department will initiate the training program on SOP.
[][]Training must be conducted before the effective date of the SOP.
[][]The originator will inform to Human Resources Department [HR] with a formal request for organizing training.

Issue of SOP:

[][]SOP controlling department will make required photocopies of the SOP from Master SOP as per distribution list.
[][]Put the “CONTROLLED” stamp in blue ink at the top of the right side of each page of the SOP.

[][]Controlling Department issues the SOP for implementation after making necessary entries in the controlled copy issuance record (Annexure-II) at the time of issuing. The record sheet will be attached with master SOP.
[][]Controlling Department will retrieve all controlled copies of the superseded version.
[][]Controlling Department person shall put the “OBSOLETE” stamp (sample is given below) in red colour on each page of the Master SOP of the superseded version. The Controlling

[][]Department shall keep the OBSOLETE MASTER SOP in the master OBSOLETE file.

[][]All other copies of superseded version will be destroyed after keeping a record.
[][]Photocopy of the “CONTROLLED COPY” is not permitted.
[][]Any photocopy that is not having blue stamp of “CONTROLLED” shall not be considered valid for use.
[][]Master SOP will be kept by Quality Assurance department.

[][]There shall be a Master List of all main SOPs and it shall be maintained by Quality Assurance Department.

Implementation:

[][]The user department after receiving “CONTROLLED” copy of the new SOP shall implement the SOP after training.

Periodic review of SOP:

[][]SOP shall be reviewed at least every 3 years. However SOP’s may be revised before the next review date if required.
[][]In case of any change in the SOPs that may affect the product quality a Change Control Proposal shall be raised by the user’s section/department.

Issuance of Additional Copy of SOP:

[][]If an additional copy of SOP is required by any department for non-operational use then QA dept. shall issue an additional copy only after written approval from Manager, quality [][]Assurance. Such requests shall be obtained through the Request Form as per Annexure -III and shall be forwarded through the department head.

Discontinuation of the SOP:

[][]The existing SOP may be discontinued with proper justification and approval of Departmental Head / Manager, Quality assurance. The SOP number of deleted SOP cannot be reassigned to any other SOP. Fill the details for discontinuation of the SOP as per Annexure-IV.
[][]QA person shall retrieve and destroy all the controlled copies of the discontinued SOP after the authorization of Manager, Quality assurance.
[][]QA person shall put the ‘OBSOLETE’ stamp in red color on the every page of the original copies of the discontinued SOP.

Annexure:

Annexure-I: Format of SOP
Annexure-II: SOP Issue Register
Annexure-III: Request for Issuance of Additional copy of SOP
Annexure-IV: Authorization for Discontinuation of SOP
Annexure-V: SOP Index

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Validation Master Plan, How to write for a GMP compliance firm

Validation Master Plan[VMP] encompass all type of validation activates of a site especially for the new firm, the firm must be validated before run any routine commercial production. The validation activities which consider the major area as Facility, Utility, Machine, Process etc.. Facility, utility, and machine must be validated before run the production operation.

Validation procedure and Validation Master plan is not the same and doesn’t implies the same thing. Validation protocol describe the specific procedure to perform the specific activities where as Validation Master Plan is the series of plan/schedule which describe the plan with a tentative define timeline. Any plan/schedule may be change which to be cover by raising deviation management with proper justification and action to be triggered followed by CAPA.

Validation Master Plan is beneficial for planning purpose and subsequently identifying the related resources to complete the assigned activates on due time. It covers the all type of major documentation like procedures, processes, product, facilities, utilities and equipment.

How a Validation Master Plan works?

Validation master plan is the core guidance of the firm which implies that how the validation activates of the firm will perform within a time frame. It details the activities of the all functional department like production, quality control, Engineering will operate their activities regarding validation events.

The plan demonstrate by the Validation master plan is set upon the agreement of the all functional department and any type of failure is properly justified which satisfy the regulatory body. The proper implementation of the VMP of the respective firm denote that they have the proper control over their quality system.

Functions of the Validation Master Plan

Management learning

Top management of the company is not concern about the requirement of the qualification and validation activities of the respective firm. Here VMP plays the major role and provide the essential information to the company top management. The content of the VMP describe the total quality requirement events of the validation process. It also denote that only the properly validated facility can provide the repeated/continuous quality product through daily activities.

Project nursing and management

By preparing the Gantt chart from the content of the VMP, the management can track the activities of the new facility and set a tentative deadline for the competition of the defined activities. Everyone will be proactive when set a tentative deadline with proper justification through a site quality review meeting. Assigned personnel must be monitored for the progression of the events by daily /weekly /fortnightly/ monthly then VMP will be fully effective and action will cover on due date.

Conducting the validation program

Validation master plan describe the all events in the validation process and the qualification of the processing equipment’s and utilities. As the VMP provide the timeline for the completion of the defined activates base on the criticality. All related resource must be on site to conduct the validation activities and recheck/double/ triple check may be conduct before starting validation activities, for any shortcoming notify the same and after solving the events proceed to validation activities.

Planning purposes

As the VMP detect the list of resources which is required to perform the validation activities in a time line then the list of document may affect by this activity-

  • Equipment
  • Facilities
  • Product
  • Processes
  • Procedures
  • Utilities
Criteria of a Validation Master Plan

VMP require specific preparedness and vigorous planning of different steps in the particular process. All type of activates need to perform in due time as per approved working plan avoiding any type of major/critical deviations. Beside this a VMP is generally written off as-

Multidisciplinary methodology:

This is not the one man job, its require multidepartment involvement, various type of SME [Subject Matter Expert] from various department are involve to perform the specific job. Expert such as chemical analysts, pharmacists, microbiologists, technologists, engineers, metrologists, and SME from QA departments must involve to this activities.

Time bound:
Any type of validation

Generally validation work is submitted to rigorous time schedules. These studies are always the last stage prior to taking new processes, facilities into routine operation.

Costing matters:

To run a successful validation activities to the site, huge resources and expert personnel are involve so that no deviation occur on the site. Lot of financial involvement require to perform the designated activities. A new machine/equipment may be involve to solve the emergency issue.

List of critical point of Standard VMP

All VMPs must include the following:

Title page with Authorization where appropriate signing with date will be present. Title page must be include title of the document, document number and version no. and Signature from the appropriate body including Head of site quality. List content to be present on a VMP-

  • Table of contents
  • Abbreviations and glossary
  • Validation plan
  • Purpose and approach to validation
  • Scope of validation
  • Roles and responsibilities
  • Outsourced services
  • Deviation management in validation
  • Change control in validation
  • Risk management principles in validation
  • Training
  • Validation matrix
  • References
Table of contents

The table content is the brief of the major substance/content present in the VMP. It contains all of the critical area of VMP. Page no. to be mentioned on the table of the content page along with the major content. It will denote where will find the major content of the VMP.

Abbreviations and glossary

Abbreviations and glossary provides necessary information’s to the reader regarding the various term or short/abbreviate form use in the VPM which may not familiar to the respective reader.

Validation plan

A VMP implies that what should be validated and when, where, how and why it should be executed. Critical process mention on the VMP must breakdown into several parts and criticality must identified to perform require validation.

Purpose and approach to validation

Purpose provides an overview of the every process also describe validation approach with supporting data. It must be sum up clearly so that the respective user can understand the actual process/procedure by tracking the document. Validation approach states the persistence of the VMP denoting critical process, equipment and system as described.

This methodology confirm that all validation events to be conducted in prospective manner following approved protocols. VMP speaks about the change control and qualification of equipment and systems and confirm the stipulated events has been done based on existing policies and procedures.

Scope of validation

Scope of the VMP describe all evets relating to the processes, systems, equipment, utilities, and procedures which may affect the quality of the product at the manufacturing site.

Specific equipment, utilities, systems, and procedure be mentioned properly and validation execution to be done based on the documented risk assessment. Define clearly which area will be under validation and where not under the scope. Procedure to be describe in such a way so that anyone possess the same understanding to coverage VMP.

Roles and responsibilities

This area specially denote the dedicated responsibility for the designated department. Generally validation department/team is responsible for preparing all type of validation protocols, validation reports, List of SOP’s deviation reporting, and change control procedure and achieving, storage of validation related all documents.

Generally, Engineering, Production, QC, Microbiology and QA personnel prepare the validation documents as when required based on define timeframe subsequently. Quality Assurance department is responsible to review the all protocol, reports, SOP’s etc. then approve the same.

Outsourced services

Any type of out sources activities regarding qualification and validation must be mention the validation master plan and record/supporting documents/agreements must be keep the same. Certified vendor to be involve to the validation activities, before engage the validation/qualification activities vendor competency certificate to be check.

Deviation management in validation

Any deviation regarding validation to be address and record must be keep for further clarification, if machine involve then call the supplier to resolve the problem. All of critical deviation must be investigate and corrective action to be taken. All validation report to be approve before starting the operation.

Change control in validation

VMP must implies all change management which have the potential impact on the validated process/system must be notify and it should be handle with the existing change management procedure.

Risk management principles in validation

Quality Risk Management Procedure to be define on the Validation Master Plan as to perform the validation activities, quality risk may be the major to be notify same and record must be done and impact to be analyze properly through FMEA[Failure mode and effects analysis] method.

Training

The defined personnel who will perform the validation activates must be trained properly and to be ensure that they have the proper knowledge and skill to perform the right job at the right time.

All validations

This include the following area-

  • Analytical method
  • Cleaning
  • Computer validation
  • Equipment
  • Premises
  • Processes
  • Qualification
  • Revalidation
  • Utilities

The description of the major area must be include VMP such as Manufacturing, Material Management, Facilities, and Central Plant. Attachment with VMP must define the GMP compliance area and non-GMP compliance areas. Describe the cleaning validation strategy and manufacturing process steps, use process flow diagram to describe the specific product manufacturing activities with major equipment involvement on the diagram. Performance qualification of the major equipment to be done showing that it repeats its intended use subsequently.

Validation matrix

Performing an effective validation matrix by prioritizing the critical validation at first then the next one. In this way the VMP activities may be more fruitful. List the all critical validation then perform the task as per justified time frame.

References

List of references to be add at the end of the VMP documentation. Proper guideline reference is mandatory to prove your documented evidence.

Writing the VMP

To write the effective VMP, a team may be form due to a single/individual/specific person didn’t contain the all idea/knowledge regarding different activates. A QA person may not be expert about Engineering activates and a QC person may not be expert about production activities, so a team from different functional department may be effective way to gather comprehensive knowledge from different perspectives then write down the right VMP.

 Involving the multidepartment people from different parts confirm that all equipment, utilities, processes, and systems has been properly addressed on the VMP. T write an effective VMP, every team member must be proactive to address the every point of view seems critical to his side.

What “WHO” says about Preparation of VMP?

“A manufacturer should have a validation master plan that reflects the key elements of validation. It should be concise and clear and at least contain reference to/have a short description”.

validation master plan, validation WHO

List of Major content of VMP as per WHO GMP guideline-

  • Analytical method validation
  • Change control
  • Cleaning validation
  • Computerized system validation
  • Deviation management
  • Equipment & instrument qualification
  • Outsourced services
  • Personnel qualification
  • Premises qualification
  • Process validation
  • Validation matrix
  • Validation policy
  • References
  • Risk management principles
  • Roles and responsibilities
  • Scope of qualification & validation
  • Training
Conclusion

A well described VMP is the true asset of the firm as well as the critical document to avoid the regulatory noncompliance. An incomplete VMP always brought more 483 with subsequent warning letters from FDA. A standard VMP must be more precise, to the point and actual to the system, process, and procedure.

Every sentence of the VMP must be “may”, “may be”, “should be” etc. free, sentence must be in active form in present tense. A well decorated VMP implies the organization positive image as well as quality products avoiding non-compliance, deviation etc.

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Audit Checklist for QA Department in Pharmaceutical Company

Audit Checklist for QA Department: here is the Audit Checklist for QA Department. You can find the best checking point for QA [Quality Assurance] Department in pharmaceutical Company-

Audit Checklist for QA
  1. Annual product review/Product Quality Review reports
  2. Batch Document Archiving /Retrieval system/Disposal records
  3. CAPA [Corrective And Preventive Action]
  4. Calibration Records of balance, equipment’s, machine etc.
  5. Change Control
  6. Destruction of samples & Chemicals reports
  7. Deviation Management
  8. Drug Master file of existing & new products
  9. Failure Investigation
  10. Finished products Released records

Comprehensive QC Department Audit Checklist

  1. GMP/Self-Inspection audit reports
  2. Job Description
  3. Incineration by third party Records
  4. List of finished products, Raw materials & packing materials
  5. Logbook maintaining & Issuance Records
  6. Label Control Procedure
  7. Market Complaint Investigation Report
  8. Machine/Equipment Qualification status records with index
  9. Organogram (Factory)
  10. Previous Self Inspection/Internal Audit Report
  11. Process Validation Protocols & reports
  12. Quality Manual
  13. Risk Management
  14. Retention Sample Management
  15. Rework/Re-process records
  16. Reagent Management records with index
  17. Recall Procedure
  18. Retention samples records with index
  19. Records of market return Goods destruction
  20. Site Mater File (SMF)
  21. Source approval procedure and its records
  22. Standardization of volumetric solution records
  23. Stability studies report of both accelerated and long term
  24. Storage condition of RM, PM, intermediate, bulk & finished products
  25. Specimen signature list
  26. Technology transfer records
  27. Validation Master Plan (VMP)
  28. Vendor/ Supplier Audit reports
  29. Write off & Disposal records of Non-conforming/Rejected materials & products
  30. Yearly Training Calendar and its records for both on Job & GMP
  31. SOP Index
  32. SOP for
  • CAPA
  • Change Control
  • Deviation Management
  • Hold Time Study
  • IPC[In-Process Control] Instruments
  • Job Description
  • Labelling & Label Control
  • Market Complaint Handling
  • Quality Manual
  • Quality Risk Management[QRM]
  • Recall Procedure
  • Site Master File
  • Training Manual
  • Waste Disposal

This all about the Audit Checklist for QA Department but not limited to.

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