19 Nov Pharmaceutical Manufacturer
Remediation – Regulatory Closure
- Compliance expertise needed to address remediation commitments.
- Customer complaints and product field recalls.
- Equipment set-up procedures and Batch Records not sufficiently robust.
- Lack of equipment set-up instructions, critical parameters, and tolerances.
- Need to enhance equipment accept/reject challenges.
- Need to develop yield specifications for all Batch Records.
Key Issues and Internal Barriers
- Additional efforts to validate the equipment and associated product specifications extending overall remediation timeline.
- Lack of methodology, resources, time constraints, and priorities of other initiatives.
- Inability of Production and QA to agree on what constitutes effective procedures and documentation for line clearance and line release for filling/packaging.
Client Strategic Objectives
- Redesign the equipment set-up SOPs and Work Instructions and enhance inspection criteria and increase the frequency of more robust checks.
- Improve the overall work flow in Batch Records and SOPs, define and clarify operator responsibilities and inspection requirements.
- Research and summarize yield data and include in all Batch Records the appropriate yield specifications for each product/presentation produced.
- Meet remediation commitments ahead of scheduled timeline.
Key Program Components
- Work with mechanics to modify and enhance the equipment set-up activities, sequence of activities, critical parameters, change parts requirements, and components used.
- Organize and simplify the SOP with “step-by-step” instructions to improve the set-up process, lists applicable set-up points, specifications, tolerances, ranges, challenges and verification.
- Perform Line Trials to confirm the set-up process and finalize the SOPs for change control.
- Add the necessary set-up information and critical parameters to the applicable Batch Records.
- Data mining to develop accurate yield specifications.
Results and Improvements
- Project completed on time and FDA letter of closure for commitments achieved ahead of schedule.
- Developed 45 equipment set-up SOPs and associated Work Instructions for set-up, change parts requirements (cleaning and use), components used, parameters, specifications, tolerances, ranges, challenges and verification checks.
- Added relevant equipment setup information and critical parameters to applicable Packaging Batch to ensure the equipment and line setup conforms to the specifications.
- Modified over 280 Packaging Batch Records that;
- Enhanced inspection criteria and frequency covering fill weight control, container sealing, and lot number and expiration date legibility.
- Added additional challenges to comply with §211.68 to confirm that the automated equipment properly performs the specified operation.
- Defined and enhanced inspection Pass/Fail criteria and action to take if a criterion is not met.
- Improved line release and line clearance procedures and provided training to line leads and QA personnel on how to effectively perform line clearances.
As a result of Malcom’s remediation program, the client now has the necessary equipment setup instructions and Batch Records to ensure that the equipment setup and the packaging line operation will produce a quality product that meets specifications and customer expectations.
I like the fact that everything is now in the setup SOP. Previously, the specifics covering equipment setup was not available, so there was a lot of trial and error and time spent trying to get the lines ready to run.
I didn't think we would be able to meet the schedule on the Batch Records that had been committed to, but we did it, a number of them have been approved and are in use and the response from the operators and QA has been very positive.