Correct for application. The correct design criteria must be specified. For example, clean compressed air must have a dewpoint temperature of approximately –40 °F to prevent condensation. Refrigerated air driers cannot meet this requirement. Oil-free compressors should be used to exclude oil contamination unless several levels of filtration are used (4). Industry standards allow no more than 1 ppm (1 mg/m3 ) of oil/hydrocarbon in compressed air.
Besides developing some original standards for process equipment design and construction, the pharmaceutical industry has borrowed standards from industries that produce similar consumer products, most notably the dairy industry. The 3-A Sanitary Standards are voluntary guidelines followed by dairy equipment vendors and dairy operators. The standards provide material specifications, design criteria, and other necessary information for the construction of dairy equipment to satisfy public health concerns. The ultimate objective is to safeguard public health from contaminated dairy products.
Providing [FDA] review and comment is desirable because it may reveal [design] defects early and prevent costly construction errors which could lead to defective operations and products. It also affords FDA the opportunity to become aware of future work load obligations and, in some cases, new technologies. Early field involvement with new or modified facilities will increase efficiency and result in the timely processing of applications (6).
Companies should understand and recognize that partnering with FDA to review proposed designs is beneficial to both parties. Costs and delays associated with rework can be avoided if problems are detected early. Definitive dates for facility inspections can be established, which serve as endpoints that motivate project completion. Current agency inspectional focus also may be apparent, foretold by the types of questions that are asked. Overall, early dialogue and FDA involvement may expedite facility completion, reduce engineering and construction costs, and lead to a smooth transition from start-up to operation. These results are desirable for all manufacturers, regardless of company size or complexity.
Scope definition, organization, and planning
Successfully implemented validation projects all begin with a well-defined scope (i.e., the set of activities and deliverables that must occur to complete the project). Scope definition is critical if contracted validation resources are used because it becomes the basis for cost estimates and assessing job completion.