It is useful to identify project activities on a spreadsheet when establishing project scope. Systems and equipment requiring qualification and validation are first determined by reviewing the project documents described previously. Then, the spreadsheet is created and the first column is reserved for each identified system and piece of equipment. Adjacent columns become a matrix of activities necessary to complete system and equipment qualification. Column headings and subheadings usually consist of the following:
- document collection and review (to develop protocols and SOPs);
- calibration and metrology;
- protocol preparation (installation qualification [IQ], operational qualification [OQ], performance qualification [PQ], and cleaning);
- protocol execution (IQ, OQ, PQ, and cleaning);
- final reports;
- turnover packages (contain construction test reports, as-built drawings);
- SOPs (operation, maintenance, cleaning).
Industry experience has shown that validation costs (excluding commissioning and process validation) typically range from 2.5–5% of the total installed cost of the facility. Aseptic-filling and biotechnology facilities frequently have the highest validation cost, whereas API facilities tend to be the least expensive. Care must be taken not to apply these guidelines too tightly because the percentage validation cost will vary with project size. As an example, the purchase and installation of a small steam sterilizer might have a total installed cost of $150,000; however, the validation costs may exceed $50,000 (33%), when protocol preparation and implementation, SOP development, and laboratory supplies are considered.
The facility revalidation program also should be described in the master plan because the validation life cycle continues long after the facility is mechanically complete and handed over for operation. Revalidation usually takes two forms: time or event based (9). Time-based revalidation is the practice in which a system or process is recertified at a specified interval. Time-based assessments also can include a review of historical system performance data. Event-based revalidation is implemented whenever physical or operational changes are made to the system outside the scope of the original validation. All such modifications are the subject of the facility's change control program, which also should be described in detail in the master plan.
Turnover package (TOP) development also can be described in the master plan. Turnover package is a system for organizing all documents related to facility and system design, construction, and start-up relevant to the eventual commissioning and qualification of systems and equipment (10). Turnover packages are usually prepared by the construction manager and turned over to the owner at project completion. TOP documents construction activities and contributes to system IQ, OQ, and PQ and usually is a prospective or concurrent activity (i.e., design, construction and start-up documents are compiled as system construction proceeds). Turnover packages will be discussed in detail in Part 2 of this article.
William Garvey is a senior advisor at Pfizer Global Research and Development, Eastern Point Road, Groton, CT 06340, tel. 860.715. 2277, fax 860.715.7806, email@example.com
1. US Food and Drug Administration, Code of Federal Regulations, Title 21 (FDA, Washington, DC, April 1, 2005), pp. 120–141.
2. W. Garvey, "Integrated Validation Programs for Solid Dosage Facilities—Part 1," Am. Pharm. Rev. 2 (2), 33–39 (1999).
3. The Construction Specifications Institute (Alexandria, VA).
4. Department of Health, Education and Welfare, "Human Drugs—Current Good Manufacturing Practice in Manufacture, Processing, Packing or Holding of Large Volume Parenterals, and Request for Comments Regarding Small Volume Parenterals," Fed. Regist. 41 (106), 22022–22115 (June 1, 1976).
5. 3-A Sanitary Standards Inc., McClean, VA.
6. FDA, "ORA Field Management Directive 135, Pre-Operational Reviews of Manufacturing Facilities" (FDA, Washington, DC, Dec. 4, 1995).
7. W. Garvey, "Effective Validation Project Management," oral presentation given at Interphex Conference 2005, New York, NY, April 26–28, 2005.
8. ISPE Baseline Pharmaceutical Engineering Guide, Pharmaceutical Engineering Guides for New and Renovated Facilities, Vol. 5, Commissioning and Qualification, (International Society for Pharmaceutical Engineering [ISPE], March 2001), pp. 11–15.
9. ISPE Baseline Pharmaceutical Engineering Guide, Pharmaceutical Engineering Guides for New and Renovated Facilities, Vol. 5, Commissioning and Qualification, (ISPE, March 2001), p. 111.
10. M. Chin, "TOP: A Rational Approach For Ensuring Proper Biopharmaceutical Plant Construction," in proceedings from PharmTech Conference '87 (Aster Publishing Corporation, Eugene, OR, 1987), p. 73.