Validation as a Quality Assurance Tool in GLP Environment Muraleedharan CV Biomedical Technology Wing Sree Chitra Tirunal Institute for Medical Sciences & Technology Thiruvananthapuram – 695 012, INDIA 1. INTRODUCTION The basic principles identified as important for laboratories carrying out testing or studies which involve making measurements, are : Measurements should be made to satisfy an agreed requirements; Measurements should be made using methods and equipment which have been tested to ensure they are fit for purpose; Persons making measurements should be both qualified and competent to undertake the task; There should be regular independent assessment of the technical performance of a laboratory; Measurements made in one location should be consistent with those made elsewhere; and Organisations making measurements should have well defined quality control and quality assurance procedures. Figure 1 shows a hierarchical approach to quality assurance within an organisation. The outer layer represents the elements of quality assurance that apply to all levels of activity within the organisation so-called organisational quality elements. Examples at this level include a quality management structure with a defined role within the organisation; a quality system; documented procedures for key activities; a recruitment and training policy for all staff; etc.. The next layer, technical quality elements forms a subset and comprises specific QA elements which apply to the technical activities of the organisation, such as policy and procedures for instrument calibration and performance checks; use of certified reference materials and reference materials, and use of statistical procedures. The inner layer, study quality elements, represents the activities carried out for particular studies or individual tests It Page 1 of 13 Organizational Quality Elements Figure 1 Hierarchical approach to quality assurance in an organisation Technical Quality Elements Study includes the planning, control and reporting practices recommended at the start of, during, and at completion of the study or testing. 1.1. Organisational Quality Elements : Many systems and practices that the organisation adopts for its routine functioning forms the organisational quality elements. These include, but is not limited to : Have staff with suitable managerial and technical abilities to plan, control, deliver and report each study. 1.2. A quality system established to implement the quality policies Systems for coordination and management of study projects Establish a good system of document control and record keeping Establish a good monitoring / surveillance system including periodic audits Technical Quality Elements : GLP study projects can be considered as a collection of discrete tests or , each consisting of a number of unit processes composed of routine unit operations. The unit processes are characterised as being separated by natural dividing lines at which work can be interrupted and the test portion or extract can be stored without detriment before the next step. This is illustrated in Figure 2. The benefit of this modular approach to defining GLP studies is that new study is likely to contain at least some components which are familiar to the laboratory and may even be performed routinely. Page 2 of 13 EXAMPLES Study Project Figure 2 Illustration of break down of GLP studies into unit processes Accelerated ageing studies of heart valve Tests Microbial barrier of Packaging Unit test Sterility test Unit processes Preparation of culture media This approach offers benefits in terms of establishing staff competence and also in documentation of procedures. This means, if the laboratory has demonstrated its ability to perform a particular method, it is also accepted as fit to perform similar closely related methods. This logical, but knowledge and experience oriented approach, enables the demonstration of valid measurements to external experts without the need for elaborate validation of every single unit operation or module or process. The major technical elements that need to be considered during establishing unit processes include : Calibration of measuring instruments to establish traceability to national / international metrology systems. Validation of the systems / methods to ensure that data produced is comparable with data for similar measurements made at different times, or by different analysts or laboratories, or using different methods. Use of statistical methods in o o o o experimental design; characterisation of method performance; quality control of the method and interpretation of results. Page 3 of 13 2. SYSTEM VALIDATION Validation of systems, whether measurement systems as in GLP regulated testing environment or production systems, as in GMP regulated production environment has been in practice for quite some time. These validations attempt to ensure reliability and comparability of study data or reproducibility of Hardware validation Software validation Method validation Figure 3 Elements of system validation SYSTEM VALIDATION System suitability assessment products manufactured, as the case may be. With respect to GLP studies, the validation process shall address the total system which include the scope of measurement , measurement system, and the measurement method. Hence the process of validation, in totality, can be depicted as in Figure 3. Any validation program may have the following elements depending on the nature and scope of validation. Documentation on the validation plan, procedures and acceptance criteria. These should be generated validation begins; Demonstrate the calibration and traceability of measurement systems used in the validation process / system under validation; Demonstrate that the process / method meets an established range of operation for the set of parameters under consideration; Demonstrate the ruggedness of the system by challenging at the limits of established operating conditions; Demonstrate the appropriateness, accuracy, precision and repeatability of the methods used; Demonstrate that the validation has been carried out as per the plan and that the outcome meets the predefined acceptance criteria. Page 4 of 13 2.1. Prospective and Retrospective Validation approaches : The simplest approach in validation is the prospective validation which means that after a system has been developed, the system and the associated methods are validated before employing in GLP studies. Prospective validation is not always feasible, especially for a laboratory who is employing certain measurement systems in testing but are setting up a GLP environment for these measurement processes. Retrospective validation means a validation process to qualify a method or system that is already being used for a specific application. Normally, a retrospective validation is a much more difficult and intensive task than prospective validation. 2.2. Validation – a continuing process : The system validation can be considered as a process which continues over the life span of the system, including the procurement phase, installation phase and usage phase. Figure 4 provides the activities at these phases of validation. The validation process starts with the manufacturer or the supplier carrying out the structural, software and method validation of the measurement system. Once the system is brought to the user’s premises, the functional validation of the system, establishing its suitability for the user’s application is carried out. This will involve the three stages, viz., Installation Qualification (IQ), Operational Qualification (OQ) and Performance Qualification (PQ). Once the system is put into use, it has to go through continuous quality assurance schemes, which may involve routine calibration, maintenance and verification. 2.3. Installation Qualification : The purpose of installation qualification is to document the Figure 4 Activity time line for a typical system validation program Supplier’s Site Structural, software and method validation User’s Site User’s Site FUNCTIONAL VALIDATION Installation Qualification (IQ) Before procurement Operational Qualification (OQ) Before use Performance Qualification (PQ) Calibration, maintenance and verification to establish continuing suitability During use installation of an instrument, equipment or system in a manner that allows for the efficient implementation of calibration and preventive maintenance programs and facilitates effective control of change to the equipment, over time. The IQ documentation shall describe all the Page 5 of 13 critical features of the equipment, i.e., any component or feature that, if changed, could seriously affect the performance, operation or safety of the system. The following information is considered appropriate for an IQ document : 2.4. Technical drawings / description of the equipment / system Primary specifications, including scope and range of operation A statement declaring the adequacy for the intended use System identity characteristics Utility requirements Safety features Reference to operator and maintenance manuals Reference to vendor support services and parts suppliers Operational Qualification : The purpose of the operational qualification (OQ) is to confirm that the equipment or the system operates as expected under controlled conditions. The IQ should be completed before the OQ begins to ensure that any deviations in operational expectations are not a result of improper installation. Activity usually associated with OQ events include the following : Calibration of sensors and measuring devices Qualification of support processing such as cleaning, disinfection, passivation, or sterilization, as applicable Qualification of the monitoring and controlling software Qualification of methods used to assess the performance A systematic demonstration of its features and functions A demonstration of cycle performance, when appropriate, including the performance of controllers / software. A demonstration of process uniformity / consistency (e.g. Temperature distribution in an oven, fill volume consistency in a filling machine, moisture level uniformity in an incubator etc) Page 6 of 13 A demonstration of safety features and reset procedures after likely events such as power failure, shut down etc. 2.5. Performance Qualification : The performance qualification (PQ) is the most important event of a system validation. PQ must confirm, under routine and challenged conditions of operation, that the system continues to operate as expected and the outcome of the process is acceptable. This must be demonstrated repeatedly, which usually means a minimum of three consecutive successful runs. Challenging the system to confirm its operation within the established limits of operation is a fundamental requirement of the PQ event. This does not mean endless number of demonstrations with each parameters pushed to a minimum or maximum limits; only means that a reasonable approach to the performance evaluation. 3. METHOD VALIDATION Method validation is the process of defining an analytical requirement, and confirming that the method under consideration has performance capabilities consistent with what the application require. A method should be validated when it is necessary to verify that its performance parameters are adequate for use for a particular application and is necessary in the following situations. new method developed for particular problem; established method revised to incorporate improvements or extended to a new problem; when quality control indicates an established method is changing with time; established method used in a different laboratory, or with different analysts or different instrumentation; to demonstrate the equivalence between two methods, e.g. a new method and a standard one which is known to be validated. The laboratory has to decide which method performance parameters need to be characterised in order to validate the method. Characterisation of method performance is an expensive process and inevitably it may be constrained by time and cost considerations. Starting with a carefully considered analytical specification provides a good base on which to plan the validation process, but it is recognised that in practice this is not always possible. The laboratory should do the best it can within the constraints imposed, taking into account customer requirements, existing experience Page 7 of 13 of the method, and the need for compatibility with other similar methods already in use within the laboratory or used by other laboratories. Some of the parameters may have been determined approximately during the method development stage. Often a particular set of experiments will yield information on several parameters, so with careful planning the effort required to get the necessary information can be minimised. The following sections describe a set of parameters, the estimation of which could form the basis for any method validation. 3.1. Applicability : This concept covers the identity of the analyte, its concentration change , the protocol, the intended application and its uncertainty requirements in the measurement of the analyte. It is necessary to establish that the signal being produced at the measurement stage, which has been attributed to the analyte, is only due to the analyte and not from the presence of something chemically or physically similar or arising as a coincidence 3.2. Selectivity : Selectivity (or specificity) is the degree to which the method can quantify the analyte under consideration, in the presence of interferences. It is the ability of a method to determine accurately and specifically the analyte of interest in the presence of other components in a sample matrix under stated conditions of test Example : A peak in a chromatographic trace may be identified as being due to the analyte of interest on the basis that a reference material (RM) containing the same analyte generates a signal at the same point in the chromatogram. But, is the signal due to the analyte or to something else which coincidently got eluted? It could be either or both. Identification of the analyte by this means only is unreliable and some form of supporting evidence is necessary. For example, the chromatography could be repeated using a column of different polarity, to see whether the signal and the signal generated by the reference materials still appear at the same time. Where a peak is due to more than one compound, a different polarity column may be a good way of separating the compounds. 3.3. Limit of Detection (LoD) : When measurements are made at low analyte or property levels, it is important to know what is the lowest concentration of the analyte or property value that can be confidently detected. LoD is relevant in qualitative tests also. LoD is also known in certain documents as minimum detectable net concentration, detection limit, or minimum detectable (true) value. Table 1 and 2 shows examples for estimation of an LoD for a quantitative and qualitative tests involving concentration estimation. Page 8 of 13 Table 1 : Estimation of LoD – Quantitative Estimation What to do ? How many times ? What to do with data ? Measure the result corresponding to sample blank Minimum 10 independent measurements Measure the result corresponding to sample blank fortified at lowest acceptable concentration Minimum 10 independent measurements Express LoD as concentration corresponding to mean + 3s (or 4.6 s), Where s is the sample standard deviation (not of population) Table 2 : Estimation of LoD – Quantitative Estimation Concentration (ppm) No. of Tests Positive / Negative Results 500 10 10/0 200 10 10/0 100 10 10/0 50 10 9/1 25 10 5/5 10 10 1/9 5 10 0/10 Note : 100 ppm is the LoD for concentration estimation in this case. 3.4. Limit of Quantitation (LoQ) : The lowest concentration of an analyte, that can be determined with acceptable precision (repeatability) and accuracy under the stated conditions of the test. Neither LoQ nor LoD represent immeasurable values; but only indicates that below which the measurement uncertainties approach the measured value itself. Many agencies specify the LoQ as 10X values of the standard deviation of the blank mean. Table 3 provides an example of LoQ estimation. Table 3 : Estimation of LoQ – Quantitative Estimation What to do ? How many times ? What to do with data ? Measure the results for Sample blanks 10 independent measurements Estimate LoQ as 10X standard deviation of the mean. Fortify aliquots of sample blank at various concentrations close to LoD At least 6 concentrations and 10 replicate measurements of each concentration Calculate the value of variance (s) for each concentration and plot against concentration. Assign LoQ by inspection Page 9 of 13 3.5. Working and Linear Ranges : The working range is the range over which the method can be employed. The lower limit of the working range may be the LoD (in qualitative estimations) and LoQ (in quantitative estimations). At the upper end of the range, limitations will be imposed by various effects, like instrument response. The linear range is the range of over which the method gives test results proportional to the input. Table 4 : Estimation of linear range 3.6. What to do ? How many times ? What to do with data ? Analyse blank + RM or fortified sample blanks at various concentrations At least six concentrations + blank (independently prepared) Plot the conc. Vs. result and identify approximate working and linear ranges Analyse RM or fortified sample blanks within the linear range At least six concentrations to be tried Calculate the regression coefficients in the linear range. Calculate the residual plots. Normal distribution of residuals with zero mean establishes linearity. Accuracy and precision : Accuracy expresses the closeness of result with the TRUE value or CONVENTIONAL TRUE value. Accuracy is expressed as BIAS. i.e. the difference between the mean value of the method and the mean value of the TRUE VALUE or CONVENTINAL TRUE VALUE. Certified Reference Materials (CRM) can be used for establishing the bias of the method Alternate method for estimation of bias is the use of any other standardised method, that could be used for the estimation of the same result. Table 5 : Estimation of accuracy 3.7. What to do ? How many times ? What to do with data ? Analyse blank and CRM using the candidate method At least 10 independent measurements Estimate the difference between the means certified value of the CRM to the value obtained in the test Reagent blank and reference / test material using alternate standard method At least 10 independent measurements Estimate the difference between the results with the candidate method and the alternate standard method. Precision : Most common precision measures are REPEATABILITY and REPRODUCIBILITY Repeatability will provide the dispersion of results when a method is performed by a single person, on one measurement system, over a short period of time (time interval being Page 10 of 13 comparable to the duration of the test). Reproducibility refers to the dispersion of results when there occurs following conditions Different operators Different measurement systems (instruments) Larger time / spatial gap between measurements Normally standard deviation of the mean (SD) is estimated to represent the measure of precision. But, the standard deviation of the mean may some times depend on the mean itself. In such cases, relative standard deviation or coefficient of variation could be a better measure of precision. A Precision estimation plan could have three distinct objectives : Estimation of Repeatability precision Estimation of Intra Laboratory reproducibility precision Estimation of Inter Laboratory reproducibility precision Table 6 : Estimation of precision measures What to do ? How many times ? What to do with data ? (Analyse RM or fortified sample blanks at various concentrations across working range) 3.8. Same analyst, equipment, laboratory, short time scale 10 independent trials Estimate repeatability standard deviation Different analysts, equipments, same laboratory, extended time scale 10 independent trials Estimate intra laboratory reproducibility standard deviation Different analysts, laboratories, extended time scale 10 independent trials Estimate inter laboratory reproducibility standard deviation Sensitivity : It is the measure of the gradient of the calibration function and is a measure to compare different techniques of measurement. 3.9. Ruggedness and Robustness : The robustness of a method is a measure of its capability to remain unaffected by small, but deliberate variations in method parameters and provides an indication of its reliability during normal usage. Robustness is normally evaluated during the method development (one laboratory) and subsequently, ruggedness estimation is attempted using an inter laboratory study. Ruggedness requires an inter laboratory study to assess the behavior of a method when small changes in the environmental and / or operating conditions are made (which signifies the changes that could arise between different laboratories). Page 11 of 13 Table 7 : Estimation of ruggedness / robustness What do you do ? Identify variables which could have significant effect on the method. Conduct experiments to monitor the effect of each variable on accuracy and precision 3.10. How many times ? What to do with data ? Analyse each set of experimental conditions once. Estimate the effect of each change in condition on the mean. Rank the variables in the order of the greatest effect on method performance. Concentrate on these variables during method improvement Measurement Uncertainty : It is a parameter that could be attributed to the dispersion of the measurement. Uncertainty estimation of the measurement shall take into account, Over all precision of the method Bias and its uncertainty (method) Calibration uncertainties Any other significant factors and their uncertainty that might affect the results (Eg. Environmental conditions, sample preparation, sampling …..) 3.11. Recovery : Test for analytes do not always measure the analyte present in the sample. Analytes may be present in different forms; either bound or unbound conditions, some of which during the extraction process does not contribute towards the result. Since it is not possible to know how much analyte is present in a sample, it is difficult to be certain how successful the method is in extracting the analyte. Estimation of efficiency of recovery is an acceptable way to ascertain the suitability of extraction method. 4. CONCLUDING REMARKS Validation starts well before a system is put to use and continues long after system / method development. After a system has been found suitable to be taken into use, it must be continuously assessed as remaining stable over its entire life. A plan for its systematic control should be established. This plan may contain parts of the elements of the system or the entire system, depending on what is necessary and most practical. The laboratory should concentrate its efforts on aspects where the sources of errors are greatest, i.e., on the control of adjustment and calibration of the components and the verification and maintenance of procedures to ensure the reliability of data. A well defined and documented validation process provides regulatory agencies with evidence that the system and method are suitable for their intended use. Page 12 of 13 5. REFERENCES 5.1. USFDA, “Analytical processes and method validation - Guidance for Industry” , Centre for Drug Evaluation and Research, Maryland 20857, USA ,2000 5.2. EURACHEM, “Quality Assurance for Research and Development and Non-routine analysis”, EURACHEM / CITAC Working Group, Middlesex, United Kingdom, 2003 5.3. NATA, “ Format and Content of Test Methods and Procedures for Validation and Verification of Chemical Test Methods”, National Association of Testing Authorities, Australia (NATA), 1998 5.4. EURACHEM, “The Fitness for Purpose of Analytical Methods - A Laboratory Guide to Method Validation and Related Topics”, EURACHEM / CITAC Working Group, Middlesex, United Kingdom, 1998 5.5. Carol DeSain and Charmaine Vercimark Sutton, “Validation for medical devices and diagnostic manufacturers”, Interpharm Press, Buffalo Grove, 1994. Page 13 of 13
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