Published on 09/12/2025
How to Track On-Time Delivery, Rejections, and Deviations
The pharmaceutical industry requires rigorous validation of processes and systems to ensure the quality and compliance of biopharmaceutical production. One critical aspect of this validation lifecycle is tracking essential metrics such as on-time delivery, rejections, and deviations throughout the manufacturing process. This comprehensive guide will walk you through each step of the validation lifecycle, emphasizing documentation, data requirements, and regulatory expectations aligned with FDA guidelines, EU GMP Annex 15, ICH guidelines, and more.
Step 1: User Requirements Specification (URS) & Risk Assessment
The foundation of an effective validation lifecycle begins with the User Requirements Specification (URS) and a thorough risk assessment. The URS must clearly outline the functional requirements of the system or process to be validated, ensuring all stakeholders have a unified understanding of the goals and objectives.
When drafting the URS, collaborate with cross-functional teams from Quality Assurance, Quality Control, and Production to capture
Once the URS is established, conduct a risk assessment following the principles outlined in ICH Q9. This involves identifying potential risks to product quality, safety, and efficacy throughout the manufacturing process. The risk assessment should prioritize risks based on their probability and impact, leading to manageable mitigation strategies.
It is important to document the entire risk assessment process, detailing identified risks, their categorization, and the rationale behind each categorization. Incorporating frameworks like Failure Mode and Effects Analysis (FMEA) can provide a structured approach to documenting and analyzing risks. Ensure that risk management documentation is aligned with ISO 13485 requirements, as it provides guidance on the validation of test methods and quality management systems in the context of medical devices and biopharmaceuticals.
Step 2: Protocol Design
With a clear URS and risk assessment in place, the next step is designing the validation protocol. The protocol serves as a roadmap for executing the validation activities and must be structured to meet regulatory expectations effectively. The design should address each requirement outlined in the URS while considering identified risks.
The validation protocol should detail the objectives, scope, methodology, responsibilities, and acceptance criteria. When developing the methodology, include aspects such as sampling strategies, test methods, and equipment qualifications. Ensure that the protocol adheres to both EU GMP Annex 15 guidelines and applicable FDA guidance on process validation.
For process validation in the manufacturing of biopharmaceuticals, categories such as Installation Qualification (IQ), Operational Qualification (OQ), and Performance Qualification (PQ) should be included. Each qualification stage must address specific requirements and acceptance criteria, ensuring each part of the process is appropriately verified.
Add comprehensive sections on data management and statistical analysis. The protocol should stipulate the types of data to be collected, the methods for data analysis, along with detailing how the data will be assessed against established acceptance criteria. Consider compliance with ISO 14644-1 Class 5 standards to monitor cleanroom classifications effectively during the process.
Step 3: Execution of Qualification Activities
After finalizing the validation protocol, the next step is the execution of the qualification activities according to the established methodologies. This includes conducting the Installation Qualification (IQ), Operational Qualification (OQ), and Performance Qualification (PQ).
During IQ, verify that all equipment and systems are installed according to specifications stated in the URS. This includes checks for hardware configurations, connectivity, and the operational environment. Document all findings meticulously, as this forms the basis for demonstrated compliance.
Operational Qualification (OQ) assesses whether the equipment operates correctly across the required operating ranges. Testing procedures should be intended to confirm each functional aspect of the equipment as per the validated protocol, including control measures and alarms. The results must be documented to provide evidence of compliance, with deviations logged and assessed.
Finally, Performance Qualification (PQ) establishes that the process consistently produces a product meeting its predetermined specifications and quality attributes. During this phase, batch runs should be conducted under normal operating conditions while capturing process parameters and product quality data. The statistically designed sampling plan should ensure that regulatory standards are met for the biopharmaceutical product produced.
Step 4: Process Performance Qualification (PPQ)
The Performance Qualification stage acts as a crucial element in the lifecycle of process validation, with a strong focus on demonstrating process consistency over time. The PPQ should ideally consist of three consecutive production batches, which provide data for comprehensive statistical analysis.
During PPQ, all critical process parameters (CPPs) and critical quality attributes (CQAs) identified in earlier stages need to be monitored, ensuring adherence to the pre-defined specifications. A robust statistical plan is critical to interpret the data accurately, with acceptance criteria built upon a thorough understanding of process variability and risk associated with the end product.
It is vital to establish that the batches produced are representative of routine production conditions. This means that all data collected during the PPQ must be meticulously analyzed for trends or deviations, documented, and reported. Ensure that any process deviations are thoroughly investigated, recorded, and assess the potential impact on product quality.
Once PPQ results indicate successful performance, the documentation should clearly demonstrate compliance with the parameters set forth in regulatory guidance documents such as the FDA’s Process Validation Guideline and ICH Q8-Q10.
Step 5: Continued Process Verification (CPV)
With the successful completion of the PPQ phase, the focus shifts to Continued Process Verification (CPV). CPV is essential for monitoring the ongoing performance of the manufacturing process by establishing a system for real-time data collection and analysis throughout the product lifecycle.
Establish key performance indicators (KPIs) that reflect both the product and process attributes critical to maintaining quality. Continuous monitoring of these indicators ensures that any deviations or trends can be acted upon promptly, reducing the likelihood of out-of-specification (OOS) results. Engage a multi-disciplinary team to interpret the data collected and perform routine assessments to verify process effectiveness.
During CPV, documentation must be maintained to substantiate that the process remains in a state of control. This requires generating reports that illustrate any trends in performance over time, delineating actions taken to address issues, and recommendations for process adjustments as necessary. Documentation should also incorporate change control measures to manage alterations in manufactured products or processes.
It may be beneficial to align CPV activities with regulatory expectations, keeping in mind requirements outlined in EU GMP Annex 15 concerning computerized systems and risk management applications. Continued verification enhances product quality and compliance while achieving efficiencies aligned with ISO standards that ensure method validation remains robust and effective.
Step 6: Revalidation
Revalidation is a critical component of the validation lifecycle that comes into play when significant changes occur within the manufacturing process, equipment, raw materials, or even surrounding environmental conditions affecting the biopharmaceuticals. Some major factors that could warrant revalidation include changes in suppliers, alterations in formulation, or shifts to a different production site. The pharmaceutical industry must maintain a proactive stance on revalidation schedules, guided by both regulatory expectations and risk assessments.
The revalidation process should follow a defined protocol, similar to the original validation process, including IQ, OQ, and PQ stages as necessary. Documenting the rationale for revalidation and the scope is essential to demonstrating compliance with both FDA regulations and ISO 13485 for quality management systems.
Execute revalidation in accordance with standard practices and maintain records showing that all concerns raised during previous stages were resolved. This will foster an effective quality assurance environment and support continued regulatory compliance. Each phase of revalidation must ensure the process’s alignment with the specifications defined in the original URS, demonstrating that product quality remains uncompromised.
Ultimately, revalidation emphasizes the dynamic nature of pharmaceutical processes, underscoring the need for continuous evaluation and adjustment to maintain high-quality standards. By adhering to these steps and best practices, pharmaceutical organizations can effectively track on-time delivery, rejections, and deviations, while ensuring robust process validation in the manufacturing of biopharmaceuticals.