EMA and WHO Focus Areas During Validation Metric Audits



EMA and WHO Focus Areas During Validation Metric Audits

Published on 10/12/2025

EMA and WHO Focus Areas During Validation Metric Audits

Validation metrics and key performance indicators (KPIs) are crucial in the pharmaceutical industry to ensure compliance with regulatory requirements, particularly during validation audits conducted by organizations such as the European Medicines Agency (EMA) and the World Health Organization (WHO). This article provides a detailed step-by-step tutorial on establishing an effective validation lifecycle, focusing on various checkpoints including process design, qualification, process performance qualification (PPQ), continued process verification (CPV), and revalidation, all framed within the context of the FDA Process Validation Guidance and ICH guidelines.

Step 1: Understanding User Requirements Specification (URS) and Risk Assessment

The foundation of an effective validation process begins with a comprehensive User Requirements Specification (URS). This document identifies what the end-users expect in terms of performance and output quality from the process to be validated. The URS should align closely with both business needs and regulatory expectations.

The risk assessment process, as outlined by ICH Q9 guidelines, involves identifying potential failures during

the lifecycle of the validation process. This assessment should classify risks associated with various stages of production and identify mitigation strategies. Risk assessment not only assists in prioritizing the validation efforts but also reinforces a culture of quality. Key tasks during this step include:

  • Formulating the URS: Engage stakeholders in the drafting of URS. Include details regarding the intended use, performance criteria, and specifications.
  • Conducting a Risk Assessment: Utilize tools like Failure Mode and Effects Analysis (FMEA) or risk matrices to ascertain risks associated with potential failure points in the process.
  • Documentation: Ensure that both the URS and risk assessment are documented appropriately. This will serve as essential evidence during audits.

Documentation and tracking of the URS and associated risk assessments align with regulatory expectations stipulated in attachments like European Annex 15, thereby aiding in demonstrating compliance throughout the validation lifecycle.

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Step 2: Protocol Design for Qualification Phases (IQ, OQ, PQ)

Once the URS and risk assessments are complete, the next step in the validation lifecycle is to design protocols for Installation Qualification (IQ), Operational Qualification (OQ), and Performance Qualification (PQ). Each qualification phase serves a distinct purpose and must be meticulously documented to ensure regulatory compliance.

Installation Qualification (IQ)

IInstallation Qualification verifies that the equipment and systems operate according to the manufacturer’s specifications and are installed correctly in the intended environment. Key activities include:

  • Inventory Verification: List all equipment and verify that it matches specifications.
  • System Configuration: Document the installation site and configurations, including utilities and environmental conditions.
  • Documentation Review: Ensure that required manuals, specifications, and installation records are available for auditing.

Operational Qualification (OQ)

After successful IQ completion, the next phase, Operational Qualification, assesses the performance of the system within defined limits. This ensures that parameters are capable of consistently operating within established criteria. Important steps include:

  • Defining Critical Operating Parameters: These should be based on the URS and associated risk management.
  • Creating Test Cases: Develop specific test cases to document the system’s operational capability.
  • Gathering and Analyzing Data: Ensure the parameters are tested against their limits and document any deviations.

Performance Qualification (PQ)

Performance Qualification follows OQ and validates that the system can consistently produce results that meet the specified quality criteria in real-world conditions. Key tasks include:

  • Batch Testing: Use representative samples and test under normal operating conditions to validate performance.
  • Data Analysis: Review the results against acceptance criteria, ensuring that valid data collection practices align with regulatory guidelines, especially regarding the validation of analytical procedures.
  • Documentation and Reporting: Summarize findings in a formal report that clearly states whether the qualification was successful.

The comprehensive documentation from IQ, OQ, and PQ is crucial for establishing compliance during audits and inspections by regulatory bodies.

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Step 3: Conducting Process Performance Qualification (PPQ)

Process Performance Qualification (PPQ) is essential in establishing that the validated processes can produce finished products meeting established quality attributes. This phase combines elements of both operational and performance qualifications while emphasizing manufacturing effectiveness. Regulatory bodies expect comprehensive documentation, and therefore, efforts must align with guidelines.

Key tasks during PPQ include:

  • Defining the PPQ Protocol: Identify objectives, acceptance criteria, and details regarding the batch sizes for conducting the PPQ.
  • Execution of Batches: Execute processing of three consecutive batches to validate performance across a broader spectrum of normal operational parameters.
  • Data Collection and Analysis: Collect and statistically analyze critical quality attributes (CQAs) to confirm that the process operates in a state of control.

Furthermore, it’s essential to document each step and the results comprehensively. This documentation will greatly aid in compliance audits by entities such as EMA or WHO.

Step 4: Continued Process Verification (CPV)

Following the PPQ phase, Continued Process Verification (CPV) is a critical step that involves ongoing monitoring and assessment of processes. This stage ensures that the manufacturing operations consistently yield products in alignment with predetermined specifications and quality criteria.

Emphasis is placed on reviewing the existing validation data against current quality standards and making necessary adjustments in manufacturing processes. Steps in CPV include:

  • Establishing a CPV Plan: Identify parameters to be monitored, including critical process parameters (CPPs) and CQAs, while determining frequency and methodology.
  • Real-time Monitoring: Implement a system for continuous monitoring of critical parameters to detect any deviations from established norms.
  • Data Analysis: Regularly assess data to ensure processes remain within control limits. Deviations should be investigated thoroughly and documented.

CPV is vital for enriching quality assurance activities, and documentation must reflect any changes in the process, methods, or specifications, thus adhering to the principles outlined in ICH Q10 concerning Pharmaceutical Quality Systems.

Step 5: Revalidation and Change Control

Revalidation is necessary to ensure continued compliance and performance as processes or equipment change over time. Changes may be driven by regulatory requirements, technological advancements, or operational efficiencies. Revalidation should conform to the principles of change control, ensuring that any adjustments made to processes undergo a rigorous evaluation.

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Key activities include:

  • Change Assessment: Review any changes in processes or equipment to determine if revalidation is necessary. This can be assessed through a change control board (CCB).
  • Documentation of the Change Control Process: Maintain clear records of what changes occurred, the rationale behind them, and the outcome of the assessment.
  • Validation Reassessments: Conduct a revalidation process similar to the initial validation activities. This may involve repeating specific phases of IQ, OQ, or PQ depending on the significance of the changes.

Documentation of revalidation and the change control process is essential, providing evidence of quality assurance and regulatory compliance, which supports the validation lifecycle comprehensively. Regulatory references like the European Annex 11 outline expectations for revalidation practices.

Conclusion

Validation within the pharmaceutical industry is an essential and multifaceted process. Emphasizing steps from the User Requirements Specification through to continued process verification and revalidation ensures that products meet quality requirements and comply with regulatory standards. With the heightened scrutiny from regulatory bodies such as the FDA, EMA, and WHO, maintaining a rigorous validation program is not only necessary but crucial for the success and sustainability of operations within the pharmaceutical sector.

This article has outlined the critical steps in the validation lifecycle and highlighted the regulatory expectations involved in each phase. By adhering to these guidelines, QA, QC, and validation professionals can ensure compliance, improve product quality, and support overall quality assurance strategies in alignment with best practices in pharmaceutical validation.