Challenges in Scaling Process Ranges from Pilot to Commercial Scale


Challenges in Scaling Process Ranges from Pilot to Commercial Scale

Published on 07/12/2025

Challenges in Scaling Process Ranges from Pilot to Commercial Scale

In the pharmaceutical industry, the transition from pilot to commercial scale involves a multitude of validation steps that ensure processes remain robust, reproducible, and aligned with regulatory requirements. This article serves as a comprehensive guide detailing the step-by-step process of validation critical to achieving successful target validation in drug discovery.

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

The first step in the validation lifecycle focuses on the User Requirements Specification (URS) and a thorough risk assessment. The URS outlines the necessary system functionalities and performance criteria essential to meet operational and regulatory expectations. This document should evolve through iterative discussions involving cross-functional teams—QA, QC, production, and regulatory affairs.

Once the URS is established, risk assessment should follow, incorporating ICH Q9 principles. A risk assessment identifies potential failure points in the process and quantifies their impact on product quality. Utilizing tools such as Failure Mode Effects Analysis (FMEA) or Hazard Analysis and Critical Control Points (HACCP) is recommended. The output of this risk assessment will inform

process design and validation effort allocation.

  • Documentation: Detailed URS documents, risk assessment reports, FMEA matrices.
  • Data Requirements: Historical data to support risk assessment, past validation reports.
  • Regulatory Expectations: Ensure compliance with ICH Q8 and ICH Q9.

Step 2: Process Design and Development

In this stage, the validation team collaborates closely with process engineers to design a scalable manufacturing process that adheres to both the URS and risk control measures. Critical process parameters (CPPs) must be identified, and allowable ranges determined to maintain product quality. This process includes establishing design space as per ICH Q8 guidelines, which delineates the flexibility available in process parameters while ensuring quality attributes are consistently met.

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During this phase, it is essential to conduct a series of studies to understand how variations in the input materials and process parameters impact the product. This data informs the development of a robust process control strategy. Moreover, failure to adequately develop a comprehensive process design can lead to complications during the qualification phase.

  • Documentation: Process flow diagrams, control strategy documents, design space reports.
  • Data Requirements: Experimental data from design of experiments (DOE) studies; stability data.
  • Regulatory Expectations: Align with ICH Q8 (Pharmaceutical Development).

Step 3: Qualification – IQ, OQ, and PQ

Following the development of the process, the qualification stage is where Installation Qualification (IQ), Operational Qualification (OQ), and Performance Qualification (PQ) come into play. This validation approach ensures that every aspect of the equipment, processes, and systems meets predetermined requirements.

Installation Qualification (IQ) verifies that the equipment is installed according to manufacturer specifications. This process includes confirming the correct installation of all utilities used in the manufacturing process.

Operational Qualification (OQ) assesses whether the equipment operates within accepted parameters across its intended operational range. Testing might incorporate stress testing under operating conditions to validate that the equipment consistently operates as expected.

Performance Qualification (PQ) evaluates the process using actual products to demonstrate consistent performance over time. Defined acceptance criteria must be met to validate this testing stage.

  • Documentation: IQ, OQ, and PQ protocols and reports.
  • Data Requirements: Test results, deviation reports, and re-validation procedures if any tests fail.
  • Regulatory Expectations: Comply with FDA’s Process Validation Guidance.

Step 4: Process Performance Qualification (PPQ)

Process Performance Qualification (PPQ) is an essential step that verifies the process operates successfully within its defined limits when scaled from a pilot to commercial scale. It involves running the process under normal production conditions to ensure that it meets all quality specifications consistently.

A minimum of three consecutive batches should be manufactured, ideally under production conditions to comprehensively assess process variability. During PPQ, testing must include both in-process controls and end-product testing, where applicable, to verify finished product quality attributes align with the predefined acceptance criteria.

  • Documentation: PPQ protocols and reports detailing batch information, test methods, and results.
  • Data Requirements: Statistical analysis should be employed to establish process capability. Control charts may also be beneficial.
  • Regulatory Expectations: ICH Q8, Q9, and Q10 compliance issues are critical during PPQ execution.
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Step 5: Continued Process Verification (CPV)

Once PPQ is successfully completed and the process is validated, Continued Process Verification (CPV) must be implemented. CPV reflects a proactive approach of quality by design, leveraging real-time data gathered through manufacturing processes. The aim is to maintain control over the process and product quality through statistical process control (SPC).

CPV includes ongoing monitoring of CPPs and product quality attributes, and deviations should be thoroughly documented and investigated. Additionally, timely updates to the process risk assessments based on new data trends is crucial for maintaining compliance and ensuring product consistency.

  • Documentation: CPV plans, monitoring reports, data analytics outcomes.
  • Data Requirements: Real-time process data, historical trends, deviation reports and CAPA documentation.
  • Regulatory Expectations: Adhere to ICH Q10 and FDA’s expectations for continuous improvement.

Step 6: Revalidation

Revalidation is a critical component of the ongoing lifecycle management of pharmaceutical processes, involving periodic review of processes and systems to ensure continued compliance and performance. Revalidation may be triggered by significant changes in raw materials, equipment alterations, facility changes, or market changes influencing product quality.

Revalidation efforts should align with current manufacturing practices and validated processes. A risk-based approach should guide the revalidation strategy, utilizing a robust change control management system to assess the need for revalidation activities. Conducting thorough assessments and subsequent validations not only ensures product consistency but also allows for a robust path forward for newer improvements in technology or methodology.

  • Documentation: Revalidation protocols, impact assessments, final reports highlighting the decisions made.
  • Data Requirements: Evidence of all proposed changes and how they impact the final product.
  • Regulatory Expectations: Consistent with CRM expectations per ICH Q10.
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Conclusion

Successfully scaling processes from pilot to commercial scale requires meticulous attention to validation across multiple stages. Each step, from URS and risk assessment through process revalidation, plays a critical role in maintaining compliance with regulations, ensuring product quality, and minimizing risks. By following a structured approach aligned with regulatory expectations such as FDA Process Validation Guidance and ICH guidelines, pharmaceutical companies can enhance their target validation in drug discovery efforts and ensure the delivery of safe and effective products to the market.