Who Owns the VMP? Governance Structure in Global Companies



Who Owns the VMP? Governance Structure in Global Companies

Published on 07/12/2025

Who Owns the VMP? Governance Structure in Global Companies

The Validation Master Plan (VMP) is a critical framework that defines the validation strategy and its execution within pharmaceutical organizations. Governance structures ensure compliance with regulatory expectations, particularly under GMP guidelines and relevant regulatory bodies like the FDA, EMA, and MHRA. This article provides a comprehensive tutorial on the validation lifecycle, emphasizing the roles, documentation, and tasks necessary for successful implementation across major validation steps.

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

The first step in the validation lifecycle involves establishing a thorough understanding of the business and regulatory requirements through the User Requirements Specification (URS). The URS is a foundational document that outlines what stakeholders expect from systems or processes.

Key components of a URS include:

  • Functional Requirements: Specifications must identify what functions and capabilities the system or process must deliver.
  • Performance Criteria: Define measurable criteria that must be achieved under various operating conditions.
  • Regulatory Requirements: Incorporate all relevant guidelines from FDA, EMA, and other governing agencies.

Once the URS

is in place, performing a risk assessment is essential. The risk assessment identifies potential failure modes and their consequences, aligning with ICH Q9 principles to understand and mitigate risks throughout the validation process. Failure Modes and Effects Analysis (FMEA) is a widely used method that can assist teams in ranking risks and prioritizing validation activities accordingly, leading to targeted and efficient resource utilization.

Step 2: Protocol Design

With a comprehensive understanding of user requirements and associated risks, the next step involves the design of validation protocols. Each protocol should be meticulously structured to validate critical aspects of processes, equipment, systems, and facilities. Documentation must clearly outline the intent of the validation, scope, methodology, and acceptance criteria.

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A well-structured protocol typically includes:

  • Objective: Outline the purpose of the validation effort.
  • Scope: Define the boundaries, including what is included and what is excluded.
  • Methods: Describe the approach, including any experimental design elements, sampling strategies, and statistical methods that will be employed.
  • Acceptance Criteria: Clearly articulate the critical limits that must be met to ensure that validation is considered successful.

Additionally, statistical criteria are crucial to ensuring that the validation is rigorous. Employing standards such as the GAMP 5 guidelines can aid teams in defining acceptable statistical limits and approaches, thereby aligning protocols with industry best practices.

Step 3: Qualification – Installation, Operational, and Performance Qualification

Qualification is the technical component of the validation strategy. It typically comprises three stages—Installation Qualification (IQ), Operational Qualification (OQ), and Performance Qualification (PQ)—which collectively ensure that systems operate consistently and according to predetermined specifications.

The Installation Qualification phase verifies that equipment and systems are installed correctly and function as intended, validating any critical systems such as HVAC or process utilities. It usually entails:

  • A checklist confirming installation against specifications.
  • Documentation of any deviations or changes made during installation.

The Operational Qualification builds on the IQ phase and includes detailed testing under varying operating conditions to confirm the system’s capability. Examples include testing input and output controls, alarm systems, and other operational functionalities.

Finally, the Performance Qualification evaluates the system’s performance long-term under actual production conditions. This stage often requires a series of runs to assess the system’s effectiveness in delivering quality products consistently.

Step 4: Process Performance Qualification (PPQ)

Process Performance Qualification (PPQ) is the critical phase that transitions from qualification to confirming that processes perform consistently over time within established parameters. The PPQ requires robust planning and execution, typically being conducted in a controlled environment matching production settings.

This step relies on initially established specifications and utilizes data generated from multiple production runs. It is essential to have a thorough sampling plan, which outlines how many samples will be taken, from where, and at which stages of the manufacturing process.

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During this phase, utilize tools such as statistical process control (SPC) charts to visualize trends and variations in the process. Assess both in-process controls and final product results to ensure process robustness. Regulatory authorities such as the FDA emphasize the importance of demonstrating a state of control over the manufacturing process to maintain product quality.

Step 5: Continued Process Verification (CPV)

Continued Process Verification (CPV) shifts the focus from validation to verification in real-time, emphasizing routine monitoring of processes to ensure ongoing compliance with pre-established specifications. CPV requires the implementation of a robust monitoring system, which continuously gathers data related to the process and product quality.

Examples of CPV activities include:

  • Routine collection of in-process and finished product measurements.
  • Statistical analysis of variance in production trends.
  • Regular audits of processes and documentation to ensure compliance.

Documentation of CPV will include reports detailing findings, analyses, and recommendations for operational improvements. KPIs should be established to regularly assess the outcomes, ensuring continuous improvement and compliance with both internal requirements and external regulatory expectations.

Step 6: Revalidation and Change Control

Revalidation is a systematic process that occurs when changes are made to any aspect of the validated system or process that might affect product quality. This may include equipment changes, process modifications, or even changes in raw materials or suppliers. An effective change control process is vital for maintaining the integrity of validation efforts.

To ensure effective revalidation, consider the following guidelines:

  • Risk Assessment: Reevaluate the risks associated with the change. Conduct an updated risk assessment to determine if a full revalidation is necessary.
  • Documentation: Maintain clear and accessible records throughout the change control process. This includes documentation of the rationale for the change, assessment results, and any new validation protocols developed.
  • Training: Ensure that personnel associated with the new or modified processes are properly trained and understand the implications of the changes.
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Documentation related to revalidation should align with established regulatory expectations, confirming compliance with guidelines set forth by organizations such as the EMA and the PIC/S. Regularly scheduled internal audits can further assist in identifying areas of improvement and ensure processes are validated continuously over time.

Conclusion

In conclusion, understanding and implementing a structured validation lifecycle is crucial to maintaining compliance and product integrity in the pharmaceutical industry. Each phase, from URS and risk assessment to revalidation, requires meticulous documentation, rigorous testing, and a commitment to continuous improvement. By strictly adhering to regulatory guidelines and industry best practices, organizations can enhance the reliability and quality of their validation efforts, ultimately contributing to improved product safety and efficacy across global markets.