Wednesday 29 January 2014

Root cause & risk analysis in pharmaceuticals - using Fish Borne Diagram


 
Root Cause Analysis using Fish Borne Diagram
 


 


A fishbone diagram is a visualization tool for categorizing the potential causes of a problem in order to identify its root causes.


Did you know?
 

·         It is referred as "fish bone" diagrams because a completed diagram can look like the skeleton of a fish, with the "ribs" representing the causes of an event and the final outcome appearing at the head of the skeleton.
 
·       "Fish bone" diagrams also known as Cause–and–Effect Diagram, Ishikawa Diagram
 
·       The Ishikawa diagram was developed by Kaoru Ishikawa during the 1960s as a way of measuring quality control processes in the ship building industry.
 
·       It is used as risk assessment tool as well.
 
·       The Fishbone diagram cannot solve anything. It is simply an information gathering and managing tool that can be used to help identify potential causes of a certain problems or event.
 
 

The purpose of the Ishikawa diagram is to allow management to determine which issues have to be addressed in order to gain or avoid a particular event.
How to create a fish diagram:
·Create a head, which lists the problem or issue to be studied.
·Create a backbone for the fish (straight line which leads to the head).
·Identify at least four “causes” that contribute to the problem. Connect these four causes with arrows to the spine. These will create the first bones of the fish.
·Brainstorm around each “cause” to document those things that contributed to the cause.
·Continue breaking down each cause until the root causes have been identified.

 

Tuesday 28 January 2014

Importance of Audit trials in Pharmaceuticals


 
 
Importance of Audit trials in Pharmaceuticals
 
 
 

 

Audit trial is a computer-generated and time-stamped record of who did what, when. CFR 21 Part 11 requires audit trails to be generated independently of operators. An audit trail capture all activities related to creating, modifying, and destroying records on a system. The main purpose of the audit trail is to provide assurance for the integrity of the electronic record.

 

Regulatory Requirements for Audit trials

FDA - 21 CFR Part 11

"The Agency intends to exercise enforcement discretion regarding specific part 11 requirements related to computer- generated, time-stamped audit trails (§ 11.10 (e), (k)(2) and any corresponding requirement in §11.30). Persons must still comply with all applicable predicate rule requirements related to documentation of, for example, date (e.g., § 58.130(e)), time, or sequencing of events, as well as any requirements for ensuring that changes to records do not obscure previous entries.

Even if there are no predicate rule requirements to document, for example, date, time, or sequence of events in a particular instance, it may nonetheless be important to have audit trails or other physical, logical, or procedural security measures in place to ensure the trustworthiness and reliability of the records. We recommend that you base your decision on whether to apply audit trails, or other appropriate measures, on the need to comply with predicate rule requirements, a justified and documented risk assessment, and a determination of the potential effect on product quality and safety and record integrity. We suggest that you apply appropriate controls based on such an assessment. Audit trails can be particularly appropriate when users are expected to create, modify, or delete regulated records during normal operation."

MHRA / EU Annex 11

The current text for the MHRA / EU Annex 11 states:
"The system should record the identity of operators entering or confirming critical data. Authority to amend entered data should be restricted to nominated persons. Any alteration to an entry of critical data should be authorised and recorded with the reason for the change. Consideration should be given to building into the system the creation of a complete record of all entries and amendments (an "audit trail")."

An audit trail is a series of records of computer events, about an operating system, an application, or user activities. The auditor can obtain valuable information about activity on a computer system from the audit trail.  Audit trails improve the auditability of the computer system.

Audit trails can assist in detecting security violations, performance problems, and flaws in applications.  
 

Content of the Audit Trail

The audit trail should be inextricably linked to the electronic record. It should be secure and not have the facility for editing or deleting, providing a permanent record.

The main function of the audit trail is to provide assurance for the integrity of the electronic record. For each entry the following information should be recorded.

  • Date and Time Stamp
  • Name of user making change (unique id)
  • Link to the record (Batch No, Record Id)
  • Original Value
  • Changed Value
  • Reason for Change

This should provide the same level of assurance to the record integrity as that of a paper record, that is where a correction or change is made and the operator makes a correction striking though the initial value, enters the new value, provides reason for change and signs and dates the entry.

The audit trail can also provide a record of invalid attempts to log on to the system, to demonstrate the security of the system.

 

21 CFR Compliance for laboratory instruments



 
21 CFR Compliance for laboratory instruments
 

 
Requirements of Part 11 (electronic records; electronic signatures) are:
  • Use of validated existing and new computerized systems.
  • Secure retention of electronic records and instant retrieval.
  • User-independent computer generated time-stamped audit trails.
  • System and data security, data integrity and confidentiality through limited authorized access to systems and records.
  • Use of secure electronic signatures for closed and open systems
  • .Use of digital signatures for open systems.
  • Use of operational checks.
  • Use of device checks.
  • Determination that the persons who develop, maintain or use electronic systems have the education, training and experience to perform their assigned task.
 

Saturday 25 January 2014

Reasons for Ghost Peaks in HPLC analysis










Ghost (Unknown “Phantom”) Peaks
in HPLC analysis



Ghost (“Phantom”) peaks are not real samples peaks; they are contaminant peaks that can appear even when no sample is injected.

Ghost peaks can easily misidentified when they are close to peaks of interest and can leads to erroneous result. Ghost peak can be resulted from impurities in instrument, impurities in sample or impurities in mobile phase.

Probable Causes of Ghost peaks

·       Laboratory sample contamination

·       Column contamination

·       System contamination

·       Contamination from Glassware and Filtration of Reagents

·       Contamination from mobile phase

·       Cary over from the previous injection



The most common reason for ghost peaks originating in the instrument is carryover attributable to the auto-sampler (or manual injector). When the needle is dipped into the vial to aspirate the sample, substances in the sample, which become the source of carryover, are adsorbed to the inside and outside surfaces of the needle. Those substances which are not eliminated even after needle rinsing are carried over to the next analysis, and appear as ghost peaks.

Ghost peak can occur due to degradation of the sample, and such degradation can be inhibited by using an auto-sampler with a vial cooling feature.

Ghost peaks can also be generated from the mobile phase in various ways, including, generation of organic substances in mobile phase due to prolonged use, or dissolution of organic substances from the air in the mobile phase. Mobile phase vial contamination due to topping off existing mobile phase with new mobile phase over a long period of time instead of preparing a fresh bottle each day or for each set of samples. Usage of contaminated organic solvent and/or water to prepare mobile phase.



Why sterile filters are flushing before use?


 
 
 
Why sterile filters are flushing before use?
 
 


Filters have some extractables and may shed particles initially, but process compatibility helps to minimize this. Recognizing this, filter manufacturers generally recommend flushing the filter before use.


 

Sunday 19 January 2014

Colour coding for topical ocular medications.




 
Colour coding for Ophthalmic Preparations
 (US Market)
 
 

 Colour coding is the systematic, standard application of a colour system to aid in the classification and identification of drug products. A colour coding system allows people to memorize a colour and match it to its function.
American Academy of Ophthalmology (AAO) endorsed the uniform use of a colour coding system for the caps and labels of topical ocular medications. The AAO worked with the FDA and the pharmaceutical industry to establish a uniform colour coding system for the caps and labels of all topical ocular medications. Specific Pantone colours were assigned to defined classes of ocular drugs according to the nature of the disease being treated, the product’s side effect profile, and the risk of serious sequelae if a product is inadvertently switched with another. No other topical medications should carry the same colour.
The FDA supports the AAO-recommended uniform colour coding system for the caps and labels of all topical ocular medications. In its Guidance for Industry on Container Closure Systems for Packaging Human Drugs and Biologics, the FDA states: “An applicant [manufacturer] should either follow this system or provide adequate justification for any deviations from the system.”
 
Class
Colour
Pantone Number
Anti-infectives
Tan
467
Anti-inflammatories/steroids
Pink
197
Mydriatics and cycloplegics
Red
1797
Nonsteroidal anti-inflammatories
Gray
4
Miotics
Dark Green
348
Beta-blockers
Yellow
Yellow C
Beta-blocker combinations
Dark Blue
281
Adrenergic agonists
Purple
2583
Carbonic anhydrase inhibitors
Orange
1585
Prostaglandin analogues
Turquoise
326
 

USFDA Pharmaceutical Inspectional findings in 2013 -Most common deficiencies


Deviation management in Pharmaceuticals


Saturday 18 January 2014

Annual Product Quality Review – APQR/APR/PQR


 
Annual Product Quality Review – APQR/APR/PQR
 




Product quality review is an annual evaluation of a pharmaceutical preparation, which looks back at production and quality control data to assess changes, trends and weaknesses.

In other words it is a structured procedure in which all information, changes and dependencies that have arisen during a calendar year with regard to the manufacture and control of a preparation are detected, evaluated and documented and in which suggestions for improvements are recommended.

Importance of PQR in Pharmaceuticals

1.    PQR is a regulatory requirement

CFR 211.180 (e) basically specifies that the quality standard of every product must be evaluated at least once a year based on the current specifications and records to determine whether modifications to product specifications, manufacturing instructions or control procedures are required. 

Chapter 1 (Pharmaceutical Quality System) of EU guidelines also recommends to evaluate the consistency of existing process annually through PQR.  

2.  PQR is an effective quality improvement tool  to enhance the consistency of the existing process & overall quality of the product (PQR helps to highlight any trends and to identify product & process improvements).

3.  PQR will provide a broader view of product data & it can serve as a historical document.

4.  PQR  will capture trends & will help to determine the need for revalidation and changes any.

5.  PQR offers the opportunity to critically examine the functions of internal systems, such as change controls, documentation, storage, investigation of deviations, OOS procedures and the processing of complaints.

6.  In short product review serves as "ongoing validation" and, on the other hand, the data and results obtained are important prerequisites for continuous improvement (CIP). 

PQR Preparation Procedure

         PQR preparation should typically be carried out for each product manufactured in the previous year.

         All documents which directly or indirectly refer to the manufacture and control of a preparation in the period concerned must be investigated.

         Data should be presented in tabular form or in graphical form (i.e., charts or graphs), when applicable.

What data must be given in product quality review?

         A review of starting and primary packing materials used in the FPP, especially those from new sources.

         All analytical results obtained from the certificates of analysis must be recorded and evaluated. The results must be included as averages or individual values, depending on the test item.

         A tabulated review and statistical analysis of quality control and in-process control & finished product results.

         Yield control - The yields at the individual manufacturing stages must be recorded. Losses at critical production stages must be evaluated for possible risk. Yields that fall below the tolerance range must be explained.

         Qualification status of critical equipments, facilities & utilities.

         Change to starting material & product specifications.

         A review of all critical deviations or non-conformances and related investigations.

         A review of all changes carried out to the processes or analytical methods.

         Details of stability testing & process validations etc.

         A review of the results of the stability-monitoring program

          A review of all quality-related returns, complaints and recalls - All internal and external complaints, as well as the affected measures must be presented in order to prevent complaints of a similar kind in the future.

Consequences of PQR

         Process optimisation                     

         Revalidation

         Adaptation of manufacturing or control procedures

         Amendments in current specifications

         Strict change control programs

         Improvement of complaint processing

 
References

         Guidance note on PQR – HSA guideline.

         EU guidelines for good manufacturing practice for medicinal products for human & veterinary use.

         PIC/S PE 009 -10 (effective 01 january2013)