Guidelines For Validation
Guidelines For Validation
Guidelines For Validation
Disclaimer
While the advice and information in these guidelines is believed to be true and
accurate at the time of going to press, neither the authors, the British Society for
Haematology nor the publishers accept any legal responsibility for the content
of these guidelines.
Contents
Introduction
Page 3
Section 1
Glossary
Page 3
Section 2
Page 7
Section 3
Overview
Page 7
Validation flowchart
Page 8
Key Recommendations
Page 10
Section 4
Page 10
Section 5.
Validation policy
Page 10
Section 6.
Page 11
Section 7.
Change Control
Page 12
Page 14
Section 8.
Page 15
Section 9.
Page 17
Page 17
Page 18
Page 21
Section 13.
Page 23
List of appendices
Page 23
Page 24
Introduction
This is a general guideline aimed at providing laboratories a practical framework
required for the introduction or use of any new or change/relocation of
established critical process, equipment, facilities or systems in the transfusion
laboratory. The following areas are covered in detail:
Change Control - a formal system for managing change
Validation - documented evidence that the process meets predetermined
specifications
Qualification - refers to equipment, facilities and systems
This guideline replaces Recommendations for evaluation, validation and
implementation of new techniques for blood grouping, antibody screening and
cross-matching1 and is based on the European Union (EU) Directives2 as
implemented in the UK through the Blood Safety and Quality Regulations SI
2005:50, as amended. 3,
Validation is a requirement of the Blood Safety and Quality Regulations SI
50/2005 (as amended). This guideline should be read in conjunction with:
1. Glossary
Acceptance Criteria
The criteria a software product must meet to successfully complete a test phase
or to achieve delivery requirements.
Accreditation
Procedure by which an authoritative body e.g. Clinical Pathology Accreditation
(CPA) UK gives formal recognition that an organisation e.g. hospital transfusion
laboratory or blood establishment is competent to carry out specific tasks
against defined standards.
Blood component
Therapeutic component of blood prepared at blood establishment includes red
cells, white cells, fresh frozen plasma, cryoprecipitate and platelets
Blood Establishment
Any organisation that is involved in collection and testing of blood or blood
components and their processing, storage and distribution e.g. National Blood
Service Centres. Blood Establishments must be authorised by the Competent
Authority.
Blood product
Therapeutic product derived from human blood or plasma e.g. Anti-D, Intra
Venous Immunoglobulin (IVIg), albumin, plasma derived factor concentrates
Calibration
Demonstration that a particular measuring device produces results within
specified limits by comparison with those produced by a reference standard
device over an appropriate range of measurements. This process results in
corrections that may be applied to optimise accuracy.
Certificates of calibration
Document signed by qualified authorities that testify that a systems
qualification, calibration, validation or revalidation has been performed
appropriately and that the results are acceptable.
Change Control
A formal system of reviewing and documenting proposed or actual change that
might affect the validated status of a system, equipment or process followed by
action to ensure ongoing validated state.
Competent Authority
The designated Competent Authority for the Blood and Safety Quality
Regulations 2005 is the Medicines and Healthcare Products Regulatory Agency
(MHRA) acting on behalf of the Secretary of State.
relevant tests are actually carried out and that materials are not released for
use until their quality has been judged to be satisfactory.
Quality assurance
Quality Assurance is a wide-ranging concept, which covers all matters, which
individually or collectively influence the quality of a product. It is the sum total of
the organised arrangements made with the objective of ensuring that
products/services are of the quality required for their intended use. Quality
Assurance therefore incorporates Good Manufacturing Practice.
Quality Management System
A quality management system provides the integration of organisational
structure and all procedures, processes and resources needed to fulfil a quality
policy.
Quality Manager
The quality manager is the individual who ensures that the quality management
system functions correctly.
Quality Manual
A quality manual describes the quality management system and includes the
quality policy and arrangements for its implementation.
Quality Risk Assessment
A systematic process for the assessment, control, communication and review of
risks to the quality of the drug (medicinal) product across the product lifecycle.
Standard Operating Procedure (SOP)
Written and approved description of essential steps, their sequence,
responsibilities and precautionary measures necessary to assure that
operations can be accomplished routinely and in a standardised manner.
User Requirements Specification (URS)
Provides a clear and precise definition of what the user wants the system to do.
It defines the functions to be carried out, the data on which the system will
operate and the operating environment. The URS defines also any nonfunctional requirements, constraints such as time and costs and what
deliverables are to be supplied. The emphasis should be on the required
functions and not the method of implementing those functions.
Validation
The documented evidence that the process, equipment, facilities or systems,
operating within established parameters, can perform effectively and
reproducibly giving results meeting predetermined specifications.
Validation Master Plan
Describes the areas of activities within which validation is to take place and
provides an overview of the status of planning. It lists the areas, systems and
projects being managed, defines the status of validation for each and gives a
broad indication of when validation is to be completed. It is a general plan and
would normally cover all equipment and processes. It should include all
systems for which validation is planned.
Validation Plan
Description of the validation activities, responsibilities and procedures. It
describes specifically how the validation is to be done and details
responsibilities if the Validation Team.
Validation Protocol
Outlines the objectives of validation of a specific equipment or process, testing
protocol including elements such as installation, operational and performance
qualification and documentation.
Validation Report
Presentation of the results of validation activities, interpretation of the results
and the conclusions drawn. If unexpected results are obtained during validation
testing, it defines what changes will need to be made or what workarounds will
be implemented to mitigate risk.
2. Acronyms and Abbreviations
BSQR
CPA
DQ
FDS
GAMP
GMP
GxP
IQ
MHRA
NPSA
OQ
PQ
QA
QC
QMS
RA
SOP
URS
VMP
3. Overview
The following flowchart identifies all the stages which should be followed when
validating/qualifying facilities, equipment or process within the laboratory. A
further flowchart showing the steps in change control is included within section
7.
Validation Flowchart
Validation Policy
(Strategic Document)
Validation Process
Plan
Protocol
Records
Summary report
DQ - design
qualification
IQ - installation
qualification
OQ - operational
qualification
PQ - performance
qualification
Perform
validation of
Processes (e.g.
methods and
reagents)
Perform
qualification of
equipment,
facilities
and systems
Document
via document
control
system
Training to SOPs
Competency assessments
Implement
3.1 Within the laboratory there should a Validation Policy which is a strategy
document that clearly defines what the validation process is and its purpose
within the laboratory. The policy should make a commitment to maintaining
critical processes and systems in a valid state and should mention applicable
regulations, standards and guidelines that underpin the laboratorys approach to
validation. The validation policy will specify what should be validated and how
validation is executed as defined in the validation master plan. .
3.2 The Validation Master Plan (VMP) details all of the critical processes,
equipment, facilities and systems, when they were last validated and when revalidation is due. The VMP is the operational document which allows the
laboratory to turn the Validation Policy into practice and provides a route map to
how the laboratory ensures critical processes and systems remain valid and fit
for purpose throughout their life-cycle from initial procurement, installation and
routine operation to withdrawal, or replacement. The VMP is a key document
which can be used by laboratories to serve as a tool for ensuring compliance
and may be used by regulatory authorities to check the robustness of the
processes employed in laboratories. The validation policy and VMP may be two
separate documents or integrated as a single document. The VMP should form
part of, or be referenced in, the laboratory quality manual (CPA (UK)
Requirement) 8
3.3 Management of a new (or changed) process, equipment, facilities and
systems should be through Change Control, incorporating a documented
Quality Risk Assessment. Risk assessment is required alongside change
control in order to assess the possible impact of the change so that action can
be taken to reduce or eliminate risk and determine and justify the extent of
validation required.
3.4 Validation Plan. The validation master plan will define the requirement for a
discrete validation plan or in the case of complex systems a series of plans to
validate each component or process. The validation plan will define the need
for a validation protocol(s) describing the scope of the validation and
procedures used.
3.5 A Validation Protocol should be established that specifies how
qualification (Installation, Operational and Performance) of equipment, facilities
and systems or process validation will be conducted. The protocols should be
reviewed and approved both prior to and following execution. The protocol
should specify critical steps and acceptance criteria. The phases of
Validation/Qualification are explained in detail in section 12.2
3.6 Following execution of the protocols a Validation Summary Report should
be prepared detailing the outcome of the validation process. Once all
appropriate training and documentation records are in place the equipment,
facility, system or process can be authorised for use.
5.
VALIDATION POLICY
5.1
There must be a written policy that clearly defines what the validation
and qualification process is and its purpose within the laboratory. The
policy should make a commitment to maintaining critical processes,
equipment, facilities and systems in a valid state and should mention
applicable regulations, standards and guidelines that underpin the
laboratorys approach to validation.
5.2
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6.1
6.2
The VMP should be based on and refer to the Validation Policy (See
section 5). The VMP should clarify:
under what circumstances
who is responsible
how the validation will be performed and documented
how the validated state will be maintained through regular
servicing and calibration and re-qualification.
6.3
6.4
6.5
6.6
Recommendation:
Each organisation should have a VMP in place as part of its
Quality System
The VMP should outline responsibilities for ensuring all
process, equipment, facilities and systems remain validated
7.
CHANGE CONTROL
7.1
7.2
Some laboratory changes e.g. using new equipment of the same type, or
relocating the process may not require any alteration to documented
procedures, but these changes should still be subject to change control.
7.3
7.4
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7.5
Recommendation:
Change Control must be an integral portion of the transfusion
laboratory quality system
Change Control should be achieved through a formal, documented
system to ensure that compliance and quality standards are
maintained during and following a change.
After completion of each stage of change control a formal release
for the next step should be made as a written authorisation.
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YES
Is validation /
qualification required?
NO
Does documentation
need changing?
Yes
Perform
Validation /
qualification
Approve
Documentation
No
No change to
documentation
No additional
training required
Update documentation
via document control
system
Implement
change
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8.
8.1
8.2
8.3
8.4
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8.5
Risk analysis is the estimation of the risk associated with the identified
hazards. It is the qualitative or quantitative process of linking the
likelihood of occurrence and severity of harms. In some risk
management tools, the ability to detect the harm (detectability) is also a
factor in the estimation of risk.
8.6
8.7
8.8
8.9
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9.
9.1
9.2
The URS:
documents the purposes for which a process, equipment, facilities
or systems is required
describes essential (musts) and desirable (wants) requirements.
defines the functions to be carried out
defines the operating environment within which the system will
operate
defines any non-functional requirements such as time and costs
and what deliverables are to be supplied.
9.3
9.4
9.5
9.6
9.7
9.8
9.9
Recommendation:
A URS should be written for all new purchases
10.
10.1
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10.2
10.3
10.4
Recommendation:
A FDS should be written when purchasing large, multi-functional
process, equipment, facilities or systems
11. Validation Process:
Each part of the validation process should be documented. There should
be a written plan for performing each validation to specify who is
responsible for managing and performing the various validation tasks such
as production of validation protocols and approvals of validation
documentation. Validation protocols should be written for each phase of
the validation to include acceptance criteria. The validation plan and the
validation protocols may be combined into a single document. The
outcome of each phase of validation should be recorded and the overall
conclusions, with a scientific assessment of any failures should be
documented in a validation summary report. The validation records and
summary report must be reviewed and approved before putting the
process or system affected into use.
11.1
Validation Plan
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11.3
Validation Records :
11.3.1 The outcome of the various validation tests described in the protocol
must be recorded at the time the tests are performed.
11.3.2 The Validation record pro-formas or test scripts should be used for
recording the outcomes.
11.3.3 When the testing for each validation phase is complete the result must
be reviewed and a summary report produced. The summary report
should confirm that acceptance criteria have been achieved and provide
the overall conclusions.
11.3.4 There should be a scientific assessment of any failures.
11.3.5 At the end of each phase, the validation/qualification records and
summary report must be reviewed by the appointed responsible person
and the decision regarding the acceptability of the validation recorded.
11.3.6 Records should be maintained for minimum of the life of the validated
process/equipment etc.
11.3.7 An example of a validation report is available in Appendix 11.
Recommendation:
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12. Implementation
12.1 Documentation
All the documentation which is part of the validation process should be
maintained by the document control system and retained for a minimum of
15 years or the life time of the process, equipment, facilities or systems,
whichever is the longest. SOPs should be written and authorised prior to
the equipment/method/system being brought into routine use.
12.2 Training
All staff who may be involved in using the equipment that has been qualified
or the system validated must be trained before using the former. Training
and competency assessments should be completed and the records kept.
12.3 Validation Final Summary Report
A Validation Summary Report that cross-references the qualification and/or
validation protocol should be prepared, summarising the results obtained,
commenting on any deviations observed, and drawing the necessary
conclusions, including recommending changes necessary to correct
deficiencies. Any changes to the plan as defined in the protocol should be
documented with appropriate justification. This report should be cross
referenced to the change control document and the quality risk assessment
matrix.
maintenance
cleaning schedules
internal quality controls
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manufacturers instructions
software/hardware upgrades
12.5 Revalidation
Revalidation should be determined and included in the VMP. Revalidation
may occur when no changes, upgrades have occurred and therefore may
not require change control to be undertaken. The timescale for revalidation
should be clearly indicated in the VMP e.g. annual revalidation of transport
boxes
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15. References
1. Scott et al. 1995 Recommendations for evaluation, validation and
implementation of new techniques for grouping, antibody screening and
crossmatching. Transfusion Medicine 1995; 5, 145-150
2. Directive 2002/98/EC
http://ec.europa.eu/health/ph_threats/human_substance/legal_blood_en.
htm
3. The Blood Safety & Quality Regulations 2005 No. 50 as amended (the
principal Regulations) were signed by authority of the Secretary of State
for Health, as were the amending Regulations (SI 2005/1098, SI
2005/2898, SI 2006/2013 & SI 2007/604).
http://www.opsi.gov.uk/stat.htm
Blackwell Publishing Ltd.
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