Calibration

This article
presents the
infrastructure of
a GMP
compliant
Calibration
Program based
on technical and
metrology
mythology.

Recommendations for Implementing a

Calibration Program
by Yefim S. Gudesblat, PE

Introduction

his article is limited to the principles of

organization for calibration work in
relation to cGMP and other pharmaceutical standards. Calibration and metrology methods related to actual calibration
techniques, statistics, and theories are not explored in our discussions.1 Each class of instruments requires specific techniques and approaches to achieve stated accuracies. All members of the calibration team should be educated
in metrology techniques and skills necessary
for the successful calibration work.
In pharmaceutical applications, performance and accuracy of instrumentation devices are governed by Current Good Manufacturing Practices (cGMPs). Verification of proper
process instrumentation operation is an important factor for finished product in Quality

Assurance (QA) programs. In GPM processes,

outside of validated parameters weighing additions, sterilization temperatures, compounding pressures, and other factors are most likely
not recoverable and costly to the business.
Mistakenly released products within an established QA program could be detrimental to
patients health and manufacturers reputation, including legal implications.5
Proper operation of process systems and
laboratory equipment in the pharmaceutical
environment is critical for product quality,
manufacturing cost, and research development.
Processes controlled by instrumentation outside of defined tolerances, presumably irreversible, will lead to distraction of affected
materials and rise of production costs. Incorrect data of laboratory instrumentation and
measurements could delay development and

Figure 1. Facility
instrumentation
configuration diagram.

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Continued on page 102.

Calibration

Figure 2. Interactions between preventative maintenance and calibration programs.

release of new products resulting in potential losses of the

market share.
The Product Master File and Batch Records contain information concerning weighing specifications, sterilization requirements, compounding parameters, and other details of
scientifically developed process tolerances. Production recipes include sequential order of all process activities and
permitted fluctuations. Maximum and minimum tempera-

tures for sterilization, weights of each chemical addition,

mixing time, and feeding rates are examples of windows for
validated parameters critical in determination of final pharmaceutical product quality.2
Precision of data in research and development applications is one of the requirements associated with current Good
Laboratory Practices (cGLPs). Good calibration record keeping and maintenance of standards and instruments are
Continued on page 104.

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Calibration
Selected Functions of Calibration
Program

Functions of Preventative Maintenance Program

in relation to Instrumentation and Measurements

Description of Differences or Comments

Field calibrators are certified as

traceable to NIST. Failures of field
calibrators will result in product hold
and investigations.

Field calibrators are functional but not necessarily

traceable to NIST. Calibrators functional or calibration
failures will be limited to equipment retests only.

Instruments subjected to calibration program require greater

functional analysis than devices under preventative maintenance
program. For example, failure of calibrators used for sterilization
processes and calibrators used for balancing temperature in
office areas will generate different responses.

Calibration and process tolerances

are specified for the process
operating range and instrument
operating range.

Instruments and loops functional performance are

defined for control and monitoring processes of nonGMP areas.

Product quality could be directly or indirectly affected by out of

tolerance instruments in the Calibration program. Instruments
under preventative maintenance program have functions of
convenience, energy cost, effectiveness or comforts.

Documentation of performed
calibration is filed under calibration
program.

Documentation of performed preventative maintenance

is filed under preventative maintenance calibration
program.

There should be no difference in documentation filing and

retrieval between calibration and preventative maintenance
programs.

Calibration schedules and frequencies are under periodic review and

approval.

Preventative Maintenance schedules and frequencies

are under periodic review and approval.

Both programs could be defined by one database and divided by

Critical, non-Critical and Maintenance categories.

Instruments, loops and systems

calibration failures will trigger
notification, investigations, product
hold, etc.

Instruments, loops and systems functional failures will

necessitate repairs and possible notifications.

Calibrated instruments and loops are traceable to calibrators and

standards. It is a good practice to use calibrated instrument in
preventative maintenance work. However, strict instrumentation
traceablilety is not necessary.

Table A. Similarities and differences between calibration and preventative maintenance programs.

necessary for expected reliability of experimental outcomes.

Introductions of new drugs to the market could be affected by
failures of upholding metrology standards in science laboratories.
The purpose of this article is to review in a general format

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a Calibration Program suitable for the pharmaceutical industry. In addition, a discussion of engineering methods for
process specifications and theory of calibration requirements
in reference to pharmaceutical process procedures, operation/laboratory methods, and standards for instrumentation

Calibration
tolerances will be outlined.
Weighing additions of chemical components, process temperatures, pressures, flows, etc., will naturally fluctuate from
batch to batch. Therefore, cGMP requires that Standard
Operating Procedures (SOPs) for validated pharmaceutical
processes will cover maximum allowed fluctuations for specified parameters. Products made outside of critical control
defined specifications will oblige sanctions of product on
hold for investigation. An almost certain outcome from
investigations will lead to destruction or rework of manufactured material.
Permitted variations in processes need to agree with the
equipment and instrumentation capabilities. Qualification
tests and procedures for instruments in validated processes
will provide the necessary assurance of accurate process
executions. Verification of the instruments compliance to the
process requirements is an important phase for the system
qualification and validation. Selections of calibration procedures, calibration frequencies, and certification methods for
instruments, sensors, control loops, and systems depend on
applications, accuracies, and characteristics of instruments
stability.
Data of pharmaceutical manufacturing processes and laboratory testing are limited by the instrumentation accuracy.
Product quality compliance requires calibration standard
certification traceable to National Institute of Standards and
Technology (NIST). Calibration procedures work with for-

mats of records to establish documentation layout and flow

designed to assure traceability of collected data. Verification
of instrumentation measuring devices performance is comprised from two parts. One is a calibration certification and
the other is a calibration check. The calibration certification
summarizes a methodical process defined by a written and
approved procedure developed for a range of measurements.
A calibration check is a simplified confirmation of the instrument, loop, or device performance. Usually calibration checks
are represented by one or two test measurements.
A successfully executed calibration procedure confirms
that manufacturing processes and laboratory experiments
are not affected by the tested instrument within the last
calibration time interval. Calibration failure in the as found
data will necessitate an investigation of the product produced
within the last calibration period. In the laboratory environment, all tested lots will be affected by an instrument calibration failure. Strict procedures are required for notification of
calibration failures. Adjustments of the instruments found
out of tolerance should be controlled by Standard Operating
Procedures (SOPs). Each SOP should contain instructions for
adjustments or reference them to published literature. For
investigation purposes, some instruments could require additional testing and may not be adjusted or repaired inimitably. Investigational tests may be needed to determine a
magnitude of losses or requirements for application/design/
replacement of an instrument.

Continued on page 106.

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105

Calibration

Figure 3. Process of calibration request approval.

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Calibration
Properly established instrumentation tolerances, calibration procedures, and instruments functional tests are very
important issues for product development, quality assurance
programs, and production costs. CGMP/cGLP metrology program issues related to laboratory instruments, manufacturing capabilities, process tolerances, and calibration methodology are addressed in this article. Actual calibration techniques and metrology requirements related to standards,
uncertainty rations, instruments bias, precision, and accuracy are outside of the scope of work for this article.

Managing a Calibration Program

A modern pharmaceutical facility is dependant on thousands
of instruments installed in operations, utilities, laboratories,
and development areas. Proper functions and accuracies of
those instruments are maintained by a Calibration Program.
Tasks of a Calibration Program are interfaced with a Preventative Maintenance Program and Quality Assurance activities.6
The process of review and approval of Preventive Maintenance activities needs to address requirements of pre and
post calibration data. The critical path formula of Pre-Calibration, Preventive Maintenance work, and Post-Calibration
is necessary for the system integrity assurance. Calibration
and Preventive Maintenance programs cannot function as
independent programs. In many cases, Preventive Maintenance could disturb instrumentation and unfortunate discov-

eries during Calibration work will lead to quality investigations, production loses, and poor business reviews.
Interfacing of Calibration and Preventive Maintenance
work requires maintenance, engineering, and quality reviews. Preventive Maintenance and Calibration tasks for all
systems and devices need initial and periodic evaluations for
assurances of production/experimental consistency and repeatability. The outcome of these reviews should be outlined
in specific procedures. For example, Preventive Maintenance
work associated with control valves, removal, and reinstallation of instruments will necessitate coordination with calibration activities. Bearing greasing, belts replacements, and
other mechanical work may not require links to the calibration program.
An established Calibration Program needs to address the
following functions:
I.

Documentation records of instruments for traceability

and application requirements in accordance with the
industry standards of metrology.

II. Continued enforcement of approved calibration SOPs.

Reviews and recommendations for modifications of calibration SOPs based on the inputs from Preventative
Maintenance and Quality Assurance. Development of
new SOPs.
Continued on page 108.

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107

Calibration
III. Notification of calibration failures to appropriate departments. Investigations of calibration failures and assistance to affected departments by providing technical
expertise and improvements.
IV. Maintaining calibration schedules and coordination with
production and maintenance activities.
Each of the above functional topics represents specific responsibilities and procedures of a comprehensive calibration
program.3 Descriptions of internal and external configuration correlated to functional topics are very important for
understanding the scope of calibration work.

I. Documentation Records of Instruments

for Traceability and Application
Requirements in Accordance with the
Industry Standards of Metrology
All instruments should be recorded on an approved single
format Instrument Data Form. The form should be able to
describe and identify a single instrument, sensor, loop, display, system, etc. The information from the manuals and
cutsheets of instruments include manufacturing model, serial
number, input/output units of measurement, resolution, and
accuracy. This information should be properly placed on an
Instrument Data Form. Consequences of instrument performances and failures related to processes should be provided

by engineering, process development groups, and technical

services. This information is needed to identify each instrument as critical or not critical, calibration frequency, and
tolerances in reference to the final product quality requirements.
Each of the critical and non-critical instrumentation could be
divided into several subcategories. That division may be
necessary to establish multi-level procedures for calibration
failure notification and actions. The following sections of this
article will provide a general discussion of critical and noncritical categories without subcategories.
Instrument review procedures in a calibration program
need to identify each device, loop, and system with a calibration number. This number will stay with each instrument,
loop, or system and will be retired from the program after
removal of the instrument or loop/system modification. Calibration numbers need to work within an establish database
to assure historical traceability (replacements and modifications) for all control elements of production and research
equipment. Figure 1 represents a sample diagram for configuration of facility instrumentation. The Instrument Data
Form requires the location of an instrument, loop, and system
(including interconnected references) to be recorded. For
example, a form for a temperature sensor, transmitter, or
controller should identify the location in the loop, system, and
plant area (factory). Each loop or system needs to reference
instruments and devices employed in the application. Bidirectional referencing is a very important factor for effective
performance of a calibration program.
Instrument calibration numbers need to be interfaced or
in many cases integrated with the preventative maintenance
program for production machines and devices. It is acceptable for the function verification of non-critical instruments
to be addressed by the plant preventative maintenance program. Non-critical gauges and displays utilized for reference
only could be checked or periodically replaced within a preventative maintenance program. The Calibration Program
could employ a separate category of maintenance devices. For
example, some HVAC control loops may be covered by the
preventative maintenance (calibration) program. Table A
demonstrates similarities and differences between calibration and preventative maintenance functions in relation to
instrumentation testing.
The process of an instrument calibration review flow
chart is presented in Figure 2. The Maintenance and Calibration work need integration for the following reasons:
Calibration schedules must be coordinated with preventative maintenance schedules. Preventative maintenance of
a system immediately after calibration will void all calibration efforts. Calibration should be a conclusion of
preventative maintenance work.
All instruments require performance verification. However, the detailed periodic calibration with documented
traceable standards is not necessary for maintenance
Continued on page 110.

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Calibration
gauges, HVAC controls, and many other devices. The
preventative maintenance functions within the Calibration Program can satisfy the need for verification for such
devices without traceable documentation for standards
and detailed records.
Figure 3 summarizes the necessary steps for finalizing and
approving calibration documentation. In the process of development or modification of a calibration program, those steps
could be subdivided or combined to satisfy company policies,
personal need of technical staff, or availability of equipment
and software. A brief description for each step is presented
below:
1. The first step is dedicated for instrument identification
with cross-reference to control loops, systems, and locations. References of the instruments to loops and system
should be bi-directional. In this step, information is recorded about manufacturing operational data, devices
models, operating software, serial numbers, I/O inputs,
etc.
2. The second step requires review of the instruments impact on product quality. This step will collect information
necessary to determine instruments, loops, and system
alliance and placement under calibration or preventative
maintenance programs.
3. This step is allocated for instruments under calibration
program and will require coordination of tolerances. Calibration limits will be determined from coordination of
tolerances. Recorded and approved calibration limits will
be used to initiate suitable procedures to notify appropriate departments of calibration failures.
Coordination of tolerances is a very important factor for
setting process calibration limits.4 This information should
be extracted from engineering and process development information. Based on instrument/loop capabilities and process requirements, calibration procedures should include two
sets of limits. After exceeding the first set of limits the
instrument or loop should be subjected to adjustments. No
calibration failure notices will be necessary. If the instrument or loop calibration data exceeds the second level of
limits then calibration failure notifications will be necessary.
For graphical interpretations see Figure 4. Calibration limits
usually are determined by experience, but process limits are
established from the process requirements and engineering
calculations.

II. Continued Enforcement of Approved

Calibration SOPs. Reviews and
Recommendations for Modifications of
Calibration SOPs Based on the Inputs From
Preventative Maintenance and Quality
Assurance. Development of new SOPs.
Periodic SOP reviews and GMP training are very important
factors for a successful calibration program. SOP reviews
should reflect changes in facility processes, quality assur-

ance, and preventative maintenance programs. GMP training is a requirement for maintaining personnel qualifications
at an acceptable level.
New and modified processes will require creation or modifications of specific SOPs. Periodic reviews will assure that
single changes of one SOP have not created contradictions
and discrepancies in the integrity of the calibration program.
Those reviews or audits should be conducted by quality,
engineering, and production representatives.
Training of personnel should be focused on actual documentation procedures and metrology techniques. It is advisable for members of a calibration team to join professional
societies. Participation in the Instrument Society of America
and National Conference of Weights and Measurements will
improve and broaden technical skills of technicians and
engineers. The staff responsible for implementation of technical tasks within the frame of a calibration program must
maintain and continuously improve their knowledge in instrumentation and metrology.3

III. Notification of Calibration Failures to

Appropriate Departments. Investigations of
Calibration Failures and Assistance to
Affected Departments by Providing
Technical Expertise and Improvements.
Procedures of a calibration program for pharmaceutical applications should be able to categorize instruments, loops,
and systems in several levels of criticality. Instruments
involved in the final product quality tests will be the most
critical and devices collecting duplicate data will be less
critical. Different organizations may adapt specific and most
appropriate terminology for a system to categorize instruments.
The majority of calibration programs choose the use of
primary standards. Primary standards are instruments,
materials, and devices utilized for testing (calibrating) field
calibrators. Primary standards are directly traceable to NIST
traceable laboratories. Field calibrators are traceable to
primary standards. Sometimes primary standards are used
for field calibration also. All instruments, loops, and devices
must be traceable to calibrators. Calibration failures of primary or field calibrators will trigger investigations of processes affected by instruments traceable to failed calibrators.
A failure of an instrument or a loop calibration indicates
that all product or testing material affected by the instrument requires investigation for quality of compliance. Investigation periods will be extended to the date of the previous
calibration. All products manufactured and tested between
the last acceptable calibration and the current failure of
calibration require an investigation.
Instruments of a failed calibration in different applications will require:
a) immediate adjustment, repair, or replacement, or
b) no adjustment or repairs until additional testing of the
failed instrument and process is conducted
The actions above must be pre-selected for each instrument,
Continued on page 112.

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Calibration

Figure 4. Limits of calibration process and tolerances.

loop, and system, and clearly identified by specific SOPs. The

actions a and b could be associated with the level of criticality of instruments and processes. Therefore, instrument
calibration frequencies should be set with considerations and
risk assessments of processes.
Calibration failures will affect all processes and instruments calibrated with the defective calibrator. Calibration
failure of instruments in a quality assurance laboratory could
have the same or larger specter of issues. Calibration failures
of critical instrumentation could put product on hold, recall
and/or destruction.
Properly engineered systems with correctly selected instruments and a practical calibration program will effec-

tively minimize nuisance calibration failures. One part of the

calibration program consists of continuous/periodic evaluations of the processes and instrumentation to assure good
cGMP compliance.

IV. Maintaining Calibrations Schedules and

Coordination with Production and
Maintenance Activities
Calibration instruments, loops, and system must be carefully
scheduled for calibration. Calibration work requires shutdown of production and laboratory testing. In production
environments, calibration of water systems, continuous sterilizers, and other systems will necessitate a major shutdown.
Concludes on page 114.

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Calibration
Calibration work requires diligence, dedication, and objectivity. Therefore, system shutdowns should be scheduled with
adequate time delegated for calibration and coordination
with other perhaps preventative maintenance activities.
Calibration schedules must be very closely monitored.
Overdue scheduled calibrations should be considered as
serious events and treated with commitments to avoid any
possible future delays. If an instrument calibration is overdue, then production/laboratory stop notices should be immediately forwarded to appropriate departments for shutdown
of instruments and associated processes. Accidentally manufactured products or laboratory work performed with instruments affected by a calibration overdue date will require
investigation and hold of products.
If a cGMP equipment or system is due for removal or
modification then calibration work should be scheduled before work begins. Calibration should be conducted immediately after production ends and before project work starts. To
assure product integrity calibration work is necessary to
verify instrumentation performance as production ends. After project completion (in case of modification), calibration
work will be part of commissioning or validation. If equipment is removed, then the last calibration report will be a
record that product manufacturing was performed under
specified controls.

Conclusion
Calibration work in a pharmaceutical plant should be focused
on the specific applications and not on the capability of
instruments in wide varieties of their potential performances.
The rules of calibration cannot require that all instruments
must be calibrated over the full range of the instrument to the
expected manufacturing accuracies and with a complete
ignorance to the processes. Each system, loop, and instrument should be carefully reviewed for calibration methodology and applicable techniques.
Process instrument calibrations should be done in place,
without instrument removal, and within the loops. Loop
calibration is one of the most desirable methods. Calibration
of instruments before installation and manufacturing certification should be considered as a reference only and acceptable for commissioning. In regulatory environments, calibration procedures of an approved program must be exercised
prior to the beginning of qualifications and validations.
The relationship between an instrument range, process
limit, and instrument tolerances is very important. Process
limits cannot exceed instrumentation ranges and range of
instruments cannot exceed the required process resolution.
For example, gauges with ranges of 0 to 1000 psi and 0 to 25
psi cannot be used in the processes of 20- 30 psi.
In a large number of pharmaceutical processes, an application loop calibration at process limits is acceptable and
considered as a reliable verification of the controlled accuracy. Loop calibrations could be supplemented by individual
device calibrations. For example, if frequency of a loop calibration is quarterly or semiannual then device calibrations
could be set for an annual schedule. After completion of
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individual device calibrations, a loop calibration should be

done to assure proper operation of the loop. Functionalities of
alarms, emergency algorithmic, and sequence of operations
at critical points could be included in calibration procedures.
This article in a general format outlines an infrastructure
of a Calibration Program dedicated to a pharmaceutical
facility. The purpose of the program is an assurance of
instrumentation integrity. A successful calibration program
must be interfaced and integrated with other functional
programs of engineering, production, and quality departments. At the present time, a facility calibration program is
one of the most important factors in the plant compliance and
business performance.

References
1. G.L. Squires, Practical Physics, McGraw-Hill, London,
1968.
2. Handbook 44, 2000 Edition, as adopted by 84th National
Conference of Weights and Measurements 1999.
3. Specific Technical Guidelines from NVLAP Calibration
Laboratories Technical Guide http://ts.nist.gov.
4. Gudesblat, Yefim S., Specification and Calibration Requirements for Industrial Scales in Pharmaceutical Applications, Pharmaceutical Engineering, Vol. 21, No. 5, pp.
82-89.
5. 21 CFR 210, MCA Rules and Guidance for Pharmaceutical
Manufacture and Distribution.
6. GAMP Good Practice Guide: Calibration Management,
ISPE 2002.

About the Author

Yefim S. Gudesblat, PE is presently employed by Baxter,
Inc. He is a Senior Process/Project Engineer responsible for
project management, construction, and design of major engineering projects in ACC
production/research facility. In 1971,
Gudesblat completed his studies in physics
and electrical engineering technology in
Odessa, Ukraine (Formally USSR). He is a
registered Professional Engineer in Pennsylvania, North Carolina, and New Jersey.
Gudesblat has 23 years of experience in the pharmaceutical
industry and has published several articles in leading technical magazines, including Pharmaceutical Engineering. He
was employed by Wyeth, Johnson & Johnson - Merck and a
consulting firm TCPI. He can be reached by tel: 1-856/4892585 or by email: yefim_gudesblat@baxter.com.
Wyeth, 2 Esterbrook Ln., Cherry Hill, NJ 08003.