Commissioning, Qualification and Validation
No deviation is a trusted partner for your commissioning, qualification, process performance qualification, re-qualification, and process verification since 2007.
We started providing commissioning, qualification and validation services in one of the most complex processes of the industry, which is vaccine manufacturing.
We have improved our risk-based qualification and validation capabilities, helped by the fact that we adopted the ASTM E2500 paradigm early-on.
Depending on your requirements and project maturity, we could ensure a full risk-based paperless validation with integrated commissioning and test plan or make your existing paper-based IQ,OQ execution efficient.
By understanding the critical aspect of your process, No deviation will help you translate the process needs into the user requirement (URS) and functional specifications (F5), which will be a point of reference throughout the validation lifecycle.
Those URS will be the source of your acceptance criteria for the systems qualification and process validation. Starting with the design qualification (DQ) where the compliance of the design with GMP would be demonstrated and documented, as mandated in the EU GMP Annex 15.
From there, risks to the product quality attribute (CQA) would be assessed and we will define the testing strategy for facility and process equipment commissioning (FAT,SAT) to qualification (IQ,OQ) to process performance qualification and continuous verification.
Frequently Ask Questions
Expert Answers to your Commissioning, Qualification and Validation (CQV) questions
Commissioning, Qualification, and Validation (CQV) are systematic approaches used in the pharmaceutical industry to ensure that the facilities, equipment, and processes perform as intended to produce pharmaceutical products that meet predetermined quality standards. The process is critical to ensure safety, efficacy, and quality of drugs, which are heavily regulated by governmental agencies such as the FDA (Food and Drug Administration) in the United States and the EMA (European Medicines Agency) in Europe.
Commissioning involves checking and testing that the equipment and systems are installed correctly and are operational. It is the initial stage where the design intentions are thoroughly tested to ensure they meet the operational needs of the manufacturer.
Qualification is the next step and is part of validation. It involves testing and verifying that equipment and systems are capable of consistently operating according to their intended use and specifications. Qualification is often broken down into Installation Qualification (IQ), Operational Qualification (OQ), and Performance Qualification (PQ).
Validation is the final step, ensuring that manufacturing processes, systems, and equipment can consistently produce a product meeting its predetermined specifications and quality attributes. Validation is broader and includes process validation, cleaning validation, method validation, and computer system validation.
Although CQV processes are interconnected and sometimes used interchangeably, they have distinct focuses:
Commissioning is focused on ensuring that the facility, systems, and equipment are installed according to the manufacturer's specifications and design intentions. It's about making sure everything is set up correctly before it's tested for operational performance.
Equipment Qualification is a subset of the overall qualification process, specifically focusing on ensuring that equipment is installed, operates as intended, and performs consistently within specified limits. It's more about the capability of the equipment itself rather than the process it's used for.
Process Validation is concerned with the end-to-end process, ensuring that it is capable of consistently producing a product that meets quality specifications. It's a comprehensive evaluation of the process design and development, including manufacturing steps, operating parameters, and environmental conditions.
The duration of the CQV process can vary significantly depending on the complexity of the facility, equipment, and processes being validated, as well as the regulatory requirements of the specific pharmaceutical product. In general, CQV can take from several months to a few years. Factors influencing the timeline include:
- Scope and size of the project: Larger facilities with more complex systems will take longer to commission, qualify, and validate.
- Regulatory environment: Different countries and products may have varying regulatory requirements that can impact the duration.
- Complexity of the product and process: More complex products and processes typically require more extensive validation efforts.
- Modifications and optimizations: Changes made during the CQV process based on findings can extend the timeline.
- Availability of resources: Limited access to skilled professionals or equipment can delay the process.
Project planning, effective communication, and having a clear understanding of regulatory requirements are critical to managing the duration of the CQV process. Continuous documentation and adherence to a well-structured project management plan can help streamline the process and ensure timely completion.
The CQV (Commissioning, Qualification, and Validation) process in biotechnology and medical devices is governed by a framework of regulations and guidelines. These regulations aim to protect public health by ensuring the safety, efficacy, and quality of biotechnological products and medical devices. The main regulatory bodies and guidelines governing these processes include, but it not limited to:
For Biotechnology:
FDA (U.S. Food and Drug Administration):
21 CFR Part 211 - Current Good Manufacturing Practice for Finished Pharmaceuticals, which outlines the requirements for the manufacturing, processing, packing, or holding of drugs.
21 CFR Part 600 - Biological Products: General, which includes provisions related to the manufacture, safety, and efficacy of biologic products.
EMA (European Medicines Agency):
EudraLex Volume 4 - Good Manufacturing Practice (GMP) guidelines, which provide guidance for the production and quality control of medicinal products and active substances.
ICH (International Council for Harmonisation of Technical Requirements for Pharmaceuticals for Human Use):
ICH Q7 - Good Manufacturing Practice Guide for Active Pharmaceutical Ingredients, addressing the specifics of manufacturing APIs under an appropriate system for managing quality.
ICH Q8, Q9, Q10, and Q11 - Guidelines covering pharmaceutical development, quality risk management, pharmaceutical quality systems, and development and manufacture of drug substances.
For Medical Devices:
FDA (U.S. Food and Drug Administration):
21 CFR Part 820 - Quality System Regulation, which outlines the regulatory requirements for the design, manufacture, packaging, labelling, storage, installation, and servicing of medical devices intended for human use.
Guidance on Software Validation - For medical devices that include software or are software-based, specific guidance on software validation is applicable.
International Organization for Standardization (ISO):
ISO 13485 - Medical Devices - Quality management systems - Requirements for regulatory purposes, which specifies requirements for a quality management system where an organization needs to demonstrate its ability to provide medical devices and related services that consistently meet customer and applicable regulatory requirements.
European Union (EU):
Medical Devices Regulation (MDR) 2017/745 - A regulatory framework for medical devices, including more stringent post-market surveillance and traceability requirements.
In Vitro Diagnostic Medical Devices Regulation (IVDR) 2017/746 - For devices intended for the in vitro examination of specimens derived from the human body.
Other Guidelines and Standards:
GAMP (Good Automated Manufacturing Practice) - Guidelines for the validation of automated systems in pharmaceutical manufacturing, which are widely accepted in both the biotechnology and medical device industries for the validation of computerized systems.
Compliance with these regulations and standards is essential for companies in the biotechnology and medical device sectors, not only to ensure the safety, efficacy, and quality of their products but also to facilitate global market access.
Yes, No deviation offers end-to-end CQV services, guiding projects from design to documentation. Our experts ensure compliance with the latest pharmaceutical, biotech, and medical device standards, streamlining the path to market readiness. Check out our comprehensive range of services to support you at https://nodeviation.com/services/
Several regulations and guidelines emphasize the importance of risk management within the Commissioning, Qualification, and Validation (CQV) process. Notable regulations include:
- FDA Regulations (U.S. Food and Drug Administration): FDA regulations, such as 21 CFR Parts 210 and 211 for pharmaceuticals and 21 CFR Part 820 for medical devices, require manufacturers to establish and follow procedures for quality assurance, including validation of processes and equipment. These regulations emphasize the need for risk-based approaches to validation, where risks to product quality, patient safety, and regulatory compliance are systematically identified, assessed, and mitigated.
- ICH Guidelines (International Council for Harmonisation of Technical Requirements for Pharmaceuticals for Human Use): ICH guidelines, particularly ICH Q9 on Quality Risk Management, provide a framework for implementing risk management principles throughout the product lifecycle. It emphasizes the importance of integrating risk management into quality systems, decision-making processes, and validation activities. ICH Q9 encourages the use of risk assessment tools to prioritize validation efforts based on the level of risk posed to product quality and patient safety.
- EU GMP Regulations (European Union Good Manufacturing Practice): EU GMP regulations, outlined in Annex 15 for qualification and validation, require pharmaceutical manufacturers to establish a systematic approach to validation, including risk assessment and risk management. Annex 15 emphasizes the need to identify and evaluate critical process parameters, potential failure modes, and associated risks during the qualification and validation of facilities, equipment, and processes.
Within the context of these regulations and guidelines, risk management plays a vital role in the CQV process for pharmaceuticals and medical devices:
- Identification of Risks: Manufacturers are required to systematically identify potential risks to product quality, patient safety, and regulatory compliance throughout the CQV process. This includes risks associated with equipment failure, process deviations, and environmental factors.
- Assessment of Risks: Risk assessment tools and methodologies are utilized to evaluate the severity, likelihood, and detectability of identified risks. This enables manufacturers to prioritize validation activities and allocate resources effectively based on the level of risk posed.
- Risk Mitigation: Manufacturers develop and implement risk mitigation strategies to reduce or eliminate identified risks. This may involve implementing control measures, process improvements, and contingency plans to ensure product quality and patient safety.
- Documentation and Traceability: Comprehensive documentation of risk management activities is essential to demonstrate compliance with regulatory requirements. This includes documenting risk assessments, mitigation strategies, and validation outcomes to ensure transparency and traceability throughout the CQV process.
- Continual Improvement: Risk management is an iterative process that requires ongoing review and reassessment. Manufacturers continually monitor and evaluate risks, making adjustments to validation strategies and risk mitigation measures as needed to adapt to changes in the manufacturing environment or emerging threats.
Overall, adherence to regulatory requirements and guidelines ensures that risk management is integrated into the CQV process, enabling pharmaceutical and medical device manufacturers to maintain product quality, patient safety, and regulatory compliance throughout the product lifecycle.
If you need further support, you can schedule a call with us by providing your details below or email us at hello@nodeviation.com
In general, digitalization in Commissioning, Qualification, and Validation (CQV) is reshaping the life sciences industry, including pharmaceuticals, biotechnology, and medical devices. This shift towards digital technologies aims to enhance efficiency, accuracy, compliance, and overall process integrity. Key elements of this trend include:
- Adoption of Electronic Documentation: Moving from paper-based to electronic systems to streamline record-keeping, improve accessibility, and ensure data integrity, complying with regulatory standards such as FDA’s 21 CFR Part 11. Check out an article by No deviation at https://nodeviation.com/using-kneat-in-process-validation-for-the-pharma-industry/.
- Implementation of Automated Systems: Using automation and software tools for more efficient execution of CQV tasks, reducing manual labour, minimizing errors, and improving reproducibility.
- Integration of Advanced Technologies: Incorporating IoT for real-time monitoring, and Artificial Intelligence (AI) and Machine Learning (ML) for predictive analytics and process optimization, providing insights into process performance and product quality.
- Enhanced Collaboration and Accessibility: Utilizing cloud-based platforms and collaboration tools for better communication and access to documentation among project teams and stakeholders, supporting agile project management.
- Data-driven Decision Making: Emphasizing data integrity and analysis for informed decision-making throughout the CQV process, enabling continuous improvement and compliance.
- Focus on Cybersecurity and Data Privacy: Ensuring the security and privacy of sensitive data through robust cybersecurity measures and compliance with data protection regulations, such as the General Data Protection Regulation (GDPR) and Health Insurance Portability and Accountability Act (HIPAA) in the United States.
- Regulatory Acceptance and Guidance: Regulatory bodies such as the FDA and the European Medicines Agency (EMA) are increasingly accommodating digital approaches within their guidelines, encouraging the adoption of digital tools to improve product quality and patient safety, as outlined in regulatory documents such as the FDA's Guidance for Industry on Process Validation and the EMA's Guideline on Process Validation for Finished Products - Information and Data to Be Provided in Regulatory Submissions.
This trend is exemplified by platforms like Kneat, which offers comprehensive solutions for digitalizing and streamlining CQV processes in the pharmaceutical industry. Overall, digitalization in CQV aims to reduce time to market, lower costs, and enhance compliance and product quality. This trend is expected to evolve further, leading to more sophisticated digital solutions and transformation of CQV practices in the pharmaceutical sector.
Commissioning and Qualification (C&Q) are critical for ensuring patient safety in the pharmaceutical and medical device industries by ensuring products are consistently manufactured to high quality and regulatory standards. Here’s why C&Q is so important:
- Product Quality and Consistency: C&Q ensures equipment and systems operate within specified limits, directly affecting the safety and efficacy of pharmaceutical products and medical devices.
- Regulatory Compliance: Adhering to regulatory standards through C&Q demonstrates a commitment to manufacturing safe, effective products.
- Risk Management: Identifies and mitigates risks to product quality and patient safety early in the manufacturing process.
- Process Validation: Validates that manufacturing processes are robust and reliable, producing safe products consistently.
- Documentation and Confidence: Provides documented evidence that manufacturing processes meet safety and quality standards, building trust among regulators, healthcare providers, and patients.
- Continuous Improvement: Involves ongoing evaluation and requalification to maintain safety and quality standards over time.
C&Q directly impacts the safety and efficacy of healthcare products, playing a vital role in protecting patients and ensuring the delivery of safe, high-quality products.
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