2. Process Validation Overview & Objective Regulations, Guidance & Internal Controls Validation Lifecycle Approach & Risk Based Model QUEST - Five Step Method to Process Validation Question Understand Evaluate Site Assessment/Implementation Track Basecamp Website Conclusion
3. Process Validation Regulatory Requirements 21 CFR 820 – Medical Device Quality System Regulation Design Validation (820.30) Process Validation (820.75) Inspection Measurement & Test Equipment/Calibration (820.72) Supporting Requirements (i.e. 820.40: Document Control) Guidance Documents ISO 13485 – International Standard for Medical Device QMS’s GHTF SG3 - Process Validation, Risk Management Guidance Internal Documents (Moog & Terumo) Design History File (Who owns design validation and DFMEAs?) Industry Standards for Sensors? Control Plans, Job Travelers and PFMEAs Terumo specification documents or drawings?
4. Regulatory Requirements Design Validation Requirements (820.30) Demonstrates a process is operating within specified limits and consistently produces product complying with predetermined requirements Process Validation Requirements (820.75) Process monitoring & control Change Control & Deviation Management Systems Vitally important if the predetermined requirements of the product can only be assured by destructive testing So… what does this mean for device manufacturers?
5. How is Compliance Demonstrated? Ask yourself the following questions… Have your processes been subject to such scrutiny that the result can be practically guaranteed? Do you have confidence in your manufacturing processes? Do you have scientific evidence that your processes are capable of consistently delivering quality product? Have you demonstrated the process works as intended? Key Point: Documented evidence of process capability is critical
20. Moog Process Validation Discussion Site Audit Review from August 2010… Discuss Process Validation Related Observations/Findings Associated CAPA QUEST Process Question Survey - (Completed) Kick-off meeting, initial walk-through & subsequent on-site visits Understand Supplier processes and industry specific standards Requirements and specifications (Acceptance Criteria) Risk assessment processes & process controls Product expectations from both Moog & Terumo
21. Moog Process Validation Discussion QUEST Process… continued Evaluate Existing process validation elements employed by Moog Opportunities to improve process control & eliminate variation Addition of PV elements to existing QMS: Considerations: Cost, time, organizational maturity, culture & regulations The only things not “negotiable” are the program's objectives: System meets process requirements Risks to patients are adequately controlled Documented evidence of system controls are available
22. Moog Process Validation Discussion QUEST Process… continued Site Assessment/Implementation Strategy & effort commensurate with the complexity and needs of the existing system Complex Multiple phase, continuous improvement approach to implementation “Rome wasn’t built in a day.” Validation Master Plan with equipment/process list & schedule Equipment Validation IQ/OQ Protocols & Reports Initial focus on ‘Direct Impact Equipment’ Process Validation Plans, Protocols & Reports Focus on critical quality attributes & critical process parameters Subsequent phases implement complementary systems including; Impact/risk assessment, maintenance, calibration, change control, document control/retention, training, periodic review & CAPA systems Simplistic Assessment & report for fully functioning Process Validation systems
23. Moog Process Validation Discussion QUEST Process… continued Track Remember, Process Validation is a continuous cycle… Process Monitoring & Continuous Improvement activities include; Change Control CAPA Tracking & Trending Use of statistical software for objective process monitoring Management review & evaluation equipment/instrument upgrades Periodic review of qualification status Revalidation if applicable Customer audits verify system suitability
24. Basecamp Website Basecamp offers: Project communication, messages, contacts, writeboards Planning and status tracking with to-do lists and milestones File sharing and storage Security and customizable permissions Benefits: Centralized, easily accessible, well documented, secure project records
25. Conclusion Recap/Discussion/Questions Arc Engineering is always available and pleased to assist further, to provide insight and resolve any uncertainties! We look forward to a productive and mutually beneficial experience for Terumo and Moog!