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Guideline WHO - Guidance On Test Method Validation of in Vitro Diagnostic Medical Devices PDF
Guideline WHO - Guidance On Test Method Validation of in Vitro Diagnostic Medical Devices PDF
Guideline WHO - Guidance On Test Method Validation of in Vitro Diagnostic Medical Devices PDF
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Contents
Contents 3
Acknowledgements 5
1 Definitions 6
2 Introduction 8
3 Scope 8
4 Terminology for test method validation 8
4.1 Explanation of the terms characterisation, verification and validation .................... 8
4.2 Explanation of the terms accuracy, trueness and precision ................................... 10
5 Uses of test method validation in the lifecycle of the IVD 11
6 Test methods 11
6.1 Categories of test methods ..................................................................................... 11
6.2 Statistics and test methods ..................................................................................... 11
6.3 Quantitative and qualitative assays ........................................................................ 11
6.4 Specimen panels and test methods ........................................................................ 12
7 Variability in the test method 12
8 Planning for test method validation 13
9 Examples of test methods and their validation 14
9.1 Validation of test methods related to cleaning processes ...................................... 14
9.2 Validation of test methods for raw materials ......................................................... 16
10 References 20
Procurement of Products that are prequalified by WHO are eligible for procurement by United Nations
prequalified (UN) agencies. The products are then commonly purchased for use in low- and middle-
IVDs
income countries.
Prequalification IVDs prequalified by WHO are expected to be accurate, reliable and be able to perform
requirements
as intended for the lifetime of the IVD under conditions likely to be experienced by a
typical user in resource-limited settings. The countries where WHO-prequalified IVDs
are procured often have minimal regulatory requirements. In addition, the use of IVDs
in these countries presents specific challenges. For instance, IVDs are often used by
health care workers without extensive training in laboratory techniques, in harsh
environmental conditions, without extensive pre- and post-test quality assurance
capacity, and for patients with a disease profile different to those encountered in high
income countries. Therefore, the requirements of the WHO Prequalification Programme
may be different to the requirements of high-income countries, and/or of the regulatory
authority in the country of manufacture.
About the The Technical Guidance Series was developed following a consultation, held on 10-13
Technical March 2015 in Geneva, Switzerland which was attended by experts from national
Guidance regulatory authorities, national reference laboratories and WHO prequalification dossier
Series
reviewers and inspectors. The guidance series is a result of the efforts of this and other
international working groups.
Audience and This guidance is intended for manufacturers interested in WHO prequalification of their
scope IVD. It applies in principle to all IVDs that are eligible for WHO prequalification for use in
WHO Member States. It should be read in conjunction with relevant international and
national standards and guidance.
The TGS guidance documents are freely available on the WHO web site.
Acknowledgements
The draft document “Technical Guidance Series for WHO Prequalification – Diagnostic Assessment:
Guidance on Test method validation of in vitro diagnostic medical devices” was developed with support
from the Bill & Melinda Gates Foundation and UNITAID. This draft was prepared in collaboration with Dr
J Duncan, London, United Kingdom; D Healy; R Meurant, WHO; and with input and expertise from Dr V
Alcón; D Lepine; IVDD Section, Medical Devices Bureau Health Canada, Ottawa, Canada; Dr S Hojvat,
MD, USA; and Dr S Norman, CA, USA. This document was produced under the coordination and
supervision of Robyn Meurant and Irena Prat, Prequalification team – Diagnostic Assessment, WHO,
Geneva, Switzerland.
1 Definitions
1 The section below provides definitions which apply to the terms used in this document.
2 Accuracy: The closeness of agreement between a test result and the accepted reference value.
3 (1)
4 Lot: Defined amount of material that is uniform in its properties and has been produced
5 in one process or series of processes.
6 NOTE: The material can be either starting material, intermediate material or finished
7 product. (2)
8 Characteristic: Distinguishing feature
9 Note 1 to entry: A characteristic can be inherent or assigned.
10 Note 2 to entry: A characteristic can be qualitative or quantitative. (3)
11 Note 3 Characterisation: a description of the distinctive nature or features of
12 something. (3)
13 Control material: Substance, material or article used to verify the performance characteristics of an in
14 vitro diagnostic medical device. (4)
15 Control procedure: Activities at the point of use to monitor the performance of an IVD medical device.
16 Note 1 In the IVD medical device industry and in many laboratories that use IVD
17 medical devices, these activities are commonly referred to as quality control.
18 Note 2 Quality control may monitor all or part of the measurement procedure, from
19 the collection of samples to reporting the result of the measurement. (4)
20 In vitro diagnostic medical device (IVD): A medical device, whether used alone or in combination,
21 intended by the manufacturer for the in vitro examination of specimens derived
22 from the human body solely or principally to provide information for diagnostic,
23 monitoring or compatibility purposes.
24 Note 1 IVDs include reagents, calibrators, control materials, specimen receptacles,
25 software, and related instruments or apparatus or other articles and are used, for
26 example, for the following test purposes: diagnosis, aid to diagnosis, screening,
27 monitoring, predisposition, prognosis, prediction, determination of physiological
28 status.
29 Note 2 In some jurisdictions, certain IVDs may be covered by other regulations. (5)
30 In vitro diagnostic reagent/IVD reagent: Chemical, biological or immunological components, solutions,
31 or preparations intended by the manufacturer to be used as an IVD. (2)
32 Life-cycle: All phases in the life of a medical device, from the initial conception to final
33 decommissioning and disposal. (6)
34 Limit of detection, detection limit: Measured quantity value, obtained by a given measurement
35 procedure, for which the probability of falsely claiming the absence of a component
36 in a material is β, given a probability α of falsely claiming its presence.
57 Quality: Degree to which a set of inherent characteristics of an object fulfils requirements. (3)
58 WHO Note: for the purpose of this document these requirements include fitness-for-
59 use, safety and performance.
60 Quality assurance: Part of quality management focused on providing confidence that quality
61 requirements will be fulfilled. (3)
62 Ruggedness (robustness): A measure of an analytical procedure’s capacity to remain unaffected by
63 small but deliberate variations in method parameters and provides an indication of
64 its reliability during normal usage. (8)
65 Standard method: A method that is (metrologically) traceable to a recognized, validated method.
66 Non-standard method: A method that is not taken from authoritative and validated
67 sources. This includes methods from scientific journals and unpublished laboratory-
68 developed methods. (8)
69 Trueness: The closeness of agreement between the average value obtained from a large series
70 of test results and an accepted reference value. (1)
71 Validation: Confirmation by examination and provision of objective evidence that the
72 requirements for a specific intended use have been fulfilled. (3)
73 Verification: Confirmation through the provision of objective evidence that specified
74 requirements have been fulfilled. (3)
2 Introduction
75 The purpose of test method validation is to ensure that a method consistently provides results fit or
76 adequate for a specific purpose. Testing must have a useful purpose and the result from the test must
77 be shown to be meaningful and to give the expected (and appropriate) information. In order to ensure
78 meaningful results, the test method must be validated; otherwise the measurement has little purpose
79 and no economic value. By using validated test methods, a manufacturer can have confidence that
80 claims made in respect to the quality and performance of an IVD are supported by objective evidence.
3 Scope
81 This document is intended to provide guidance on the validation of the test methods used in
82 manufacturing of an IVD. Sometimes test methods are referred to as analytical methods but in the
83 context of establishing the design, the development and manufacture of an IVD, “test method” is the
84 more commonly used and a more appropriate description since not all testing is analytical. Minimal
85 specific guidance relating to test method validation is available for IVD manufacturers despite the
86 abundance of guidance for the analytical chemistry or pharmaceutical industries (e.g. those from
87 Eurachem (10), Eurolab (11), ICH (12), WHO (13) and FDA (14)) or for clinical laboratories compliant with
88 ISO 15189 (15). This document provides information on validating the test methods used by
89 manufacturers of IVDs in their research and development (R&D), quality control and quality assurance
90 laboratories; it must be read as an adjunct to those formal guides mentioned previously.
91 This document is not intended to give guidance on validation of the IVD itself. For this, it is
92 recommended to refer to “TGS3 Principles of performance studies” (16) in this series. Qualification of
93 instrumentation is outside the scope of this document although the test methods used in qualification
94 must be validated (17). This document does not outline statistical methods for analysis of the required
95 data.
111 The R&D department consequently identifies valid test methods to demonstrate that the specifications
112 have been met (verification) in the new design. Once design has been established, further numerical
113 specifications are produced by the R&D department to ensure that the specifications of each attribute
114 will be met consistently in routine production to ensure quality manufacturing. These new specifications
115 are assigned to control critical production points and may include those for acceptance of raw materials,
116 in-process materials, cleanliness of equipment, qualification of instrumentation and for the finalised IVD
117 to verify its manufacture. Again, it is also the role of the R&D department to identify appropriate test
118 methods to monitor these specifications. An example of verification is related to incoming goods
119 inspections; each time a raw material is purchased its properties will be verified against the specification
120 using a validated test method.
121 Validation is the documentary proof that the particular requirements for a specific intended use can be
122 consistently fulfilled (9). VIM (7) defines validation as “verification against needs for a specific use” (i.e.
123 the specification for that use). Within this guide, consistency is essential: it is an expectation that every
124 lot of an IVD will behave as all other lots and will continue to meet design inputs. To ensure this, it is
125 necessary to have validated test methods for measuring and/or monitoring specifications that will
126 consistently produce results fit for purpose. The test methods must be validated to ensure that the
127 results of measuring and/or monitoring are meaningful. For example, the need for accurate
128 measurement of a raw material weighed in micrograms will not be achieved by using a weighing device
129 with tolerance measured in grams. A test method using such an instrument would not be valid for the
130 intended use. Thus, for the example provided, a test method should be specified that has the necessary
131 accuracy and precision for measuring such weights, and an instrument and procedure identified that will
132 consistently achieve this requirement during its use. The test method is then validated to produce
133 results fit for purpose.
134 Validation of a test method is distinct from its characterisation. Characterisation is documentation of
135 some or all of the features of the method; validation is ensuring that the relevant characteristics are
136 appropriate for the specific intended use. Validation of a method to be used widely, and for standard
137 methods, often begins with complete characterisation. However, for each specific intended use it is
138 likely that only a subset of the characteristics will be relevant and must be evaluated.
139 Published guides to test method validation provide the broad characteristics of assays as set out in Table
140 1.
† Productivity is not usually mentioned in test method validation texts but is important in
manufacturing environments. Although cost must not be a factor considered in risk minimization (6), it
should be a consideration in choice and validation of test methods.
142 Usually only a small selection of the possible characteristics and attributes will ever be studied for a test
143 method specifically developed for a single purpose.
167 fact of limited replication does not convert accuracy to trueness although it may improve the accuracy.
168 Accuracy is expressed in terms of bias: “the accuracy of that measurement was -z-units” (1, 7).
169 Both precision and trueness for a particular method, and subsequently the accuracy of an assay by that
170 method, can be influenced by the concentration of the measurand. As such, when characterising a
171 method, knowledge of the performance of the assay should be obtained over a range of foreseeable
172 measurand concentrations, to ensure the validity of any assumptions regarding the performance of the
173 method.
6 Test methods
202 Some IVDs are intended only to produce qualitative results in users’ environments but it is usual (and is
203 probably essential) that the test methods used in manufacture (quality assurance, quality control) will
204 provide a quantitative result. In most cases qualitative assays can be adjusted to provide a quantitative
205 result, either from an instrumental reading, e.g. for an enzyme immunoassay, or against a graduated
206 reference scale (semi-quantitative reporting of a present/absent result as is the case with many rapid
207 diagnostic tests) . If a quantitative result cannot be obtained then experiments and results must be
208 designed to be analysed by appropriate qualitative statistical methods. Documenting an outcome as
209 merely positive or negative without giving an uncertainty estimate is rarely sufficient, particularly for
210 test methods intended to characterise an IVD (e.g. for stability, precision, sensitivity) or for release-to-
211 sale testing.
282 relationship between the chosen test method and the testing panel, it is almost always too late to try to
283 find appropriate specimens for the panels after R&D is completed.
320 These are typical specifications for equipment used for fermentation or protein handling and experience
321 shows that if they are achieved the vessel is likely to be acceptably clean for these purposes. However
322 the utility of the cleaning process with these specifications would need to be validated (26) for the
323 specific use before finalising and validating the test methods.
324 d) Select or develop the method(s)
325 The extraction of the water from the vessel is part of the test method: it is required to demonstrate
326 during validation by R&D that a second, similar extraction would contain unmeasurable amounts of the
327 potential contaminants and, independently, that nothing of practical importance would leach into the
328 next solution to be used in the vessel. This aspect of the work requires different methods to those used
329 for the routine verification. These more sensitive methods are required to be validated in the R&D phase
330 of the work (validated for use in the conjugation solution).
331 The validation of the (non-standard) test methods used in this type of work is thoroughly exemplified in
332 the formal pharmaceutical test method validation guides. Validation of the total organic carbon
333 measuring system originates from the manufacturer’s specification and the subsequent performance
334 qualification.
335 As the measurements are made in almost pure water it would not be necessary to verify lack of
336 interference from other constituents of the matrix. Similarly if the conductivity meter was specified as
337 being capable of accurate readings superior than the requirement, further validation would not be
338 necessary.
339 Residual detergent would be measured using an instrument, for example high performance liquid
340 chromatography (HPLC). The method chosen would require characterisation of the sensitivity, accuracy
341 and precision for this purpose and the specific detergent involved. Functionality and conformation of
342 proteins would not survive the acid and alkali washes so any contaminating protein would be measured
343 by a chemical technique, defined in the standard operating procedure for the cleaning process. The
344 definition of the test method is essential as each method of protein quantitation (Lowry, biuret, binding
345 of various dyes and HPLC) provides marginally different results for specific proteins. The sensitivity of the
346 method would be demonstrated to be capable of meeting the requirement and the precision to show
347 that the stated level of protein could be determined with sufficient accuracy. Chemical methods may be
348 used to analysis cleanliness relating to the conjugation reagents. The test method must be defined and
349 the precision and sensitivity in the matrix of distilled water demonstrated to be appropriate.
350 e) Compare performance with requirements and use the methods if adequate
351 Once the methods have been characterised and proven to meet the required numerical attributes they
352 can be used in routine verification of the cleaning process.
353 Over time as the process is shown to consistently produce cleanliness within the required
354 specification, testing would be minimised: i.e. the process itself would be validated
355 (consistently providing cleanliness fit for purpose). However this can only be done by prior
356 use of validated test methods.
395 of water and drops of each specimen type from the pipettes. The number of randomly selected pipettes
396 and the proportion of lots to be tested are calculated on the basis of acceptable risks (27) as confidence
397 in the supplier increased.
398 It is unlikely that the quality assurance incoming goods inspection team have access to the specimens
399 claimed for the IVD (e.g. fresh whole blood, fresh serum, cerebrospinal fluid). Hence any volume
400 measurements on a substitute liquid (e.g. water) with volume estimated by weight must be validated.
401 Drop volumes and variances of different liquids differ due to density and surface tension effects.
402 The exact method and required specifications would be documented in a standard operating procedure
403 in addition to data recording, monitoring requirements and a reference to the validation of the test
404 method.
405 e) Compare performance with requirements
406 The required characteristics of the test method can be measured and compared against the specification
407 (the precision and the number of pipettes to be tested). Consequently the method may be used if found
408 to be fit for purpose.
409 As can be seen, method validation at this level require planning, experimental work and documentation
410 beyond merely defining the method (“weigh some drops”) and the specification for the component.
411 9.2.1.2 Package labels, instructions for use, vials, stoppers etc.
412 Ancillary materials (e.g. printed matter, packing materials, containers, stoppers) will at a minimum, need
413 inspection prior to acceptance. Inspection is a test method. As usual, the requirements of the test
414 method (the inspection) must be defined once the purpose of the testing is understood. The attributes
415 of the test method can be evaluated (e.g. the pre-defined consumer risk and hence the proportion of the
416 incoming delivery to examine, the capability of the inspectors to distinguish and record the attribute)
417 and the method validated to consistently assure appropriate quality. Regardless of inspection method
418 chosen, its capability to detect flaws at the required level of risk must be documented as must be the
419 standard operating procedure for performing the inspection.
432 9.2.2.1 Example of acceptance testing for a low molecular weight constituent
433 Some detergents (those containing a polyether bond e.g. Tween, Triton) easily and quickly generate
434 peroxides (28).
Page 17 of 21 Draft for comment 20 December 2016
Technical Guidance Series for WHO prequalification – Diagnostic assessment:
Guidance on Test method validation of in vitro diagnostic medical devices TGS–4
474 dependent on the conformation of the macromolecules and specificity depends on the precise
475 impurities present (among other things). The material’s specification must include requirements for
476 functionality, for purity based on similarity of contaminants between lots, measures of sequence
477 integrity and molecular conformation.
478 The test methods involved in preparing satisfactory COAs, or of providing evidence of satisfactory in-
479 house preparations, are much more complex than those in the elementary examples given above.
480 However, validation of the methods follows exactly the same principles. Usually the methods are well
481 known analytical procedures. It may be the case that they are not “standard” methods but adequately
482 known and characterised so that if used appropriately they do not require further validation.
483 A problem observed in many submissions to WHO prequalification is that either the methods are not
484 used at all, or the output is not appropriate for the task. The following section discusses these major
485 issues. It does not provide detail of the process of validation, but an expectation of how the well-known
486 test methods will be used.
487 Both purity and conformation are critically lot dependent and are not usually documented in sufficient
488 detail in a commercial COA to provide objective evidence of inter-lot reproducibility. A standard
489 commercial COA for a recombinant protein usually provides a result for purity from a gel after
490 electrophoresis (e.g. “>95 %”) without specifying the exact concentrations and molecular weights of the
491 impurities (so allowing lot-to-lot variation within the specification and hence potential for specificity and
492 stability issues). A COA will also usually provide a molecular weight which is determined from a gel or a
493 Western blot. However, neither technique are adequately sensitive to demonstrate minor post-
494 translational modifications, nor capable of providing any information about conformation (allowing
495 potential sensitivity and selectivity issues). Quantitation of results from both stained and blotted gels is
496 not reproducible without special techniques and gives only approximate values (29). A COA should
497 always give some measure of uncertainty in the stated values of both molecular weight and quantity. A
498 competent COA should also include amino- and carboxy- terminal amino acid analyses to ensure
499 absence of minor proteolysis during purification.
500 Choice of correct methods, and knowledge of their limitations, is a major deficiency in most WHO
501 prequalification submissions. There is insufficient proof that there is no lot-to-lot variability, neither in
502 those critical materials nor in the final IVD made from them.
503 Before committing to purchase or process a substantial amount of a new lot of recombinant protein, a
504 careful manufacturer will need to check that the new lot will detect the difficult specimens
505 (seroconversion, latent stage, unusual serotype specimens) with the sensitivity and specificity claimed
506 for the IVD and with approximately the same utilization (devices per milligram) as the lots used to
507 validate the IVD itself. Proficient manufacturers develop testing of identity, integrity and functionality of
508 polynucleotides to be used in IVD.
509 These tests for complex critical reagents can only be specified for commercial or for in-house reagents
510 by the manufacturer of the IVD, since the requirements are unique to the IVD and its validated claims.
511 Nevertheless, the methods used must be validated as suitable for use.
512 The sensitivity, specificity and utilization measurements on new lots of recombinant proteins are usually
513 made by preparing the IVD on a small scale and testing against defined panels of specimens proven to
514 monitor the stated parameters with satisfactory efficiency. Test method validation is to ensure that the
515 panels do indeed monitor the expected parameters.
10 References
516 1. ISO 5725-1:1994: Accuracy (trueness and precision) of measurement methods and results —
517 Part 1: General principles and definitions. Geneva, Switzerland: International Organization for
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525 user quality control procedures by the manufacturer. Geneva, Switzerland: International
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528 Global Harmonization Task Force (GHTF) Steering Committee; 2012.
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530 International Organization for Standardization; Geneva, Switzerland: 2007.
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532 associated terms (VIM). Geneva, Switzerland: International Organization for Standardization;
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540 978-91-87461-59-0. (http://www.eurachem.org)
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542 (http://www.eurolab.org)
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548 2001 & September 2013 (draft update)
549 15. ISO 15189:2012. Medical laboratories -- Requirements for quality and competence. Geneva,
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556 Wayne, PA: Clinical and Laboratory Standards Institute; 2011
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581 Supplementary guidelines on good manufacturing practices : validation - WHO, 2006
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587 Research International, volume 2014, Article ID 361590 8 pages, 2014
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