Professional Documents
Culture Documents
Pharmaceutical Process Validation
Pharmaceutical Process Validation
Process Validation
An International Third Edition, Revised and Expanded
edited by
Robert A. Nash
Stevens Institute of Technology
Hoboken, New Jersey, U.S.A.
Alfred H.Wachter
Wachter P h r m a Projects
Therwil, Switzerland
MARCEL
MARCELDEKKER,
INC. NEWYORK * BASEL
DEKKER
CRC Press
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Executive Editor
James Swarbrick
PharmaceuTech, Inc
Pinehurst, North Carolina
Advisory Board
Peter G. Welling
Institut de Recherche Jouvemal
Fresnes, France
DRUGS AND THE PHARMACEUTICAL SCIENCES
Robert A. Nash
v
Contents
Preface v
Contributors ix
Introduction xiii
3. Retrospective Validation 31
Chester J. Trubinski
4. Sterilization Validation 83
Michael J. Akers and Neil R. Anderson
Peter H. Cheng New York State Research Foundation for Mental Hygiene,
New York, New York, U.S.A.
John M. Dietrick Center for Drug Evaluation and Research, U.S. Food and
Drug Administration, Rockville, Maryland, U.S.A.
William E. Hall Hall & Pharmaceutical Associates, Inc., Kure Beach, North
Carolina, U.S.A.
F. St. John Forbes Wyeth Labs, Pearl River, New York, U.S.A.
*Retired
Contributors xi
Chester J. Trubinski Church & Dwight Co., Inc., Princeton, New Jersey,
U.S.A.
Paul Von Doehren Searle & Co., Inc., Skokie, Illinois, U.S.A.
Robert A. Nash
Stevens Institute of Technology, Hoboken, New Jersey, U.S.A.
I. FDA GUIDELINES
The U.S. Food and Drug Administration (FDA) has proposed guidelines with
the following definition for process validation [1]:
Process validation is establishing documented evidence which provides a
high degree of assurance that a specific process (such as the manufacture
of pharmaceutical dosage forms) will consistently produce a product meet-
ing its predetermined specifications and quality characteristics.
The first four items listed above are directly related to the manufacture
and validation of solid dosage forms. Items 1 and 3 are normally associated
with variability in the manufacturing process, while items 2 and 4 are usually
influenced by the selection of the ingredients in the product formulation. With
respect to content uniformity and unit potency control (item 3), adequacy of
mixing to assure uniformity and homogeneity is considered a high-priority con-
cern.
Conventional quality control procedures for finished product testing en-
compass three basic steps:
1. Establishment of specifications and performance characteristics
2. Selection of appropriate methodology, equipment, and instrumenta-
tion to ensure that testing of the product meets specifications
3. Testing of the final product, using validated analytical and testing
methods to ensure that finished product meets specifications.
With the emergence of the pharmaceutical process validation concept, the fol-
lowing four additional steps have been added:
4. Qualification of the processing facility and its equipment
5. Qualification and validation of the manufacturing process through ap-
propriate means
6. Auditing, monitoring, sampling, or challenging the key steps in the
process for conformance to in-process and final product specifications
7. Revalidation when there is a significant change in either the product
or its manufacturing process [3].
It has been said that there is no specific basis for requiring a separate set of
process validation guidelines, since the essentials of process validation are em-
bodied within the purpose and scope of the present CGMP regulations [2]. With
this in mind, the entire CGMP document, from subpart B through subpart K,
may be viewed as being a set of principles applicable to the overall process of
manufacturing, i.e., medical devices (21 CFR–Part 820) as well as drug prod-
ucts, and thus may be subjected, subpart by subpart, to the application of the
principles of qualification, validation, verification and control, in addition to
change control and revalidation, where applicable. Although not a specific re-
Introduction xv
The FDA, under the authority of existing CGMP regulations, guidelines [1], and
directives [3], considers process validation necessary because it makes good
engineering sense. The basic concept, according to Mead [5], has long been
Qualification and
Subpart Section of CGMPs control documentation
A General provisions
B Organization and personnel Responsibilities of the quality con-
trol unit
C Buildings and facilities Plant and facility installation and
qualification
Maintenance and sanitation
Microbial and pest control
D Equipment Installation and qualification of
equipment and cleaning methods
E Control of components, containers Incoming component testing proce-
and closures dures
F Production and process controls Process control systems, reprocess-
ing control of microbial contami-
nation
G Packaging and labeling controls Depyrogenation, sterile packaging,
filling and closing, expire dating
H Holding and distribution Warehousing and distribution pro-
cedures
I Laboratory controls Analytical methods, testing for re-
lease component testing and sta-
bility testing
J Records and reports Computer systems and information
systems
K Return and salvaged drug products Batch reprocessing
Sterilization procedures, Air and water quality are covered in appropriate subparts of Table 1.
xvi Nash
applied in other industries, often without formal recognition that such a concept
was being used. For example, the terms reliability engineering and qualification
have been used in the past by the automotive and aerospace industries to repre-
sent the process validation concept.
The application of process validation should result in fewer product re-
calls and troubleshooting assignments in manufacturing operations and more
technically and economically sound products and their manufacturing processes.
In the old days R & D “gurus” would literally hand down the “go” sometimes
overformulated product and accompanying obtuse manufacturing procedure,
usually with little or no justification or rationale provided. Today, under FDA’s
Preapproval Inspection (PAI) program [4] such actions are no longer accept-
able. The watchword is to provide scientifically sound justifications (including
qualification and validation documentation) for everything that comes out of the
pharmaceutical R & D function.
With the exception of solution products, the bulk of the work is nor-
mally carried out at 10 × batch size, which is usually the first scale-up
batches in production-type equipment.
The following operations are normally carried out by the development function
prior to the preparation of the first pilot-production batch. The development
activities are listed as follows:
xviii Nash
A. Laboratory Batch
The first step in the scale-up process is the selection of a suitable preliminary
formula for more critical study and testing based on certain agreed-upon initial
design criteria, requirements, and/or specifications. The work is performed in
the development laboratory. The formula selected is designated as the (1 × )
laboratory batch. The size of the (1 × ) laboratory batch is usually 3–10 kg of a
solid or semisolid, 3–10 liters of a liquid, or 3000 to 10,000 units of a tablet or
capsule.
C. Pilot Production
The pilot-production phase may be carried out either as a shared responsibility
between the development laboratories and its appropriate manufacturing coun-
terpart or as a process demonstration by a separate, designated pilot-plant or
process-development function. The two organization piloting options are pre-
sented separately in Figure 1. The creation of a separate pilot-plant or process-
development unit has been favored in recent years because it is ideally suited to
carry out process scale-up and/or validation assignments in a timely manner. On
the other hand, the joint pilot-operation option provides direct communication
between the development laboratory and pharmaceutical production.
The object of the pilot-production batch is to scale the product and process
by another order of magnitude (100 × ) to, for example, 300–1,000 kg, 300–
1,000 liters, or 300,000–1,000,000 dosage form units (tablets or capsules) in
size. For most drug products this represents a full production batch in standard
production equipment. If required, pharmaceutical production is capable of scal-
ing the product/process to even larger batch sizes should the product require
expanded production output. If the batch size changes significantly, additional
validation studies would be required. The term product/process is used, since
one can’t describe a product with discussing its process of manufacture and,
conversely, one can’t talk about a process without describing the product being
manufactured.
Usually large production batch scale-up is undertaken only after product
introduction. Again, the actual size of the pilot-production (100 × ) batch may
vary due to equipment and raw material availability. The need for additional
pilot-production batches ultimately depends on the successful completion of a
first pilot batch and its process validation program. Usually three successfully
completed pilot-production batches are required for validation purposes.
In summary, process capability studies start in the development labora-
tories and/or during product and process development, and continue in well-
defined stages until the process is validated in the pilot plant and/or pharmaceu-
tical production.
An approximate timetable for new product development and its pilot
scale-up program is suggested in Table 3.
Calendar
Event months
Process validation is done by individuals with the necessary training and experi-
ence to carry out the assignment.
The specifics of how a dedicated group, team, or committee is organized
to conduct process validation assignments is beyond the scope of this introduc-
tory chapter. The responsibilities that must be carried out and the organizational
structures best equipped to handle each assignment are outlined in Table 4. The
xxii Nash
Engineering Install, qualify, and certify plant, facilities, equipment, and sup-
port system.
Development Design and optimize manufacturing process within design limits,
specifications, and/or requirements—in other words, the estab-
lishment of process capability information.
Manufacturing Operate and maintain plant, facilities, equipment, support sys-
tems, and the specific manufacturing process within its design
limits, specifications, and/or requirements.
Quality assurance Establish approvable validation protocols and conduct process
validation by monitoring, sampling, testing, challenging, and/
or auditing the specific manufacturing process for compliance
with design limits, specifications, and/or requirements.
Source: Ref. 8.
Process capability is defined as the studies used to determine the critical process
parameters or operating variables that influence process output and the range of
numerical data for critical process parameters that result in acceptable process
output. If the capability of a process is properly delineated, the process should
consistently stay within the defined limits of its critical process parameters and
product characteristics [12].
Process demonstration formerly called process qualification, represents
the actual studies or trials conducted to show that all systems, subsystems, or
unit operations of a manufacturing process perform as intended; that all critical
process parameters operate within their assigned control limits; and that such
studies and trials, which form the basis of process capability design and testing,
are verifiable and certifiable through appropriate documentation.
The manufacturing process is briefly defined as the ways and means used
to convert raw materials into a finished product. The ways and means also
include people, equipment, facilities, and support systems required to operate
the process in a planned and effectively managed way. All the latter functions
must be qualified individually. The master plan or protocol for process capabil-
ity design and testing is presented in Table 5.
A simple flow chart should be provided to show the logistical sequence
of unit operations during product/process manufacture. A typical flow chart used
in the manufacture of a tablet dosage form by the wet granulation method is
presented in Figure 2.
Table 5 Master Plan or Protocol for Process Capability Design and Testing
Figure 2 Process flow diagram for the manufacture of a tablet dosage form by wet
granulation method. The arrows show the transfer of material into and out of each of the
various unit operations. The information in parentheses indicates additions of material to
specific unit operations. A list of useful pharmaceutical unit operations is presented in
Table 6.
Introduction xxv
ment, clinical study, process development, and process validation and into pro-
duction. Working individually with separate analytical testing functions and
with little or no appropriate communication among these three vital functions is
a prescription for expensive delays. It is important to remember that the concept
illustrated in Figure 3 can still be followed even when the API is sourced from
outside the plant site or company. In this particular situation there will probably
be two separate analytical methods development functions: one for the API
manufacturer and one for the drug product manufacturer [14].
Statistical process control (SPC), also called statistical quality control and pro-
cess validation (PV), represents two sides of the same coin. SPC comprises the
various mathematical tools (histogram, scatter diagram run chart, and control
chart) used to monitor a manufacturing process and to keep it within in-process
and final product specification limits. Lord Kelvin once said, “When you can
measure what you are speaking about, and express it in numbers, then you know
something about it.” Such a thought provides the necessary link between the
two concepts. Thus, SPC represents the tools to be used, while PV represents
the procedural environment in which those tools are used.
xxvi Nash
There are three ways of establishing quality products and their manufac-
turing processes:
1. In-process and final product testing, which normally depends on sam-
pling size (the larger the better). In some instances, nothing short of
excessive sampling can ensure reaching the desired goal, i.e., sterility
testing.
2. Establishment of tighter (so called “in-house”) control limits that hold
the product and the manufacturing process to a more demanding stan-
Introduction xxvii
dard will often reduce the need for more extensive sampling require-
ments.
3. The modern approach, based on Japanese quality engineering [15], is
the pursuit of “zero defects” by applying tighter control over process
variability (meeting a so-called 6 sigma standard). Most pharmaceuti-
cal products and their manufacturing processes in the United States
today, with the exception of sterile processes are designed to meet a
4 sigma limit (which would permit as many as eight defects per 1000
units). The new approach is to center the process (in which the grand
average is roughly equal to 100% of label potency or the target value
of a given specification) and to reduce the process variability or noise
around the mean or to achieve minimum variability by holding both
to the new standard, batch after batch. In so doing, a 6 sigma limit
may be possible (which is equivalent to not more than three to four
defects per 1 million units), also called “zero defects.” The goal of 6
sigma, “zero defects” is easier to achieve for liquid than for solid
pharmaceutical dosage forms [16].
Process characterization represents the methods used to determine the
critical unit operations or processing steps and their process variables, that usu-
ally affect the quality and consistency of the product outcomes or product attri-
butes. Process ranging represents studies that are used to identify critical process
or test parameters and their respective control limits, which normally affect the
quality and consistency of the product outcomes of their attributes. The follow-
ing process characterization techniques may be used to designate critical unit
operations in a given manufacturing process.
A. Constraint Analysis
One procedure that makes subsystem evaluations and performance qualification
trials manageable is the application of constraint analysis. Boundary limits of
any technology and restrictions as to what constitutes acceptable output from
unit operations or process steps should in most situations constrain the number
of process variables and product attributes that require analysis. The application
of the constraint analysis principle should also limit and restrict the operational
range of each process variable and/or specification limit of each product attri-
bute. Information about constraining process variables usually comes from the
following sources:
• Previous successful experience with related products/processes
• Technical and engineering support functions and outside suppliers
• Published literatures concerning the specific technology under investi-
gation
xxviii Nash
Optimization techniques are used to find either the best possible quantitative
formula for a product or the best possible set of experimental conditions (input
values) needed to run the process. Optimization techniques may be employed in
the laboratory stage to develop the most stable, least sensitive formula, or in the
qualification and validation stages of scale-up in order to develop the most sta-
Introduction xxix
Trial no. X1 X2 X3 X4 X5 X6 X7 X8 X9
1 − − − − − − − − −
2 + − − − − − − − −
3 − − − + − − − − +
4 + − + − − − + − −
5 − + − + − + − + −
6 + − + − + − + − +
7 − + − + + + − + +
8 + + + − + + + + −
9 − + + + + + + + +
10 + + + + + + + + +
Worst-case conditions: Trial 1 (lower control limit). Trial 10 (upper control limit). X variables
randomly assigned. Best values to use are RSD of data set for each trial. When adding up the data
by columns, + and − are now numerical values and the sum is divided by 5 (number of +s or −s).
If the variable is not significant, the sum will approach zero.
ble, least variable, robust process within its proven acceptable range(s) of opera-
tion, Chapman’s so-called proven acceptable range (PAR) principle [20].
Optimization techniques may be classified as parametric statistical meth-
ods and nonparametric search methods. Parametric statistical methods, usually
employed for optimization, are full factorial designs, half factorial designs, sim-
plex designs, and Lagrangian multiple regression analysis [21]. Parametric
methods are best suited for formula optimization in the early stages of product
development. Constraint analysis, described previously, is used to simplify the
testing protocol and the analysis of experimental results.
The steps involved in the parametric optimization procedure for pharma-
ceutical systems have been fully described by Schwartz [22]. Optimization tech-
niques consist of the following essential operations:
1. Selection of a suitable experimental design
2. Selection of variables (independent Xs and dependent Ys) to be tested
3. Performance of a set of statistically designed experiments (e.g., 23 or
32 factorials)
4. Measurement of responses (dependent variables)
5. Development of a predictor, polynomial equation based on statistical
and regression analysis of the generated experimental data
6. Development of a set of optimized requirements for the formula based
on mathematical and graphical analysis of the data generated
xxx Nash
may be the already successfully concluded first pilot batch at 100 × size, which
is usually prepared under the direction of the organizational function directly
responsible for pilot scale-up activities. Later, replicate batch manufacture may
be performed by the pharmaceutical production function.
The strategy selected for process validation should be simple and straight-
forward. The following factors are presented for the reader’s consideration:
1. The use of different lots of components should be included, i.e., APIs
and major excipients.
2. Batches should be run in succession and on different days and shifts
(the latter condition, if appropriate).
3. Batches should be manufactured in equipment and facilities desig-
nated for eventual commercial production.
4. Critical process variables should be set within their operating ranges
and should not exceed their upper and lower control limits during
process operation. Output responses should be well within finished
product specifications.
xxxii Nash
B. Retrospective Validation
The retrospective validation option is chosen for established products whose
manufacturing processes are considered stable and when on the basis of eco-
nomic considerations alone and resource limitations, prospective validation pro-
grams cannot be justified. Prior to undertaking retrospective validation, wherein
the numerical in-process and/or end-product test data of historic production
batches are subjected to statistical analysis, the equipment, facilities and subsys-
tems used in connection with the manufacturing process must be qualified in
conformance with CGMP requirements. The basis for retrospective validation
is stated in 21CFR 211.110(b): “Valid in-process specifications for such charac-
teristics shall be consistent with drug product final specifications and shall be
derived from previous acceptable process average and process variability esti-
mates where possible and determined by the application of suitable statistical
procedures where appropriate.”
The concept of using accumulated final product as well as in-process nu-
merical test data and batch records to provide documented evidence of product/
process validation was originally advanced by Meyers [26] and Simms [27] of
Eli Lilly and Company in 1980. The concept is also recognized in the FDA’s
Guidelines on General Principles of Process Validation [1].
Using either data-based computer systems [28,29] or manual methods,
retrospective validation may be conducted in the following manner:
1. Gather the numerical data from the completed batch record and in-
clude assay values, end-product test results, and in-process data.
2. Organize these data in a chronological sequence according to batch
manufacturing data, using a spreadsheet format.
3. Include data from at least the last 20–30 manufactured batches for
analysis. If the number of batches is less than 20, then include all
manufactured batches and commit to obtain the required number for
analysis.
4. Trim the data by eliminating test results from noncritical processing
steps and delete all gratuitous numerical information.
5. Subject the resultant data to statistical analysis and evaluation.
6. Draw conclusions as to the state of control of the manufacturing pro-
cess based on the analysis of retrospective validation data.
7. Issue a report of your findings (documented evidence).
Introduction xxxiii
C. Concurrent Validation
In-process monitoring of critical processing steps and end-product testing of
current production can provide documented evidence to show that the manufac-
turing process is in a state of control. Such validation documentation can be
provided from the test parameter and data sources disclosed in the section on
retrospective validation.
xxxiv Nash
Not all of the in-process tests enumerated above are required to demon-
strate that the process is in a state of control. Selections of test parameters
should be made on the basis of the critical processing variables to be evaluated.
D. Revalidation
Conditions requiring revalidation study and documentation are listed as follows:
1. Change in a critical component (usually refers to raw materials)
2. Change or replacement in a critical piece of modular (capital) equip-
ment
3. Change in a facility and/or plant (usually location or site)
4. Significant (usually order of magnitude) increase or decrease in batch
size
5. Sequential batches that fail to meet product and process specifications
In some situations performance requalification studies may be required
prior to undertaking specific revalidation assignments.
The FDA process validation guidelines [1] refer to a quality assurance
system in place that requires revalidation whenever there are changes in packag-
ing (assumed to be the primary container-closure system), formulation, equip-
ment or processes (meaning not clear) which could impact on product effective-
ness or product characteristics and whenever there are changes in product
characteristics.
Approved packaging is normally selected after completing package perfor-
mance qualification testing as well as product compatibility and stability studies.
Since in most cases (exceptions: transdermal delivery systems, diagnostic tests,
and medical devices) packaging is not intimately involved in the manufacturing
process of the product itself, it differs from other factors, such as raw materials.
Introduction xxxv
The reader should realize that there is no one way to establish proof or
evidence of process validation (i.e., a product and process in control). If the
manufacturer is certain that its products and processes are under statistical con-
trol and in compliance with CGMP regulations, it should be a relatively simple
matter to establish documented evidence of process validation through the use
of prospective, concurrent, or retrospective pilot and/or product quality informa-
tion and data. The choice of procedures and methods to be used to establish
validation documentation is left with the manufacturer.
This introduction was written to aid scientists and technicians in the phar-
maceutical and allied industries in the selection of procedures and approaches
that may be employed to achieve a successful outcome with respect to product
performance and process validation. The authors of the following chapters ex-
plore the same topics from their own perspectives and experience. It is hoped
that the reader will gain much from the diversity and richness of these varied
approaches.
REFERENCES
14. Nash, R. A., Streamlining Process Validation, Amer. Pharm. Outsourcing May
2001.
15. Ishikawa, K., What is Total Quality Control? The Japanese Way, Prentice-Hall,
Englewood Cliffs, NJ (1985).
16. Nash, R. A., Practicality of Achieving Six Sigma or Zero-Defects in Pharmaceutical
Systems, Pharmaceutical Formulation & Quality, Oct./Nov. 2001.
17. CGMP: Amendment of Certain Requirements, FDA Federal Register, May 3,
1996.
18. Box, G. E. and Hunter, J. S., Statistics for Experimenters, John Wiley, N.Y. (1978).
19. Hendrix, C. D., What every technologist should know about experimental design,
CHEMTECH (March 1979).
20. Chapman, K. G., The PAR approach to process validation, Pharm. Tech., Dec.
1984.
21. Bolton, S., Pharmaceutical Statistics: Practical and Clinical Applications, 3rd ed.,
Marcel Dekker, New York (1997).
22. Schwartz, J. B., Optimization techniques in product formulation. J. Soc. Cosmet.
Chem. 32:287–301 (1981).
23. Butler, J. J., Statistical quality control, Chem. Eng. (Aug. 1983).
24. Deming, S. N., Quality by Design, CHEMTECH, (Sept. 1988).
25. Contino, AV., Improved plant performance with statistical process control, Chem.
Eng. (July 1987).
26. Meyer, R. J., Validation of Products and Processes, PMA Seminar on Validation
of Solid Dosage Form Processes, Atlanta, GA, May 1980.
27. Simms, L., Validation of Existing Products by Statistical Evaluation, Atlanta, GA,
May 1980.
28. Agalloco, J. P., Practical considerations in retrospective validation, Pharm. Tech.
(June 1983).
29. Kahan, J. S., Validating computer systems, MD&DI (March 1987).
1
Regulatory Basis for
Process Validation
John M. Dietrick
U.S. Food and Drug Administration, Rockville, Maryland, U.S.A.
Bernard T. Loftus
U.S. Food and Drug Administration, Washington, D.C., U.S.A.
I. INTRODUCTION
Bernard T. Loftus was director of drug manufacturing in the Food and Drug
Administration (FDA) in the 1970s, when the concept of process validation was
first applied to the pharmaceutical industry and became an important part of
current good manufacturing practices (CGMPs). His comments on the develop-
ment and implementation of these regulations and policies as presented in the
first and second editions of this volume are summarized below [1].
The term process validation is not defined in the Food, Drug, and Cosmetic Act
(FD&C) Act or in FDA’s CGMP regulations. Many definitions have been of-
fered that in general express the same idea—that a process will do what it
purports to do, or that the process works and the proof is documented. A June
1978 FDA compliance program on drug process inspections [2] contained the
following definition:
This chapter was written by John M. Dietrick in his private capacity. No official support or endorse-
ment by the Food and Drug Administration is intended or should be inferred.
1
2 Dietrick and Loftus
Once the concept of being able to predict process performance to meet user
requirements evolved, FDA regulatory officials established that there was a le-
gal basis for requiring process validation. The ultimate legal authority is Section
501(a)(2)(B) of the FD&C Act [4], which states that a drug is deemed to be
adulterated if the methods used in, or the facilities or controls used for, its
manufacture, processing, packing, or holding do not conform to or were not
operated or administrated in conformity with CGMP. Assurance must be given
that the drug would meet the requirements of the act as to safety and would
have the identity and strength and meet the quality and purity characteristics
that it purported or was represented to possess. That section of the act sets the
premise for process validation requirements for both finished pharmaceuticals
and active pharmaceutical ingredients, because active pharmaceutical ingredi-
ents are also deemed to be drugs under the act.
The CGMP regulations for finished pharmaceuticals, 21 CFR 210 and
211, were promulgated to enforce the requirements of the act. Although these
regulations do not include a definition for process validation, the requirement is
implicit in the language of 21 CFR 211.100 [5], which states: “There shall be
written procedures for production and process control designed to assure that
the drug products have the identity, strength, quality, and purity they purport or
are represented to possess.”
Although the emphasis on validation began in the late 1970s, the requirement
has been around since at least the 1963 CGMP regulations for finished pharma-
ceuticals. The Kefauver-Harris Amendments to the FD&C Act were approved
Regulatory Basis for Process Validation 3
cials were not thinking in terms of process validation. One of the first entries
into process validation was a 1974 paper presented by Ted Byers, entitled “De-
sign for Quality” [7]. The term validation was not used, but the paper described
an increased attention to adequacy of processes for the production of pharma-
ceuticals. Another paper—by Bernard Loftus before the Parenteral Drug Associ-
ation in 1978 entitled “Validation and Stability” [8]—discussed the legal basis
for the requirement that processes be validated.
The May 1987 Guideline on General Principles of Process Validation [3]
was written for the pharmaceutical, device, and veterinary medicine industries.
It has been effective in standardizing the approach by the different parts of the
agency and in communicating that approach to manufacturers in each industry.
V. UPDATE
As discussed in the preceding sections, process validation has been a legal re-
quirement since at least 1963. Implementation of the requirement was a slow
and deliberate process, beginning with the development and dissemination of an
agency policy by Loftus, Byers, and others, and leading to the May 1987 guide-
line. The guideline quickly became an important source of information to phar-
maceutical manufacturers interested in establishing a process validation pro-
gram. Many industry organizations and officials promoted the requirements as
well as the benefits of validation. Many publications, such as Pharmaceutical
Process Validation [1] and various pharmaceutical industry journal articles,
cited and often expanded on the principals in the guideline. During the same
period, computer validation—or validation of computer controlled processes—
also became a widely discussed topic in both seminars and industry publications.
The regulatory implementation of the validation requirement was also a
deliberate process by FDA. During the 1980s, FDA investigators often reported
processes that had not been validated or had been inadequately validated. Batch
failures were often associated with unvalidated manufacturing processes. The
FDA issued a number of regulatory letters to deficient manufacturers citing the
lack of adequate process validation as a deviation from CGMP regulations
(21CFR 211.100), which causes the drug product to be adulterated within the
meaning of Section 501(a)(2)(B) of the federal FD&C Act. Process validation
was seldom the only deficiency listed in these regulatory letters. The failure of
some manufacturers to respond to these early warnings resulted in FDA filing
several injunction cases that included this charge in the early 1990s. Most of
these cases resulted in consent decrees, and ultimately the adoption of satisfac-
tory process validation programs by the subject manufacturers. One injunction
case filed in 1992, however, was contested in court and led to a lengthy written
order and opinion by the U.S. District Court in February of 1993 [9]. The court
Regulatory Basis for Process Validation 5
affirmed the requirement for process validation in the current good manufactur-
ing regulations, and ordered the defendants to perform process validation studies
on certain drug products, as well as equipment cleaning validation studies. This
case and the court’s ruling were widely circulated in the pharmaceutical industry
and became the subject of numerous FDA and industry seminars.
The court also criticized the CGMP regulations for their lack of specific-
ity, along with their ambiguity and vagueness. Responding to this criticism,
FDA drafted revisions to several parts of these regulations. The proposed revi-
sions were published in the Federal Register on May 3, 1996 [10]. One of the
main proposed changes was intended to emphasize and clarify the process vali-
dation requirements. The proposal included a definition of process validation
(the same definition used in the 1987 guideline), a specific requirement to vali-
date manufacturing processes, and minimum requirements for performing and
documenting a validation study. These were all implied but not specific in the
1978 regulation. In proposing these changes, FDA stated that it was codifying
current expectations and current industry practice and did not intend to add new
validation requirements. Comments from all interested parties were requested
under the agency’s rule-making policies, and approximately 1500 comments
were received. Most of the responses to the changes regarding process validation
supported the agency’s proposals, but there were many comments regarding the
definitions and terminology proposed about which processes and steps in a pro-
cess should or should not require validation, the number of batches required for
process validation, maintenance of validation records, and the assignment of
responsibility for final approval of a validation study and change control deci-
sions. Because of other high-priority obligations, the agency has not yet com-
pleted the evaluation of these responses and has not been able to publish the
final rule. In addition to the official comments, the proposed changes prompted
numerous industry and FDA seminars on the subject.
Process validation is not just an FDA or a U.S. requirement. Similar re-
quirements are included in the World Health Organization (WHO), the Pharma-
ceutical Inspection Co-operation Scheme (PIC/S), and the European Union (EU)
requirements, along with those of Australia, Canada, Japan, and other interna-
tional authorities.
Most pharmaceutical manufacturers now put substantial resources into
process validation for both regulatory and economic reasons, but despite contin-
ued educational efforts by both the agency and the pharmaceutical industry,
FDA inspections (both domestically and internationally) continue to find some
firms manufacturing drug products using unvalidated or inadequately validated
processes. Evidently there is still room for improvement, and continued discus-
sion, education, and occasional regulatory action appears warranted.
The future of process validation is also of great interest, especially with
the worldwide expansion of pharmaceutical manufacturing and the desire for
6 Dietrick and Loftus
REFERENCES
1. Loftus, B. T., Nash, R. A., ed. Pharmaceutical Process Validation. vol. 57. New
York: Marcel Dekker (1993).
2. U.S. Food and Drug Administration. Compliance Program no. 7356.002.
3. U.S. Food and Drug Administration. Guideline on General Principles of Process
Validation. Rockville, MD: FDA, 1987.
4. Federal Food Drug and Cosmetic Act, Title 21 U.S. Code, Section 501 (a)(2)(B).
5. Code of Federal Regulations, Title 21, Parts 210 & 211. Fed Reg 43, 1978.
6. U.S. Code, Federal Food Drug and Cosmetic Act, Title 21, Section 510 (h).
7. Byers, T. E. Design for quality, Manufacturing Controls Seminar, Proprietary Asso-
ciation, Cherry Hill, NJ, Oct. 11, 1974.
8. Loftus, B. T. Validation and stability, meeting of Parenteral Drug Association,
1978.
9. U.S. v. Barr Laboratories, Inc., et al., Civil Action No. 92-1744, U.S. District Court
for the District of New Jersey, 1973.
10. Code of Federal Regulations, Title 21, Parts 21 & 211, Proposed Revisions, Fed
Reg (May 3, 1996).
References
Introduction
xxxvi Nash
14. Nash, R. A., Streamlining Process Validation, Amer.
Pharm. Outsourcing May 2001.
6. U.S. Code, Federal Food Drug and Cosmetic Act, Title 21,
Section 510 (h).
30 Chao et al.
82 Trubinski
212 Nishihata
234 Sofer
42. U.S. FDA. Guidance for Industry IND Meetings for Human
Drugs and Biologics CMC Information. draft (Feb. 2000).
326 Trappler
400 Nash
524 Huber
790 Rifino
11. Chao, A. Y., St. John Forbes, E., Johnson, R. F., von
Doehren, P. Prospective process validation. In: I. Berry,
R. A. Nash, eds. Pharmaceutical Processing Validation. vol.
23. New York: Marcel Dekker, pp. 227–248 (1993).
28. Fed Reg 56(198), 51354 (Oct. 11, 1991). See 21CFR Part
211 et al.
854 Wachter