009 what are the systems validation protocol methods at atl 05 28-2015
TRANSCRIPT
Leaders in Pharmaceuticaland Medical Converting
ATL Pharmaceutical/ Medical
What Is ISO-13485/
MDD 93/42/EEC, FDA cGMP
Systems Validation Protocol ?
SYSTEMS VALIDATION PROTOCOL SYSTEMS VALIDATION PROTOCOL SYSTEMS VALIDATION PROTOCOL SYSTEMS VALIDATION PROTOCOL
INCLUDES ALL OF THE ELEMENTS INCLUDES ALL OF THE ELEMENTS INCLUDES ALL OF THE ELEMENTS INCLUDES ALL OF THE ELEMENTS
LISTED ON THIS PAGE……LISTED ON THIS PAGE……LISTED ON THIS PAGE……LISTED ON THIS PAGE……
AND MORE, INCLUDING SIXAND MORE, INCLUDING SIXAND MORE, INCLUDING SIXAND MORE, INCLUDING SIX----SIGMA.SIGMA.SIGMA.SIGMA.
ATL Specializes in Converting,
(die-cutting, laminating, stripping, sheeting, etc.)
Manufacturing of Pressure Sensitive Labels,
and Disposable Medical Devices.
Validation Is An Important Part Of Our
Manufacturing Cycle.
Time
Very precious resource. Timing is everything.
Validation
Allocation of Resources
Wasted Effort
Drastically reduced. ATL’s idea is to get yourproduct to market as quickly as possible.
PeopleAll ATL personnel are specialists
working for you.
IdeasATL’s engineering skills and knowledgeable
staff complement your needs through
concurrent development.
Validation
Allocation of Resources
ATL’s Facility
Newly constructed world class manufacturing
center in Menomonee Falls, Wisconsin.
We can bring your product to market.
An entire assembly or a beautiful label …
Validation
Allocation of Resources
ATL Plant, W140 N9504 Fountain Blvd, Menomonee Falls, Wisconsin, 53051ATL Plant, W140 N9504 Fountain Blvd, Menomonee Falls, Wisconsin, 53051ATL Plant, W140 N9504 Fountain Blvd, Menomonee Falls, Wisconsin, 53051ATL Plant, W140 N9504 Fountain Blvd, Menomonee Falls, Wisconsin, 53051
Phone 262Phone 262Phone 262Phone 262----255255255255----6150 8006150 8006150 8006150 800----444444444444----5144 www.atlco.com5144 www.atlco.com5144 www.atlco.com5144 www.atlco.com
FDA cGMP/ ISO-13485/
MDD 93/42/ EEC Validation
Begins With Customer Planning
Formulate Product Development by
Identifying Customer Needs…
• Customer Requirements (Intended Use of
Product)
• Six-Sigma Approach Used (DMAIC) Define,
Measure, Analyze, Improve, Control
• APQP (Advanced Product Quality Planning)
Implement Process Development from
Customer’s Design Goals…
•Establish Necessary Materials
• Process Flow, ISO-14971 Risk Analysis
• Timeline for Completion
• ATL Roles and Responsibilities
•Feasibilities of Your Proposed Product as ranked by product RISK
FDA cGMP/ ISO-13485/
MDD 93/42/ EEC Validation
Begins With Customer Planning
Evaluate and Control Manufacturing Process
•Packaging Standards
•Your Characteristics – critical, major, and minor
•Perform FMEA (Failure Modes & Effects Analysis)
FDA cGMP/ ISO-13485/
MDD 93/42/ EEC Validation
Begins With Customer Planning
Develop Your Product Control Plan or
FDA cGMP Performance Qualification (PQ)
•Measurement Technique
•Cpk Determination
•Sample Size
•Sample Frequency
•Control Method
•Reaction Plan
This includes:
•Product
•Process
•Operations
•Machines
•Characteristics Class
•Specification Tolerances
FDA cGMP/ ISO-13485/
MDD 93/42/ EEC Validation
Begins With Customer Planning
FDA cGMP/ ISO-13485/
MDD 93/42/EEC Validation
4 Phase A.P.Q.P.
Advanced Product Quality Planning
Phase 1 – Customer Requirements
• Design Process For Manufacturability
• Concurrent process development
• Understand Intended Use For Product
Phase 2 - Process Methods
• Process Characteristics
• Materials
• Packaging Standards
FDA cGMP/ ISO-13485/
MDD 93/42/EEC Validation
4 Phase A.P.Q.P.
Advanced Product Quality Planning
Phase 3 - Finalization of Test Run and Process Mapping
• Preliminary control plan
• Part approval process
• MSA (Measurement System Analysis)
FDA cGMP/ ISO-13485/
MDD 93/42/EEC Validation
4 Phase A.P.Q.P.
Advanced Product Quality Planning
Phase 4 – Test (Preliminary) Production Run
• Determination of conformance capability
• Production control plan
• Production Validation
• Feedback To Customer
FDA cGMP/ ISO-13485/
MDD 93/42/EEC Validation
4 Phase A.P.Q.P.
Advanced Product Quality Planning
Our Quality System
Always Has Its
Focus On The
Customer
Do
Plan
Act
Study
We Implement ATL’s FDA cGMP/ ISO-13485 Validation
To Think Like Our Customer
1. Identify what the
customer’s needs are:
2. Describe what Characteristics are
critical, major, or minor for product
conformance.
3. APQP:
Formulate
a process
8.Create
control
plan
7. Analyze
Sequence of
Cause-Effect
Events
10. Verify &
Validate
9. Run
Process
5.
Synchronize
Information
4.
Establish
Time Line
6.
Determine
Materials
11. Satisfy Customer
ATL’s products & services …almost unlimited
FDA cGMP/ ISO-13485/
MDD/93/42/EEC Validation4 Steps to Establish Control
• Fully Understand “The Voice of the
Customer” (Your Specific Needs).
• Identify Equipment Needed.
• Develop Prototype Control Plan.
• Establish Gages & Testing Equipment.
1. Set a Standard, Goal or Target:
2. Process Design & Development:
• Process Concept.
• Inter-Relationships –
Characteristics to Machine
Variability.
• Dimensional Tolerances.
•Performance Requirements.
•Material Handling.
•Process FMEA.
•Control Plan (start).
FDA cGMP/ ISO-13485/
MDD 93/42/EEC Validation
4 Steps to Establish Control
3. After Process Development, ATL Will
Finalize Your Test Run Requirements:
• Packaging Standards.
• Quality System Review.
• Control Plan (Finished).
• Process Instructions Completed.
• Device History Completed.
• Special Processes Developed.
FDA cGMP/ ISO-13485/
MDD 93/42/EEC Validation
4 Steps to Establish Control
4. Verify & Validate This Includes:
• Production Test Run.
• FDA cGMP P.Q. or Control Plan Implementation.
• PPAP and/or Final Inspection Performed.
• Production Validation.
• Capability and/or Conformance Evaluation.
• Packaging Evaluation.
• Control Plan
Formalized.
• Manufacturing &
Quality Feedback.
• Test Run Sign-off.
• Report to (end user)
Customer.
FDA cGMP/ ISO-13485/
MDD 93/42/EEC Validation
4 Steps to Establish Control
ATL takes pride in
cGMP compliance (21
CFR 210, 211, 820) for
pharmaceutical labels &
medical devices. Since
1999 our pharmaceutical
validation record has
been better than
99.985% conformance
with zero product recalls.
(Based on a systems
protocol sample size of
more than 3,000,000
units over 16 years.)
Registered Medical Device Manufacturer # 2183564
Audited for FDA cGMP,
ISO-13485, MDD 93/42/EEC
compliance.
ATL’s Liability & Responsibility
is Different than Other Printers.
Process Validation.
Statistical Process Control.
FDA cGMP
Pharmaceutical Label
Quality Assurance
ATL’s FDA cGMP/ ISO-13485
MDD/93/42/EEC Validation
Staff Is Ready To Serve You• Full time engineers and project managers.
• Tooling specialists.
• Sales engineers knowledgeable about ATL processes.
• Quality staff to manufacturing ratio is 1:8.
• ATL’s manufacturing facility is FDA cGMP compliant.
• Very low employee turnover- this provides a consistency
for repeat orders.
• Our facility (and staff) have passed pharmaceutical/ medical
audits preformed by Bristol-Myers Squibb, Novartis, Eli
Lilly, Abbott Labs, Pfizer, G.E. Medical, and many others.
ATL’s Mission Statement
The goal of “FDA cGMP/ ISO-13485/ MDD/93/42/EEC Validation” is to:
Execute one project, yours…successfully, making the best product, delivered on time.
We are dedicated to following 3 principles:
Listening to the voice of the customer.
APQP (Advanced Product Quality Planning).
Superior Manufacturing Quality Through Six Sigma (DMAIC)
Structure and Design of
FDA cGMP/ ISO-13485
MDD/93/42/EEC Validation
is Organization
ATL’s Staff is a flat structure where everyone works together
on the same level for you.
Structure and Design of
FDA cGMP/ ISO-13485
MDD/93/42/EEC Validation
is Organization
ATL’s Process Design is functional and efficient, each person has a specific
responsibility, all working in concert,focused on you.
ATL’s Engineering Project Manager,
focused on your project,
implements FDA cGMP/ ISO-13485/
MDD/93/42/EEC Validation
all in concurrent development,
and in a smooth and fluid timeline.
Structure and Design of
FDA cGMP/ ISO-13485
Validation
is Organization
ATL’s Project Coordinator
transforms critical information from the
“VOC” into ATL’s technical language.
Intended Use Of
Product Materials
Templates/
Drawings
Regulatory
Requirements
Project
Requirements
Voice
of the
Customer
Production Details
Tooling
� Materials
� Total Quantity
� Special Requirements
� Customer Information
� Construction
� Dimensions
Voice of the Customer
( VOC )
The VOC fully details “end user” customer labeling requirements:
The critical to quality (CTQ’s) characteristics to be established in concert with the “customer approved specifications”
Project Requirements
� Tooling
� Template
� Material
� Production Details
� Art / Plate
The VOC is translated into
technical language that is
understood by ATL personnel.
Once project requirements are
detailed, ATL “art” and “job”
requirements can be set into
motion (Job Ticket Established).
Tooling
� The engineer that orders your tooling is a
specialist in template layout design, and,
matches the rotary tool specifically for the job.
� Backup tooling is kept on hand for jobs with
higher quantities.
Rotary tooling is an ATL engineering specialty.
Material
The project engineer translates the required materials
into specifications for ATL purchasing:
� Face Stock
� Adhesives
� Base Stock Width
The purchasing department orders the materials and
“kits” each specific job number’s (required stocks)
in advance of production.
Customer Order
Customer
Acknowledgement
Material
Purchase Order
Plates
Purchase OrderJob Ticket
“Floor”
“Scheduling”
Art Work Purchase
Order
Job Ticket Order Entry
Medical Master Record
Prototype Master Record
Production Master Record
Three Types of (Device) Master Records
ATL manufactures a
wide variety of
products for their
customers.
The product history
includes the
description of the
methods used in
production for a
specific construction.
On-Press Inspection
Pharmaceutical/ Medical
Quality Check Startup
Pharmaceutical – Medical Product
Quality Dept. Traveler
In-Process
Label Attachments
Or Samples
Item Traceability
The device history for
pharmaceutical orders
is stored securely in a
locked area.
Medical Master Record
As the name implies, the Quality Traveler
“travels” with the job.
There are four sign-offs required on the “Traveler”.
� Line Clearance.
� First Article S/U documentation.
� Final Quality (Inspection) documentation.
� Final documentation (batch record) complete.
Pharmaceutical – Medical Product
Quality Dept. Traveler
Change Control
The ATL “Change Control” form coordinates significant changes
to an item or process. This includes…
The initiation and closeout of all change controls must be
approved by the Quality Manager.
� Existing P.Q.’s (FDA cGMP Performance Qualifications)
� Art Department
� Process Controls
� Specifications
� Raw Materials
� SOP’s
� Training
� Tooling
� Notification to Customer
� Equipment Qualifications
� Manufacturing Instructions
ATL Performance Qualification
A PQ is also performed
for color variation (in
blinded studies) for Cpk
determination (defects per
million), after major
maintenance, and, as an
ongoing assessment tool in
An ATL PQ is done on a
regular basis to each
press to access total
output (in conformance
percentage).
“Systems Validation Protocol”.
( I.Q., O.Q., P.Q. )
Equipment Qualification Review
The “Equipment Qualification Review” is used to “validate” process functions,
as they relate to various pieces of ATL equipment. For further clarification,
see the next slide, “Performance Qualification Review”.
The ATL “Quality Management System” (QMS) describes “what” we do.
The “Systems Validation Protocol” (SVP) is a validation master plan, and
describes “to what extent” we do what we do. This is expressed as defects per
million (Cpk), conformance percentage, or a validation in “yes” or “no” terms
(such as a computer test).
The “Standard Operating Procedures” (SOP) Manual describes “how” we do it.
Performance Qualification Review
Process Specific Identification
Product Features To Qualify
Qualification (List of Characteristics to Validate)
Qualification Results
Qualification Acceptance
The difference between the two:
An “EQ” is for equipment only.
A “PQ” may be for equipment, vendor, process, or procedure.
Both the “Performance Qualification” and the “Equipment Qualification”
reviews are used with the “Systems Validation Protocol”.
Common items to the “PQ” and “EQ” are:
Bell Curves
Are Shown
On Next Page
The Cpk for “L”
The Cpk for “a”
The Cpk for “b”
This is an
Actual “EQ”
for color
variation,
expressed in
L* a* b*
readings.
The process is in control, and
capable. This Equipment
Qualification is acceptable.
“L”
“a”
“b”
“L”
“a”
“b”
The ATL “Batch Record” is completed for each order.
Final Documentation Checklist
• Green “Released” label
• Copy of “Final Inspection” sheet
• Current “Master” record
• Copy of current “Quality Traveler”
• In-process samples (kept in production sequence)
• All pharmaceutical label in-process inspection sheets
• Copy of material roll tags
• Quality check start up inspection
A typical batch record includes:
Thank You!
Ad Tape & Label
W140 N9504 Fountain Blvd
Menomonee Falls, WI 53051
Phone (262) 255 6150
Toll Free 800 444 5144
Fax (262) 255 4301
www.atlco.com
Author: Donald J. Dobert, President, ATL
Ad Tape & Label