Pharmaceutical Validation Problem 4 of 10.

There are many simple and quiet straight forward tasks that if we had know about them and tackled them at an early stage we would have delivered our validation project through on time, within budget and with a lot less hassle.  We have documented what we consider to  be the top ten of these tasks and will issue then one at a time in a random mix in our next ten news-letters. 

At Number Four we have:  Client document reviewing and approving.

The client nearly always insists on reviewing and approving consultant prepared documents, prior to their use. These tasks are the most consistently under manned tasks in projects. After many project disputes about what were or are the actual choke points in project progress, we started to advocate that a simple progress plan was set out to display, to all, the time involved in this task. 
Use a planning tool such as Microsoft Project.  Meet with the client or your peers, and jointly agree that the times allowed for the various tasks, is a time they can and will work to.  Agree how often a document should be reviewed (is each person going to review concurrently, consecutively or is every one circulated and given a set time to return document with their comments).  If one person is on holiday or sick leave, consecutive reviewing could mean that the reviewing process will stop at his desk and reviewing, in general, could choke to a standstill.  Reviewers should be nominated by job title and at the very least one deputy should be nominated for each title.  A time limit must be set for each title holder to review each document and the number of reviewers ideally should not exceed three.

A small project may involve (just for discussion) 20 items requiring validation. That is, 20 (IQ's)(OQ's)(PQ's), that have to be authored, reviewed (once), approved for use, and reviewed for final approval.  Using these hypothetical figures we can start to estimate the reviewing task.  The reviewers have to review, 60 documents 3 times. A total of 180 reviews, if we have 10 reviewers (an extreme, but often factual), that comes to a total of 1800 reviews. If each document lies on a reviewers desk for 4 days this could be 7200 days. Now allow for the documents that will get lost (miss-filed, tea spills etc), and it quickly becomes evident that unless this side of the validation effort is very rigorously controlled, anarchy will prevail. It is at this stage that we learned to construct a simple plan for Document Review Manpower Requirements. The manpower required always amazes the client, however, once they agree the parameters and have been served with the documented forecast, the onus is on them to perform to the parameters they agreed, or provide additional resources.  As a consultant in charge, you are failing your client if you do not get this out into the open and a solution agreed; long before reviewing commences.

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The Importance of Correct Procurement.

When an analysis of the end user's priorities, in procurement priorities, is made the importance of the equipment / programs being validateable ranks at number two out of ten.  Second only to delivery; with cost ranking around sixth. This has been true in over 80% of all cases we have been involved with.

For the-would-be purchaser, it gives enormous reassurance to know that regulatory compliant validation protocols and plans are supplied.  They are often willing to pay a 15 to 30 percent surcharge for these documents.  If a consultant is hired to produce the full suite of validation documents (8/9 documents) considerable costs are involved.  However it is the question; is the system / program actually capable of being validated?  That makes people hesitate.  I doubt (after over twenty years as an auditor) if there is any pharmaceutical company that has not at some time had to abandon new programs or equipment for these reasons.

The FDA have actually stated that 70% of validation problems are directly related to none compliant procurement methods.

Your comments about you having to validate the equipment or program are completely erroneous.  The end user has that task; your task is to ensure that your product is validatable.  That means in all ways it must be compliant with the applicable directives in cGMP.  On our site we carry further details of all these requirements.

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