change control 1
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Ajmal Nasir P h. DDirector TechnicalBF Bioscineces LtdLahorePAKISTAN
Change Control
Importance & Management .
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OBJECTIVETo Discuss TheImportance Of
Change Control,Requirement
AndEffective Management.
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DEFINITIONA CHANGE IS ANY VARIATION THAT MAY
IMPACT CONSISTENT PRODUCT QUALITY .
Variation Can Be In Documentation,Equipment, Packaging, Utilities, Facilities,
Formulations, Process Or Computer System.
The Change May Or May Not Impact The Safety,Quality, Purity Or Potency Of A ProductThroughout Its Shelf Life
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INITIATIVES TO CHANGEChange is the end result of initiatives for QualityManagement and Continuous improvement .
Objective of Change is
Improving QualityIncreasing Yield
Reducing Costs
Cutting Waste
Streamlining
Processes Etc .
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Change is of two Types:Temporary
Can be a planned or un planneddeviation.
PermanentResult of three planned and approved
deviations agreed by all stake holders.
CLASSIFICATION OF CHANGE
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CLASSIFICATION OF CHANGEThere are three level of Change:
High : Very likely to impact the product.
Medium : Somewhat likely to impact theproduct
Low : (Emergency changes) Anticipated tohave no or a negligible impact on the product.Change Level indicates the possible
impact to the product .
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Why a Change ControlOne Of The Most Critical Element In APharmaceutical Or Biotech Company'sQuality Management System.
Huge Risk Of Non Compliance If NotAdequate.
The FDA's Guidance For Industry, EUOrange Guide , ICH Guidelines Etc. ClearlyReinforces The Importance OfImplementing An Effective Change ControlProcedures As A Critical Component In An
Overall Quality System .
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Change Control is Done ForAdvance Determination of Possibleissues Related to Proposed orRequired Change.
Decision on required Validation orQualification Possibilities.In time Preparation or Updating of
SOPs / Documents .Structured Training program for allConcerned.
Smooth sailing of the CHANGE
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WHO CAN INITIATE CHANGEAny Body In The Organization CanInitiate.Must Be Reviewed and Approved By TheSectional Head And All Other SectionsInvolvedThe Activity Shall Be Controlled By QO
Formal Review Of Change ControlRequest.Formal Approval / Rejection By All
Concerned.
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What IS Required ?A Formal System By Which Qualified
Representatives Of AppropriateDisciplines Review Proposed Or Actual
Changes That Might Affect The Validated Status Of Facilities, Systems,
Equipment or Processes That WouldEnsure And Document That The System
Is Maintained In A Validated State EU guidance on GMP - Qualification and Validation (Annex 15 of the 'Orange Guide' page 185)
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PROGRAM DESIGNThe Program Must Manage The End-to-
End Change Control ProcessIncluding:
Initiating
Reviewing
Approving
Training Distributing
Storing Change History.
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PROGRAM SCOPE The Change Control Program MustCover A Broad Set Of Possibilities Including
Formulation
Product Design,
Facilities,
Utilities
Equipment
Computer systems,
Manufacturing
instructionsSOPs,
Test methods
Specifications,
New raw materials
Changes in Policy.
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PROGRAM MUSTProvide Compliance
Capture Relevant Information ForThe Objective ,Nature &Scope OfCC.
Provide Traceable History ofChanges in Quality and Systems
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System Schematic
Assess (reviews) the change [follow-up]
Implements change
Approves the change
Assesses impact of the proposed change
Identifies The Need For Change
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Impact Assessment
For Impact analysis we shallconsiderRisk Associated to the Change
Which SOPs and documents will be affected
Impact on other Departments
Training required before the Change
implementation
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Risk AssessmentShould be performed by a person or
Committee understanding Process andexpert in Transfusion.
How Bad
Action
Needed?
Frequency?
What Can
Go Wrong
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RISK MATRIX
CRITICAL
MAJOR
MODERATE
MINOR
NEGLIGABLE
RARE UNLIKELY POSSIBLE LIKELY ALMOST CERTAIN
CONS
QUEN
C
LIKELIHOOD
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WHAT WE NEED TO MANAGECHANGE CONTROL
A Company -wide Change ControlSystem
HISTORY Maintenance Of Changes ForAudit Trail Purposes(Most ImportantAspects )
A Structured Approach TowardsManaging Change In An EnvironmentFocused On Continuous Improvement.
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How system should be
Initiating,
Reviewing,
Approving,
Distributing
Training
Maintaining Change
History
Evidence To Compliance
Must Helps To Capture Relevant Information About
The Objective, Nature And Scope Of Change.
A Concrete System Capable To Manage The End-to-endChange Control Process Must Include :
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Approach Shall Be
KISS
Keep It SimpleStupid
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ELEMENTS OF GOOD SYSTEM
A company wide SystemOwner Ship at all levelsList of Change Control Items
Formal Review ,Risk analysis,approval/ RejectionSimple Forms and PathwayAn efficient and Quick SystemProper Training and DistributionArchiving of HistoryFormal Close out
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What Is The Difference Between DeviationAnd Change Control? At What Situations WeCan Raise The Deviation And Change Control
Deviation is temporary and it is twotypes one is planed deviation anotheris un-planed deviation. Un-planed
deviation occurs suddenly.Change control is a proposal thatchange in any process, equipments or
method. But it approved the commentsof all department which are related tothis change.
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