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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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