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IQ/OQ/PQ

  • 1.  IQ/OQ/PQ

    This message was posted by a user wishing to remain anonymous
    Posted 11 days ago
    This message was posted by a user wishing to remain anonymous

    Hello Validation Experts, 

    Could anyone please simple rule which equipment's require IQ, OQ and PQ in a small medical devices manufacturing company?

    Do we need perform for every machine in the plant such as welding machine, CNC machines, forklifts, drilling machines, milling machines?

    And how about those machines, which are in currently from so long time?

    How IQ/OQ/PQ are different then machine maintenance stuff?



  • 2.  RE: IQ/OQ/PQ

    Posted 10 days ago

    Anon,

    All of them?  This can be a bit complex because some equipment could have a rationale for not doing certain parts of IQ, OQ, or PQ - or none of them at all.  Typically there would be a master equipment list which would include a listing of the IQ, OQ, and/or PQ with a description of need for each piece of equipment.  There are some pieces of equipment which are "simple" such as a cutter which would just be "installed" and typically a rationale written for not going through the whole IQ, OQ, and PQ process.  Whereas more complex pieces of equipment like CNC machines would typically have all of this along with the PQ for the process validations as well.  Then there are other pieces of equipment like forklifts which would may have a rationale because they are non-Good Manufacturing Practice or non-GMP related - meaning they have no impact on the manufacturing of the device.  My own thought is there are certain pieces of equipment which are known as non-GMP, but there are some silly auditors out there not using common sense.  Having a general list of all the equipment is then helpful to have a link to the IQ, OQ, and/or PQ or having a rationale statement documented that piece of equipment or type of equipment.  There are a few ways which this could be done, would need to be suited to your organisation and facility needs.



    ------------------------------
    Richard Vincins ASQ-CQA, MTOPRA, RAC
    Principal Strategy Consultant
    NAMSA
    ------------------------------



  • 3.  RE: IQ/OQ/PQ

    Posted 10 days ago

    I would like to suggest that you develop a validation master plan to define which equipment needs what.

    As an example, a welding machine needs typically IQ and OQ, but if you validated the welding process you need also PQ.  That for most equipment as they need typically only IQ and OQ.,

    And yes, IQ, OQ, and PQ is completely different from maintenance and preventive maintenance.  I can go on here for many hours, days and weeks to establish taht.

    Best,

    A



    ------------------------------
    Armin Beck
    CEO
    SunTrixConsulting LLC
    El Dorado Hills, CA
    1-925-212-7683
    armin.beck@suntrixmedical.com
    ------------------------------



  • 4.  RE: IQ/OQ/PQ

    Posted 10 days ago

    Hello Anon,

    A simple rule may suffer from oversimplification and failure to capture requirements at the appropriate granularity.  Here is our simple rule, if any piece of equipment is used during our design and development process it must undergo process validation.  We define the start of the design and development process as when a product under development enters design control.  

    Second question, yes, every "machine" which is used in our design and development process must undergo process validation.  Additionally, all process validation should be reviewed periodically to determine if new process validation needs to be conducted.

    Third question, yes even pre-existing machinery must have documented process validation reports. 

    Fourth question, in very simple terms validation assures the consistency of results from a process that cannot be fully verified by subsequent inspection and testing.  Maintenance is care for the equipment and infrastructure (the pieces and parts) so it runs but does not help assure a process can consistently meet requirements or specifications.

    See GHTF/SG3/N99-10:2004 Quality Management Systems - Process Validation Guidance; 21 CFR 820.3(z)(1); 820.75; and ISO 13485 7.5.6.  CDRH/DICE also has some training on this.



    ------------------------------
    William Coulston PMP, MS, RAC
    Director of Quality & Regulatory Affairs
    Rochal Technologies
    San Antonio TX
    United States
    ------------------------------



  • 5.  RE: IQ/OQ/PQ

    Posted 10 days ago

    IQ/OQ/PQ does not apply to equipment, but to process validation.

    A process requires validation when you don't check the process output for items the process produces. You need a method to ensure that every item produced is conforming without inspecting or testing it.

    IQ ensures the production equipment is installed correctly. IQ applies to most equipment and is covered by 820.70(g). In addition, I tell my clients to implement the OSHA requirements for lock out/tag out and for machine guarding as part of IQ.

    When a process requires validation, you don't check the output. This means your only controls are the process inputs. PQ determines the parameter space for the process inputs that provide "a high degree of assurance" that the process output is conforming. I tell my clients that this means a Cpk of 1.33 or better. The common approach uses a fractional factorial designed experiment to set the input parameter space. There is a GHTF guidance document that has pretty good worked example.

    PQ is a check on the IQ results that helps you determine whether you have them right for the different products the process produces.



    ------------------------------
    Dan O'Leary CQA, CQE
    Swanzey NH
    United States
    ------------------------------



  • 6.  RE: IQ/OQ/PQ

    Posted 10 days ago

    Qualification is generating documentation that the equipment is fit for use - it was installed correctly, has been added to our calibration and preventive maintenance program if applicable and operates as designed. With this you get all equipment should undergo some type of qualification based on the risk it has to the process. USP has a good chapter as it relates to laboratory equipment to classify equipment into categories - those that need nothing more than yest they operate to those that require extensive testing to demonstrate all of their functions perform as desired. As others in this thread have suggested - a master plan or similar document that categorizes equipment into classes with each class predefined as to what is required. Risk Management methodology can be used to support the classification. Based on fit for use - means somewhere you have defined what is its use - depending on the complexity this may mean extensive user requirements (documented) to capture its intended use. Maintenance and calibration are programs that ensure that the equipment continues to operate in a qualified state, they cannot be used to establish a qualified state. 



    ------------------------------
    David W. Husman, Ph.D., ASQ CPGP, RAC
    President and Principal Consultant
    David Husman Consulting, LLC
    Greenville, SC
    USA
    ------------------------------



  • 7.  RE: IQ/OQ/PQ

    This message was posted by a user wishing to remain anonymous
    Posted 10 days ago
    This message was posted by a user wishing to remain anonymous

    If you are in the US (or sell into the US), this is the FDA's position on process validations:

    iii. Process Validation (Sec. 820.75)
    

        143. A few comments on proposed Sec. 820.75 Special processes 
    stated that the meaning of the term ``special processes'' was unclear. 
    Other comments stated that FDA should provide examples of processes 
    that would be considered ``special processes.'' Several comments stated 
    the term ``fully verified'' was unclear and should be deleted.
        In response to the comments, the term ``special processes'' has 
    been dropped from the regulation and the term ``process validation'' is 
    defined in Sec. 820.3(z)(1). The section now requires that when a 
    process ``cannot be fully verified by subsequent inspection and test, 
    the process shall be validated with a high degree of assurance. * * *'' 
    Examples of such processes include sterilization, aseptic processing, 
    injection molding, and welding, among others. The validation method 
    must ensure that predetermined specifications are consistently met. The 
    new Sec. 820.75, entitled ``Process validation,'' is consistent with 
    ISO 9001:1994, section 4.9, including the terminology ``fully 
    verified.'' FDA does not believe this terminology is unclear since it 
    has been used in ISO 9001:1987 and 1994 and explained in several 
    guidance documents.



  • 8.  RE: IQ/OQ/PQ

    Posted 9 days ago

    There are a lot of misinterpretations in the responses here. AAMI has a course on Process Validation you may want to take, it is done virtually so it is available anywhere you are located.

    As mentioned in one of the posts, for medical devices there is a great GHTF guidance on Process Validation for medical devices including IVDs which is the IQ,OQ,PQ process you asked about. This only applies to processes which require Process Validation. The guidance helps you determine which processes must be validated  

    The point of apparent confusion here is that ALL equipment used in manufacturing requires Qualification, often referred to as Equipment Qualification to assure it is installed correctly and has the necessary inputs such as electrical power, air supply, and necessary water and any other services such as necessary maintenance to perform as required. ALL equipment requires Equipment Qualification. 

    IQ, OQ, PQ are elements of Process Validation which are applied as described in the mentioned GHTF guidance. Not all processes require Process Validation, but it is applied as described in the guidance.  IQ and EQ are very similar processes which may lead to confusion.  IQ is Installation Qualification, which assures equipment used in Orocess Validation is installed correctly and has required inputs. OQ is Operational Qualification and helps establish the ability of a process to produces product meeting specifications.  PQ is Process Qualification which assures a Process will operate over a longer term producing Product that meets requirements. 

    So, all Equipment you use in production requires EQ. All Processes which require Validation require IQ, OQ, and PQ. Additionally all equipment used to make any measurements for Verification, including Design Verification, Incoming Inspection, In-process Inspection, and especially Final Acceptance require EQ AND Calibration. 

    Just to add to confusion the above is for medical devices including IVDs. If you are in drugs or biological, US FDA has a process validation guidance for those products. 



    ------------------------------
    Edwin Bills
    Edwin Bills Consultant
    ASQ Fellow CQE, CQA, CQM/OE, RAPS RAC
    elb@edwinbillsconsultant.com
    ------------------------------



  • 9.  RE: IQ/OQ/PQ

    This message was posted by a user wishing to remain anonymous
    Posted 7 days ago
    This message was posted by a user wishing to remain anonymous

    Excellent - Edwin

    Thanks for clarification and for detailed answers.

    How we can do EQ?
    Please give me some guidelines with useful examples.

    Thanks




  • 10.  RE: IQ/OQ/PQ

    This message was posted by a user wishing to remain anonymous
    Posted 7 days ago
    This message was posted by a user wishing to remain anonymous

    Excellent Edwin. Thanks for clarifying the concept.

    How we can do EQ?
    Please give some examples




  • 11.  RE: IQ/OQ/PQ

    Posted 7 days ago

    Probably the best description is the US FDA 21 CFR 820.70 (g) regulation, which is similar to ISO 13485 7.5.6 and 6.3,  where it states "Each manufacturer shall ensure that ALL equipment used in the manufacturing process meets specified requirements and is appropriately designed, constructed, placed, and installed to facilitate maintenance, adjustment, cleaning, and use."  This description is a little more complete than IQ in Process Validation GHTF guidance, but again a little more information that you must complete.

    Installation of the equipment includes things like is the electrical service adequate and does it meet the requirements of the equipment manufacturer, similar to other services like air and water.  Does the equipment have everything it needs to function properly, according to the manufacturer's instruction.  Is it included in your maintenance system, and do you have all the needed items to service the equipment.  What is the recommended operation of the equipment? 40 hours per week or some other period?  Is this how you will operate it?  If you are operating different from the manufacturer recommendation then you have to adjust your maintenance appropriately.  When you have it properly installed you need to verify it operates as designed and that it meets your requirements.  Have all concerned with he equipment been properly trained in its operation and maintenance?   There requirements apply to all equipment as well as the addition sub-paragraphs 1,2,3 under 820 70 (g) on maintenance, inspection, and adjustment of equipment.  

    Hope this helps.  The FDA regulation is available online for free with a simple search of 21 CFR 820 on your browser, where the ISO 13485 standard must be purchased from your standards provided, if you do not already have a copy. 

    By the way, equipment used in inspection, testing, and measurement  during manufacturing falls in this process as well as it is "equipment used in the manufacturing process".  Additional requirements for calibration of this equipment applies as described in 21 CFR 820.72 and ISO 13485 7.6

    IQ in Process Validation is similar but only applies to equipment used in processes that are to be validated.  You might be able to write a single procedure for both, but EQ applies to all equipment used in manufacturing while IQ only apples to the equipment used in the Process Validation activities, and has a little more detail.



    ------------------------------
    Edwin Bills
    Edwin Bills Consultant
    ASQ Fellow CQE, CQA, CQM/OE, RAPS RAC
    elb@edwinbillsconsultant.com
    ------------------------------



  • 12.  RE: IQ/OQ/PQ

    Posted 7 days ago

    In addition to all the good things Ed cited, I recommend to my clients that they also include the OSHA requirements on Lock-out/tag-out as well as the requirements for machine guarding.

    These are most easily done during installation. They protect the health and safety of employees and can prevent large OSHA fines.

    There are probably similar regulations outside the US.



    ------------------------------
    Dan O'Leary CQA, CQE
    Swanzey NH
    United States
    ------------------------------



  • 13.  RE: IQ/OQ/PQ

    This message was posted by a user wishing to remain anonymous
    Posted 6 days ago
    This message was posted by a user wishing to remain anonymous

    Hello Dan, 

    Is there any Standard, we need to comply for OHSA?

    If we don't do, what are the consequences?

    what are OSHA requirements on Lock-out/tag-out ?

    How it can help in EQ or IQ/OQ/PQ?

    Thanks




  • 14.  RE: IQ/OQ/PQ

    Posted 6 days ago

    OSHA has a set of regulations, which they call standards.

    29 CFR 1910.147 - The control of hazardous energy (lockout/tagout).

    29 CFR 1910.147 App A - Typical minimal lockout procedures

    29 CFR 1910 Subpart O - Machinery and Machine Guarding

    The OSHA standards are required in the US.

    These two standards are most easily implemented during installation. For example, during installation you will learn all power sources to the machine (electricity, compressed air, etc.) , so that is the best time to document the lockout/tagout plan. Similarly for machine guarding.

    The goal is operator safety. You do not want an operator maimed or killed because you failed to take these basic steps.

    OSHA performs inspections and can cite your company for violations. Unlike FDA, OSHA is quick to levy fines. I haven't checked the data in a few years, but, as I recall, annul fines to manufacturers run around five million dollars for each of the regulations.

    There are also financial issues related to insurance and to worker's compensation.

    Equipment installations (EQ & IQ) should also include these regulations.



    ------------------------------
    Dan O'Leary CQA, CQE
    Swanzey NH
    United States
    ------------------------------



  • 15.  RE: IQ/OQ/PQ

    This message was posted by a user wishing to remain anonymous
    Posted 6 days ago
    This message was posted by a user wishing to remain anonymous

    Hello Dan, 

    Thanks for detailed answers.

    OHSA requirements are only applicable in US, correct?

    Do we need LOTO procedures for Canadian Medical Devices Manufacturer?

    Thanks




  • 16.  RE: IQ/OQ/PQ

    Posted 6 days ago

    OSHA regulations apply to the US only.

    However, I'm sure that other industrial countries have similar regulations. I just don't know them.



    ------------------------------
    Dan O'Leary CQA, CQE
    Swanzey NH
    United States
    ------------------------------



  • 17.  RE: IQ/OQ/PQ

    This message was posted by a user wishing to remain anonymous
    Posted 6 days ago
    This message was posted by a user wishing to remain anonymous

    Excellent - thanks for the clarification




  • 18.  RE: IQ/OQ/PQ

    Posted 6 days ago

    Anon, you'll find an introduction to Lockout/Tagout requirements here:

    https://www.osha.gov/control-hazardous-energy



    ------------------------------
    Anne LeBlanc
    United States
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  • 19.  RE: IQ/OQ/PQ

    Posted 6 days ago

    Hi Anon,

    We can support you with process validation for medical device manufacturing. Cencora PharmaLex is one of the largest global regulatory solutions providers for Pharma, Biotech, and MedTech companies, with offices in over 60 countries around the globe. We can provide solutions at whatever stage of development or commercialization you're at in the product lifecycle. I'd be happy to discuss your needs further or connect you with the appropriate subject matter experts here at Cencora PharmaLex.  Please let me know what the best way to connect with you is, and we can set up a call.



    ------------------------------
    Kayla Maue
    PharmaLex - ENTERPRISE
    Conshohocken PA
    United States
    ------------------------------



  • 20.  RE: IQ/OQ/PQ

    Posted 5 days ago

    A Canadian introduction to LOTO:  https://www.ccohs.ca/oshanswers/hsprograms/lockout.html

    Each province has its own occupational health and safety regulations. It is important for your company to be familiar with the applicable ones.

    https://www.ccohs.ca/oshanswers/legisl/legislation/intro.html



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    Anne LeBlanc
    United States
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