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发表于 2013-9-21 08:53:39
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Common Errors
1. Failing to perform a good process flow,beginning with the raw material sampling process and focusing on obviouslyimportant stages such as the compounding or filling process.
2. Failing to train operators well, andfailure to instill a sense of high commitment:
Most common mistakes, such as not following procedures, not taking samples at the time specified, improper handling of samples, not reporting discrepancies observed during the specific process executed, etc., undermine high quality performance and contribute to poor results. It is highly recommended to have representation from the validation department present throughout all runs.
3. Missing or inaccurate documentation:
In addition, to the common errors noted above in #2, a lack of documentation also causes difficult situations during future audits, because important key information will be missing during investigations. This is often the basis for general misunderstanding of data.
4. Lack of good coordination andcommunication between the different areas involved in the validation process:
Examples of poor coordination and communication include samples not being taken on time, required materials not being available, disputes within departments, lack of cooperation, and bad working environments based on placing blame rather than on cooperation.
5. Failing to understand the criticalityof the sampling process:
It is very important to take the samples at the time(s) established and for the proper durations (stability), taking correct quantities and volumes, attending to the proper handling and storage of samples, using the correct equipment, and other special considerations for samples requiring microbiological testing.
6. Failure to properly train persons incharge of sampling:
This can have a major impact on the accuracy of microbiological sampling.
7. Not having an effective change controlprogram:
Once the validation process is completed, internal procedures impacted by the validation outcomes must be revised accordingly. It is frequently observed that the communication and follow up systems fail at some point and impacted procedures and activities are not modified.
8. Not having an adequate cleaningmonitoring system:
It is frequently observed that changes are made to an already validated system, disregarding the impact those changes might have on the validation state of the total system. Constant communication between manufacturing and the validation department is critical.
9. Failure of manufacturing areas toconsider the validation department in internal changes and procedure approval:
Due to lack of technical knowledge in the validation area personnel in manufacturing might overlook or be unaware of important aspects that have impact from a validation point of review.
10. Failure of plant personnel primarilyfocused on the manufacturing operation, to require compliance with the cleaningvalidation procedures. |
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