金币
UID176556
帖子
主题
积分25241
注册时间2014-6-6
最后登录1970-1-1
听众
性别保密
|
发表于 2016-6-10 15:25:36
|
显示全部楼层
Q7A how to do中有提到这个不合格放行至下一步骤的情况。供参考讨论:
The statement "can be reworked or reprocessed" replaced the requirement that such material should be "rejected" during the discussions in the WG to indicate quite clearly that, in the cases of intermediates and APIs, further processing is one option of treating materials not meeting specification. Nevertheless the input specification of the material has to be met.
One possibility which was not specifically mentioned, is that of actually using the batch of rejected material in the process without reworking or reprocessing it. § 2.15 (这是什么意思???)might be so interpreted to mean that intermediates which do not meet specification can still be released under quarantine for use in the next process step, and the "completion of the evaluation" can be carried out at the end of the process, i.e. a check is made whether the detected deviation from specification has no effect upon the final product. If such a procedure is permitted by the company's SOPs then there should be the requirement that such a step be classified as a "Concurrent Validation" step, because it will rarely have been covered by the normal prospective validation activities. 这句话就是说rejected中间产品放行至下一步骤,并且“通过在下一步骤产品或者在最终产品”完成评估该质量偏差是否会对最终产品有影响。如果该公司内部程序允许(那么这样看这种做法应该至少不是禁止的),这种操作应该被归为同步验证,因为这种操作很少会出现在正常的前验证程序中。这个到底怎么理解呢?????因为我们也经常遇到这种中间体不合格情况,但是技术部use test和评估以后证明能合格,就放行到下一步骤去了,生产的最终的成品也是合格的,但是不知道怎么处理其放行问题。@hongwei2000 @uiofer
As there is no definition of "Rejected" in the Guide it is left to each company to lay down its' own policy on this topic in writing. A reasonable policy would usually state that if materials are truly "rejected" i.e. cannot be treated in any other way, apart from permanent disposal, then a record should be maintained of when and how this disposal was carried out. This procedure should also cover API starting materials which are returned to the supplier as being unsuitable for use, such returns however should be accompanied by the provision that the supplier should not just blend the "returned" material with good batches and then resubmit this.
|
|