Analysis and Testing Flashcards
What is an OOS (Out of Specification) Result?
Test result that does not comply with the pre-determined acceptance criteria (e.g, filed applications, drug master files, approved marketing submissions, or official compendia or internal acceptance criteria).
– Test results that fall outside of established acceptance criteria which have been established in official compendia and/or by company documentation (i.e., Raw Material Specifications, In-Process/Final Product Testing, etc.).
What is an Out of Trend (OOT) result?
– The result is not necessarily OOS but does not look like a typical data point.
- Generally a stability result that does not follow the expected trend, either in comparison with other stability batches or with respect to previous results collected during a stability study
- However trends of starting materials and in-process samples may also yield out of trend data.
- Should be considered for environmental trend analysis such as for viable and non viable data (action limit or warning limit trends)
Whay is an Atypical / Aberrant / Anomalous Result?
Results that are still within specification but are unexpected, questionable, irregular, deviant or abnormal. Examples would be unexpected result for stability test point, etc.
When do “Out of Specification (OOS) / Out of Trend (OOT)/ Atypical -results” need to be investigated?
in cases of:
– Batch release testing and testing of starting materials.
– In-Process Control testing: if data is used for batch calculations/decisions and if in a dossier and on Certificates of Analysis.
– Stability studies on marketed batches of finished products and or active pharmaceutical ingredients, on-going / follow up stability (no stress tests)
– Previous released batch used as reference sample in an OOS investigation showing OOS or suspect results.
– Batches for clinical trials
When are additional analyses permitted without OOS/OOT/Atypical investiation?
Pharmacopoeia have specific criteria for additional analyses of specific tests (i.e. dissolution level specification for S1, S2 & S3 testing; Uniformity of dosage units specification for testing of 20 additional units; Sterility Testing).
However if the sample test criteria is usually the first level of testing and a sample has to be tested to the next level this should be investigated as it is not following the normal trend
Also for In-process testing while trying to achieve a manufacturing process end-point i.e. adjustment of the manufacturing process. (e.g. pH, viscosity), and for studies conducted at variable parameters to check the impact of drift (e.g. process validation at variable parameters).
What is a Phase 1a Investigation?
To determine if there is clear obvious error(s) due to external circumstances affecting the analysis.
Examples:
* Calculation error
* Power outage
* Equipment failure
* Spilling of sample
* Incorrect Instrument Parameters
What is a Phase 1b Investigation?
Initial Investigation conducted by the analyst and supervisor using the Laboratory Investigation Checklist
What is a Phase II Investigation?
Conducted when the phase Ia+Ib investigations did not reveal an assignable laboratory error.
Phase II investigations are driven by written and approved instructions against hypothesis to determine whether there is a laboratory testing issue or there is a possible manufacturing root cause.
What is a Phase III Investigation?
(typically done as part of manufacturing deviation). The batch is rejected, there still needs to be an investigation to determine:
– if other batches or products are affected.
– identification and implementation of corrective and preventative action.
What is a Specification?
From MHRA guidance on OOS & ICH Q6A:
A list of tests, references to analytical procedures, and appropriate acceptance criteria which are numerical limits, ranges, or other criteria for the tests described. It establishes the set of criteria to which a drug substance, drug product or materials at other stages of its manufacture should conform to be considered acceptable for its intended use. “Conformance to specification” means that the drug substance and drug product, when tested according to the listed analytical procedures, will meet the acceptance criteria.
Specifications are critical quality standards that are proposed and justified by the manufacturer and approved by regulatory authorities as conditions of approval.
What is an Acceptance Criteria?
Numerical limits, ranges, or other suitable measures for acceptance of the results of analytical procedures which the drug substance or drug product or materials at other stages of their manufacture should meet.
What can an OOS result be invalidated?
A test is considered invalid when the investigation has determined a sample/ laboratory assignable cause.
What is a Reportable Result?
The final analytical result. This result is appropriately defined in the written approved test method and derived from one full execution of that method, starting from the original sample.
What is Hypothesis testing?
Documented and approved testing performed (phase 1b or phase II) to help confirm or discount a possible root cause.
For example: it may include further testing regarding sample filtration, sonication /extraction; and potential equipment failures etc. Multiple hypothesis can be explored.
What is a Retest?
If no assignable cause can be identified during the manufacturing investigation or the assay failure investigation, retesting may be considered. Performing the test over again using material from the original sample composite, provided it has not been compromised and is still available. If not, a new sample will be used (re-sampling).
The minimum number of retests should be documented within the procedure and be based upon scientifically / statistically sound principles. (e.g. 7 or 9 retests)
When is averaging permitted as part of OOS investigation?
– When all test results conform to specifications
– Where averaging must be specified by the test method.
– Consideration of the 95% Confidence Limits (CL 95% ) of the mean
- When averaging is the registered reportable result.
When is resampling permitted as part of OOS investigation?
Rarely….. If original sample determined to be non representative of batch or that it is compromised, or if there is insufficient quantity of the original sample to perform all further testing. Must be discussed and agreed by QA/Contract Giver and process of obtaining the resample recorded within
the laboratory investigation.
When can Outlier tests be used in OOS investigation?
Statistical analysis for Outlier test results can be as part of the investigation and analysis. However for validated chemical tests with relatively small variance and that the sample was considered homogeneous it cannot be used to justify the rejection of data.
How are confirmed OOS results for a batch handled?
The OOS result should be used in evaluating the quality of the batch or lot. A confirmed OOS result indicates that the batch does not meet established standards or specifications and should result in the batch’s rejection and proper disposition.
Other lots should be reviewed to assess impact.
How are inconclusive OOS investigation results for a batch handled?
In cases where an investigation:-
(1) does not reveal a cause for the OOS test result and
(2) does not confirm the OOS result
– the OOS result should be given full consideration (most probable cause determined) in the batch or lot disposition decision by the certifying QP and the potential for a batch specific variation also needs considering.
What is Accuracy?
The closeness of the experimental to the true value (ICH Q2 R1)
What is Precision?
A measure of closeness of results (ICH Q2 R1)…..Types of Precision are: Repeatability, Intermediate Precision, Reproducibility
What is Repeatability?
Intermediate precision?
Reproducibility?
Repeatability - Under identical conditions….ICH Q2R1
Intermediate - within lab variation, eg on different days/analyst ….ICH Q2R1
Reproducibility - Between lab variation (use 2 labs)….Also ICH Q2R1
What guidance is there on reference and retain samples?
Eudralex volume 4 Annex 19: Reference and Retention Samples
Reference sample: A sample of a batch of starting material, packaging material or finished product -stored for the purpose analysis if needed during shelf life of the batch concerned. Where stability permits, reference samples from critical intermediate stages (e.g. those requiring analytical testing and release) or intermediates transported outside of the manufacturer’s control, should be kept.
Retention sample: A sample of a fully packaged unit from a batch of finished product. Stored for identification purposes. eg, presentation, packaging, labelling, patient information leaflet, batch number, expiry date should the need arise during the shelf life of the batch. May be exceptional circumstances where this requirement can be met without retention of duplicate samples e.g. where small amounts of a batch are packaged for different markets or in the production of very expensive medicinal products.
- necessary for manufacturer, importer or site of batch release to keep reference and/or retention samples from each batch of finished product and, for manufacturer to keep reference sample from a batch of starting material.
- can be assessed in the event of quality complaint, query relating to compliance with MA, a labelling/packaging query or a pharmacovigilance report.
- Records of traceability of samples maintained and be available for review by competent authorities.
- Should be retained for at least one year after the expiry date.
- samples of starting materials (other than solvents, gases or water used in the manufacturing process) shall be
retained for at least two years after the release of product. - The reference sample should be representative, close to suitable laboratory with validated methods and of sufficient size to permit on, at least, twice, full analytical controls on the batch in accordance with the MA. Must be in EEA unless MRA in place.
- A set of Retention samples must always be in EEA, preferably at certifying QP site.
- all necessary analytical materials and equipment ahould available to carry out all tests in the specification until one year after expiry of the last batch manufactured.
- Ensure appropriate storage conditions and written agreements and access by the QP performing certification.
What are the requirements for Analytical validation?
ICH Q2 (R1) & EU GMP Chapter 6, Quality Control: Analytical method transfer & FDA Guide – Analytical Method Validation
General Trends in Method Validation and Transfer
* Use of integrated lifecycle
Design – development – validation – routine use – updates – transfer
* Quality by Design
* Understand critical parameters
* Apply structured risk assessment for selection of DoE tests
* Use multivariate DoE studies to define method operational limits
* On-going control of critical parameters during routine operation
ACCURACY
PRECISION
- Repeatability
- Intermediate Precision
- Reproducibility
SPECIFICITY
LOD
LOQ
LINEARITY
RANGE
<ROBUSTNESS>
</ROBUSTNESS>
Is validation required for micro methods?
If it was an EP method you would just verify the ability to perform the method,
If a non-EP method
I was unclear if this was a recovery, so offered protocol, washes, removal of inhibitors, Assessor asked about the specification you would apply I said I would consult my micro person – felt out of depth