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发表于 2017-5-23 15:43:03
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以下是欧盟附录15的项目负责人关于这两个词的内容。全文见附件。意思就是说这两个没什么区别。
Ongoing process verification is something new that has been introduced to EU GMP. Traditionally in the past, companies would maybe repeat the process validation based on a time interval. Five years was common. Some might repeat the whole process validation. Some might do an assessment. So they may look at the data and then decide if the need to do a process validation or not. So there were lots of approaches previously.
Now we are saying that it needs to be done for all products. So our definition: There is a monitoring process to confirm that state of control is maintained throughout that product lifecycle. The aim is to detect unplanned departures or unintended process variability from the process as designed. And I am sure that definition is not significantly different from how you use it in the USA.
How would we expect that to work in practice? In practice, companies spend an awful lot of time on what we call product quality reviews [PQRs] in Europe, and in America you call them annual product reviews [APRs]. We spend an awful lot of time preparing that document. And I have always thought, ‘do we actually get any benefit from doing it?’ So hopefully with the introduction of ongoing process verification, that could be used to confirm that the process is in a state of control.
There may also be some circumstances where you have a written PQR or you want to look at a specific issue. And under these circumstances you could also write a specific protocol or write a specific report to confirm some aspects of ongoing process verification.
Again, the frequency by which you perform it should be based on the lifecycle. For example, if it is a new product, you would expect it to be more frequent than an established product.
I should have said at the beginning when I presented this that we changed ‘continued process verification’ to ‘ongoing process verification,’ because we thought there was confusion between continuous and continued. So the terminology has changed. I apologize for not saying that earlier. In American terms, this is continued process verification. |
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