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发表于 2017-6-2 17:55:46
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这有一个案例可供参考!选自http://www.pharmtech.com/change-management-common-failures-and-checklist-improvement
- The FDA expects the intimate involvement of the quality control unit in the change control review and approval process, and usually holds the quality control unit responsible for deficiencies regarding change control, which again can be evidenced in several Warning Letters issued in the past years. One example of this FDA expectation was documented in a Warning Letter issued by the FDA in 2003. A company performed a routine replacement of the filling pump pistons, without filing a change request because it was a "like to like" replacement (which has been a typical industry practice). Although the replacement pistons had the same part number as the original pistons, they were slightly longer. This longer dimension caused the pistons to come into contact with the bottom of the filling blocks, resulting in the generation of metal particles, which contaminated the product batches. This metal contamination resulted in the recall of several product batches and the FDA's issuance of a Warning Letter. The Warning Letter stated that: "Prior to changing the filling line pump parts on the…line, the quality control unit failed to properly assess the impact that the change may have on the product. It is the quality control unit's responsibility to review any change to your manufacturing process and to assure the change will not adversely affect the drug product".
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