Validation study: Why Three batch for validation study?

In
this article we will try to understand the fundamental concept of three batches for
Validation study
; or more correctly we say Process performance qualification (PPQ).
This is very important to know “what we are doing and why we are doing” to come on fruitful conclusion. So, we will continue the topic with the small
background on regulatory requirements.

Why Three batch for validation study

Fig. 01: Validation-Three batch concept

In
the world of pharmaceutical manufacturing, Validation of manufacturing
processes is a requirement of the Current Good Manufacturing Practice (CGMP)
regulations (21 CFR 211.100 and 211.110
and
is considered an enforceable element of current good manufacturing practice for
active pharmaceutical ingredients (APIs) under the broader statutory CGMP
provisions of section 501(a)(2)(B) of the Federal Food, Drug, and Cosmetic Act.

A
validated manufacturing process has a high level of scientific assurance that it
will reliably produce acceptable product. The proof of validation is obtained
through rational experimental design and the evaluation of data, preferably beginning
from the process development phase and continuing through the commercial
production phase.

Before
the commercial distribution begins, a manufacturer is expected to have
accumulated enough data and knowledge about the commercial production process
to support post-approval product distribution. 

Normally, this is achieved after
satisfactory product and process development, scale-up studies, equipment and
system qualification, and the successful completion of the initial conformance
batches. Conformance batches (sometimes referred to as “validation”
batches and demonstration batches) are prepared to demonstrate that, under
normal conditions and defined ranges of operating parameters, the commercial
scale process appears to make acceptable product.

Generally
it is considered; three batches are required for validation study

  • If
    we get the desired quality in the first batch, it is accidental, second batch
    quality is regulator and quality in the third batch is validation.
     
  • For statistically
    evaluation and to prove reproducibility, as two data points would not show
    fluctuation (if any) it will always give a straight line and no conclusive
    remark.
  • No regulatory agency defines minimum or maximum no. of batch for
    validation study.
  • If three batch meets quality requirement as per established
    specification or acceptance criteria; 
Three batch for validation study
Fig. 02: Validation-Three batch concept

Some Fact with resect to regulatory guidance

  • Neither
    the cGMP/ICH Q7 rules, nor an FDA policy requires a minimum number of runs for
    proving the validity of a process, in validation study. 
    The
    FDA considers a reduction to 3 runs as too simple for being able to prove
    validity. (News Feed)
  • No.
     Neither the CGMP regulations nor FDA policy specifies a minimum number of
    batches to validate a manufacturing process. The current FDA guidance on APIs
    (see guidance for industry ICH Q7 for APIs) also does not specify a
    specific number of batches for process validation. The manufacturer is
    expected to have a sound rationale for its choices in this regard. (
    FDA Reference)
  • However,
    the “rule of three” batches or runs are no longer appropriate for
    process validation activities. FDA’s guidance for industry Process
    Validation: General Principles and Practices
     (2011)
    recommends that a validation
    protocol should include the sampling plan, including “sampling points, number
    of samples, and the frequency of sampling for each unit operation and
    attribute. (Reference)

Even
those with a limited knowledge of statistics will recognize that a run of three
is not statistically significant. And those who have a mastery of statistical
techniques already know that a sample of three is not significant.

If
a manufacturer were to use the success-run
theorem
 to determine the number of process validation runs,
using 95% confidence and 90% reliability, it would require 30 runs. However, 30
runs is neither practical nor cost effective. Additionally, some products may
be produced only occasionally.

I Hope this article helped you to get an fundamental overview on the Fundamental concept of Three batches for validation study. This curious topic have many different different opinion for execution. i  this series we tried to reveal the basic concept. This is not the end we will keep in touch with the consideration of topic PPQ Study and will get back with new stuff….


Learn more……..

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