By Brian Chviruk, Bristol-Myers Squibb
The Factory Acceptance Test (FAT) represents a lingering dilemma for many engineers: Accept the vendor’s standard FAT with the intent to recheck everything during the Site Acceptance Test (SAT); develop specialized FAT procedures intended to help reduce SAT activities; or choose one of any number of other options.
When Bristol-Myers Squibb (BMS) announced plans to construct a biologics manufacturing facility in Devens, Mass., it provided a unique opportunity for BMS engineers to put into practice some intriguing ideas they had been discussing about streamlining the entire validation process by incorporating FAT activities. A central enabler included in these discussions was the early incorporation of a manufacturing execution system (MES) into the work process.
“Validation” has many different meanings depending on the industry sector. For example, many people associate validation activities with a strict set of requirements established by the U.S. Food and Drug Administration (FDA) that apply only to the drug and health-care industry. Though those in particular industries are quite familiar with FDA validation requirements and activities, the fact is that various forms of validation exist in all industries, albeit frequently referred to by other names – “commissioning,” “verification” and “ISO 9000-certified” being among the more familiar.
Validation is closely related to quality-release testing, but is different in the sense that the latter often implies post-production verification that the product meets pre-defined specification, whereas prospective validation activities prove that the process itself produces products within specification.
Validation also dictates that a robust quality assurance plan exists, is being appropriately applied and, therefore, proves (validates) that the process will produce products within pre-defined specifications.
The significant requirements of any quality assurance (validation) effort include:
- A set of procedures that cover key business processes;
- Monitoring processes that ensure procedural effectiveness;
- Maintaining accurate, detailed records;
- Checking process outputs and applying appropriate corrective and preventative action where necessary;
- Regularly reviewing individual processes and the effectiveness of the overall quality assurance plan; and
- Facilitating continual improvement.
Once a process is running and making quality product, engineers are often reluctant to introduce new ideas, technologies or practices because of misconceptions about regulatory hurdles and/or perceived inconsistencies between systems or sites. What is odd is that those same persons often take pride in constantly refreshing their knowledge about technological advances while remaining guarded about being an early adopter.
While a cautious approach intended to protect consumers and patients is critical, today’s worldwide business environment also punishes those that procrastinate in their adoption of innovative technologies and business practices.
What we often witness is that 21st -century business successes come to those companies with a corporate culture that embraces innovative thinking. However, innovative ideas alone aren’t the whole answer. Each idea must be submitted to the securitization of reliable, risk-based management practices that can transition innovative ideas into well-organized, actionable opportunities.
Shortly after the FDA began encouraging the use of risk-based approaches to advance good manufacturing practices, BMS engineers began exploring ways to increase the use of state-of-the-art technologies and practices. Although several innovations have been successfully completed, many of the more novel and forward thinking ideas simply weren’t feasible to implement on existing processes.
When BMS announced plans to build a large-Scale cell culture (LSCC) facility in Devens, Mass., a once-in-an-engineer’s-career opportunity emerged. Employees would have the opportunity to implement an often-discussed, highly integrated, paperless plant designed to achieve:
- Highly automated and tightly integrated electronic production and laboratory batch records;
- Batch releases by exception;
- Application of a science and risk-based approach to validation;
- Implementation of an open-office environment designed to maximize collaboration within and across functional groups;
- Contributions to the company’s Sustainability 2010 Goals.
As previously mentioned, the key to turning innovative thinking into actionable opportunities is the use of sound, risk-based management practices. In the case of BMS’s LSCC facility, risk management considerations included using existing industry consensus standards such as ASTM E2500, ISA88 and ISA95.