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How We Improved Purified Water System Monitoring with TOC Trending and Risk-Based Controls

In a consulting project with a South American pharmaceutical manufacturer, Zamann Pharma Support was asked to help validate a new Purified Water (PW) system. Although the equipment was reliable and the vendor qualified, the project lacked a solid risk assessment.

Critical parameters had no clear justification, and worst-case conditions remained unchallenged. Consequently, the project required a major reassessment, delaying validation by months and increasing costs.

Our team assessed the validation strategy, identified critical gaps, and highlighted the need for stronger risk-based controls.

Challenges Faced

A detailed GAP analysis in Quality Management Systems is essential for identifying process deficiencies effectively.
  • Insufficient Risk Assessment: The project lacked a sound risk assessment to justify critical PW validation decisions.
  • Unjustified Validation Parameters: Critical parameters lacked scientific justification, particularly microbial limits and Total Organic Carbon (TOC) values.
  • Unchallenged Worst-Case Conditions: The team had not adequately tested or documented worst-case operating conditions, weakening the validation evidence.
  • Missing Flow Velocity Justification: The project lacked a documented flow velocity rationale, including the cited 1 m/s example for biofilm prevention.
  • No Lifecycle Validation Strategy: The project focused on qualification documents without a clear strategy for ongoing risk evaluation.

Zamann Pharma Support’s Approach

  • Define a Risk-Based Validation Strategy: Establish a Risk-Based Validation Strategy (RBVS) with scientifically justified parameters and documented risk decisions.
  • Establish Validation Traceability: Ensure that user requirements, risk assessments, test plans, and Performance Qualification (PQ) activities are clearly connected and supported by documented evidence.
  • Challenge Worst-Case Conditions: Test critical operating conditions and document justifications for microbial limits, TOC values, and flow velocity.
  • Strengthen Risk-Based Documentation: Document the scientific rationale behind critical validation decisions before equipment validation begins.
  •  Plan Risk-Based Periodic Reviews: Include risk reassessment in periodic reviews to support the system’s validation lifecycle.
  • Quick PW Validation Self-Assessment:Check acceptance criteria, worst-case testing, PQ alignment, flow velocity, microbial limits, and periodic risk reviews. EU GMP Annex 15, ICH Q9, ISPE, and FDA guidance support risk-based validation.

Results Achieved

  • Critical Validation Gaps Identified: Our team identified weaknesses in risk assessment, parameter justification, worst-case testing, and lifecycle planning.
  • Major System Reassessment Required: The findings led to a major reassessment of the Purified Water system.
  • Validation Delayed by Months: Consequently, the reassessment delayed validation by months and increased project costs.
  • Need for a Stronger Validation Strategy Established: The assessment highlighted the need to connect risk evaluation, qualification activities, and lifecycle reviews.
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GMP qualification and lifecycle validation activities including IQ, OQ, and PQ supporting inspection readiness in pharmaceutical manufacturing.
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Qualification and Validation for GMP Systems

Our team supports the planning, execution, and maintenance of qualification and validation activities, including IQ, OQ, and PQ, to keep GMP-regulated systems compliant and under control.

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FAQ

1. How should microbial limits and TOC acceptance criteria be justified during PW validation?

Microbial limits and TOC acceptance criteria require documented scientific justification. The assessment should consider applicable pharmacopoeial requirements and connect the selected parameters to the PW system’s risk assessment. In this case, missing justifications contributed to the need for reassessment.

2. Why is worst-case testing important during Purified Water system performance qualification?

Worst-case testing challenges the operating conditions considered critical to the PW validation strategy. It helps demonstrate whether qualification evidence supports the selected conditions and acceptance criteria. In this case, the team had not adequately challenged worst-case conditions, weakening the validation approach.

3. What risk assessment gaps can cause delays in PW system qualification?

Missing parameter justifications, inadequate worst-case evaluation, undocumented flow velocity rationale, and weak lifecycle planning can undermine a PW validation strategy. In this case, these weaknesses led to a major system reassessment, delaying validation by months and increasing costs.