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VALIDATION
For medical device companies, using prerequisites translates into section. An official
less time and money spent on avoidable delays. Because the copy of the protocol
requirements for a piece of equipment or a device can vary widely is printed and the
from company to company and even between pieces of the same tester fills in results
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prerequisites that will address all potential trouble areas. Device the test section
OEMs and device-testing facilities need to understand how performed.
prerequisites fit into an equipment qualification, and need to know what should be
verified during prerequisite verifications in an equipment qualification. They should also
be able to outline a universal set of prerequisites.
Because the IQ, OQ, and PQ are performed separately, each should have its own set
of prerequisite verifications. Because the equipment requirements at each of the
qualification stages are different, the prerequisite requirements at each of the
qualification stages should be different as well.
The general goal of prerequisite testing is to ensure that items that commonly cause
execution to be delayed or repeated are in order prior to starting the qualification.
Because of variations in equipment and differences in how facilities operate, using the
exact same prerequisite verifications may not always be the best approach.
For prerequisites to significantly help streamline the qualification process, they have to
be tailored to fit the specifics of both the equipment and the facility. As a whole, it is
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Procedure Prerequisites
Training Verification
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Procedure addition to the personnel executing the protocol) have the training
prerequisite required to successfully perform the necessary tasks according to
specifications in the currently acceptable method. Additionally, the personnel
equipment executing the protocol should be similarly trained.
qualification.
Picture executing a performance qualification of an autoclave for
which the operator doesn't know how to control the equipment, and the importance of
verifying operator training becomes clear. What may not seem as clear is why it is
important to verify the training of the qualification test personnel. A medical device
manufacturer learned the importance of test personnel training during the qualification
of a freezer. The freezer qualification included a 72-hour temperature mapping, which
required monitoring and recording the temperature in different quadrants of the freezer
at specified time intervals for a three-day period. During an audit, it was discovered that
the data were not collected for the full 72 hours. An investigation concluded that the
error was due to the fact that the testers who set up the mapping were trained on an
earlier revision of the protocol and didn't realize the time interval had changed. For this
company, the small amount of time that would have been needed to execute a
prerequisite seems well worth it after being set back three or more days because of the
need to investigate and repeat the test.
Utilities Verification
Although not actually a part of the equipment, utilities are essential to its operation.
Equipment cannot run without electricity, compressed air, gas, water, etc. Utilities that
should be verified include any utility that is required to execute the protocol and has the
possibility of not being available or not being available at the required level.
An example of the benefit of performing utility verifications was seen during the
qualification of equipment designed to weld the seam of a medical device. For the
equipment to produce a successful weld, it was critical that the laser power supply
meet very specific electrical requirements. During the qualification, multiple
unsuccessful welds were observed. After a lengthy investigation, it was discovered that
the problems were caused by a variation in the electricity feeding the laser. Although
the problem was identified, the time needed to correct the problem and rerun the test
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was costly and could have been avoided had the utility qualification of the electrical
system been performed prior to starting the testing.
Instituting test instrument prerequisites is a simple way to eliminate costly delays and
misunderstandings. The items that should be tested in this section include any
instrument or piece of equipment that is required during the execution of the protocol.
Some examples of instruments or equipment that are typically verified in test
instrument verification include voltage meters, particle counters, and scales. Testing
and sampling instruments and equipment are often used by many people and often
require calibration. Typical items that benefit from prerequisite testing include the
availability or location of the instrument or equipment and its calibration status for the
expected duration of the qualification execution. Just imagine the headache it would
cause, if, when it came time to start a qualification, you realized that your scale was out
of calibration or the particle counter you ordered a month ago never arrived. Making
arrangements for calibration or tracking down an order often involves time-consuming
activities (e.g. getting approvals, contacting customer service representatives, and
tedious paperwork). Such tasks are time-consuming in general, so don't add to the
burden by waiting to do them until it's too late to resolve the issue without holding up
the qualification. Performing prerequisites allows you to address the items before they
start causing delays.
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areas to focus efforts prior to an audit instead of after an auditor has found the
problems.
Conclusion
Jennifer Medlar is a consultant for Advanced Biomedical Consulting LLC (ABC; St.
Petersburg, FL), and Nancy Cafmeyer is a project manager at the company. Contact
them at jmedlar@advancedbiomedicalconsulting.com and
cafmeyer@advancedbiomedicalconsulting.com .
Bibliography
N Cafmeyer and JM Lewis, “Process Validation Prerequisites 101,” Medical Device &
Diagnostic Industry, March 2008.
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