New EU GMP Annex 15 Revision Published
In February 2014 the draft for the revision of EU GMP Annex 15 was published (see the GMP-News from 11 February 2014 “Revision of the EU GMP Annex 15 for Qualification and Validation published“). Compared with the currently valid version the changes were significant in some parts (see also the GMP-News from 21 March 2014 “Detailed Analysis of Annex 15 Draft“. Now the draft was published as final document and will be valid as of 1 October 2015.
The options with regard to process validation have been extended. The previous “traditional” approach is still mentioned as a possibility, though – also with the determination of 3 validation batches. For a 3 batch validation further data from following batches may be necessary according to an “ongoing process verification”. The possibility of a “continuous process verification” as described in ICH Q8, and a hybrid approach as a mix of the before mentioned two approaches is new. This is a clear difference to the US FDA Process Validation Guidance where only one approach is mentioned. According to the final EU GMP Annex 15 a “bracketing” approach can be used with respect to the number of runs, strength, batch size, packaging sizes and types. This is already known from the US.
As part of the “ongoing process verification” the product quality should be monitored during the product life cycle to show that the “state of control” is fulfilled and that trends are assessed. This is also known as “Continued Process Verification” from the US. The “ongoing process verification” should be based and reported according to a protocol or equivalent documents, latter is new compared to the draft. Completely omitted has been the subject of a (regular) revalidation.
The chapters “Transport Verification”, “Packaging Validation” and “Qualification of Utilities” as well as a separate chapter on “Validation of Analytical Methods” are new. Compared to the draft the new final document now addresses also the qualification of equipment for secondary packaging.