Agilent Technologies, Inc. · NYSE:A

Agilent Technologies — Technical Presentation (2016)

31 slides from Agilent Technologies's technical presentation, 2016

  1. Slide 1: Lessons from Pharmaceutical Laboratory related FDA Warning Letters

    Lessons from Pharmaceutical Laboratory related FDA Warning Letters The Agilent Critical Compliance Seminar 2016 Ludwig Huber Ludwig_huber@labcompliance.com

  2. Slide 2: Overview

    Overview • FDA Inspections and reports • GMP compliance along the sample and data workflow • Recent FDA warning letters & 483s and recommendations how to avoid FDA warning letters related to – Requirements for quality systems – Requirements for workflow steps • Responding to Warning Letters and 483’

  3. Slide 3: FDA Inspection Documentation

    FDA Inspection Documentation • 483 Form Inspection Observation – only deviations listed – written for inspection exit meeting • Establishment Inspection Report (EIR) – very detailed (20-40 pages) – more like an inspection protocol • Warning letter – With significant deviations – Reviewed by FDA cent

  4. Slide 4: What about Europe

    What about Europe • EMA launched new version of the EudraGMDP website • Incudes statements of non-compliance with GMP and positive GMP certificates • Information includes company name, location, issue date, nature of no-compliance and the action taken by issuing authority in order to protect public

  5. Slide 5: Example from EudraGMDP Website

    Example from EudraGMDP Website Issue Date March 21 2014 Company and location Nature of non-compliance : It was not possible to confirm the validity of stability testing data. Several falsified and inaccurate results had been reported in long term stability and batch testing. Discrepancies between el

  6. Slide 6: Typical Warning Letter Statement

    Typical Warning Letter Statement • Within fifteen working days of receipt of this letter, please notify this office in writing of the specific steps that you have taken to correct violations. • Include an explanation of each step taken to prevent the recurrence of violations and copies of supporting

  7. Slide 7: Missing Roles and Responsibilities

    Missing Roles and Responsibilities • Deviation Data security protocols are not established that describe the user's roles and responsibilities in terms of privileges to access, change, modify, create, and delete projects and data (242) • Root Cause (assumed) The company was not aware that user roles

  8. Slide 8: Compliance across the GMP Lab

    Compliance across the GMP Lab Trace forward Trace backward Sample Record Sampling Testing Test reports handling maintenance Sampling plan & Sample Monitoring the Test conditions Ensure representative identification & quality of test & test results, data record sampling, statistics protection of resu

  9. Slide 9: Poor Quality System

    Poor Quality System • It is apparent that you have not implemented a robust quality system at your firm. • Be advised that corporate management is responsible for ensuring the quality, safety, and integrity of drugs • FDA strongly recommends that your corporate management immediately undertake a com

  10. Slide 10: No on-going GMP Training

    No on-going GMP Training • Our review of your firm's training program disclosed that there was no requirement for on-going CGMP training of employees. • The firm only had an initial CGMP training and did not provide regular CGMP training to all employees involved in the manufacture of drug products.

  11. Slide 11: No Supplier Quality Agreement

    No Supplier Quality Agreement • Failure to establish and maintain the requirements, including quality requirements that must be met by suppliers. • For example, your firm has not specified quality requirements for suppliers, maintained lists of approved suppliers and developed written procedures des

  12. Slide 12: Method Validation

    Method Validation • The accuracy, sensitivity, specificity, and reproducibility of test methods have not been established and documented (W-187) The FDA frequently mentions these four parameters as the only required validation parameters, They are listed in CFR 211 but not sufficient. You need to do

  13. Slide 13: Compendial Methods not Verified

    Compendial Methods not Verified • Method verifications for compendial tests are not performed. Any method, including compendial methods, must be verified as suitable under actual conditions of use (W-274).  Demonstrate that your laboratory is suitable to run compendial methods under actual conditio

  14. Slide 14: No Formal Method Transfer

    No Formal Method Transfer • The firm failed to determine the acceptability of ten methods prior to using them in the QC laboratory through formal method transfer procedures (282) • Methods that were validated at one facility and transferred to xxx site are being used without a methods transfer or re

  15. Slide 15: No Equipment Qualification Program

    No Equipment Qualification Program • The calibration procedure for HPLC systems is inadequate in that it did not include the detector’s linearity, injector’s reproducibility, and accuracy of temperature settings for the column heater (W-097) • Failure to have an adequate qualification (calibration)

  16. Slide 16: No Failure Investigations for failed Calibrations

    No Failure Investigations for failed Calibrations • There was no documentation that an investigation was conducted to determine the root cause of the failed calibrations of the Gas Chromatograph. • In addition, your firm failed to implement adequate corrective action to prevent re-occurrence..(W-240

  17. Slide 17: No Computer Validation at the Users Site

    No Computer Validation at the Users Site • During the inspection, I asked if the computer software has been validation to assure that it performs for it's intended use. • I was told that the software was validated by the manufacturer. The managing director provided me a copy of the letter the receiv

  18. Slide 18: Excel Spreadsheets not Validated and Controlled

    Excel Spreadsheets not Validated and Controlled • The calculation for residual solvent uses an Excel spreadsheet that has not been qualified. We are concerned about the data generated by your QC laboratory from non- qualified and uncontrolled spreadsheets • The use of the Excel® spreadsheets in anal

  19. Slide 19: Inadequate System Suitability Testing

    Inadequate System Suitability Testing • Methods do not include system suitability tests to ensure that the system is operating properly (W-162) • No System Suitability performance before running testing (132) • The SOP requirement for the assay analysis of xxx was not followed in that the HPLC syste

  20. Slide 20: No SOP for Inadequate Handling of Out-of-Trend Results

    No SOP for Inadequate Handling of Out-of-Trend Results • There is no standard operating procedure in place that describes the steps to be followed during an Out-of-Trend (OOT) Investigation • Besides, the "OOT Investigation" performed was inadequate. (W-241) 1. Study requirements for handling OOT re

  21. Slide 21: Examples for Data Integrity Issues

    Examples for Data Integrity Issues FDA Observations • Failure to maintain complete data derived from all lab tests • Failure to record activities at the time they are performed • Not reporting failing results • Conducting unofficial testing (trial injections) • Disabling electronic audit trails, una

  22. Slide 22: No Procedure for Chromatographic Peak Integration and Re-integration

    No Procedure for Chromatographic Peak Integration and Re-integration • The inspector documented that HPLC processing methods (including integration parameters) and re-integrations are executed without a pre-defined, scientifically valid procedure • A QC operator interviewed during the inspection sta

  23. Slide 23: Trial Sample Injections not Recorded

    Trial Sample Injections not Recorded • Our investigators identified your practice of performing trial sample injections for HPLC analyses. • For example, trial injections of stability samples were acquired in the “Test” folder prior to official testing. Immediately after the trial injections were co

  24. Slide 24: Incomplete Raw Data

    Incomplete Raw Data • Your Quality Unit failed to provide all spectra and raw data associated to the reports. (W-248) • The laboratory records do not include raw data to support the evidence of sample preparation, standards preparation and did not include a statement of the weight or measure of the

  25. Slide 25: Electronic Raw Data not Saved

    Electronic Raw Data not Saved • Operating parameters of the spectroscopy system were maintained with the relevant test records. However, electronic raw data was not saved (W-167). 21 CFR Part 211: (e) requires that complete records shall be maintained of all stability testing performed in accordance

  26. Slide 26: Missing Audit Trail

    Missing Audit Trail • Data stored on the computer can be deleted, removed, transferred, renamed or altered (W-209) • There is no audit trail or log of data changes that are made to the information in the database. (W-224) Develop procedural and technical controls to ensure electronic audit trail  I

  27. Slide 27: Electronic Audit Trail not Reviewed

    Electronic Audit Trail not Reviewed • Your firm's review of laboratory data does not include a review of an audit trail or revision history to determine if unapproved changes have been made.. (W-229) Develop a procedure for reviewing electronic audit trail  Inform you laboratory staff that audit tr

  28. Slide 28: Manipulation of Printed Raw Data

    Manipulation of Printed Raw Data • Your firm's laboratory analyst had modified printed raw data related to the IR Spectra test • Your quality control unit failed to detect that IR spectra were being substituted by a laboratory employee and detect the manipulation or alteration of laboratory document

  29. Slide 29: No Access to Information During Inspection

    No Access to Information During Inspection • During the inspection, an analyst removed a USB thumb drive from a computer controlling an HPLC. When asked to provide the drive, the analyst instead exited the room with the thumb drive. • After approximately 15 minutes, management provided our investiga

  30. Slide 30: Responding to Inspection Deviations

    Responding to Inspection Deviations • Fully understand the content of each deviation in the exit meeting • Respond in time (15 days for FDA Warning Letters and 483s) • Address each item separately in the response • Start with a statement that you understand and accept the deviation • If some deviati

  31. Slide 31: Resources

    Resources www.labcompliance.com/agilent (available until April 30, 2016) • Agilent Primers – Analytical Instrument Qualification and System Validation – Understanding and Implementing ISO/IEC 17025 – Compliance for BioPharmaceutical Laboratories Version 2 (2015) – Compliance by Design“ for Quality C

Agilent Technologies — Technical Presentation (2016) on 6ix