Day-2, Session - 8.

“Water System
Commissioning & Qualification”
(30 m)

Speaker - Sumant Baukhandi, PhD

 Commissioning & Qualification
Introduction
Quality By Design
Risk Based Approach
System Qualification Documentation
System Qualification Sampling Program
Acceptance Criteria
Qualification Reports
Change Control, and
Re-qualification
 Commissioning & Qualification
Established science & engineering methods
to deliver cost effective
• Design and installation considering:
• cGMP
• Health QRM
• Safety
• Environmental EQS
• Ergonomic
QBD
• Maintenance
• Operation
• Statutory requirements
• Recognized industry guidance
 Commissioning & Qualification

• Commissioning and qualification comprise the

validation process by which a system is put into
service and demonstrated to consistently produce
water of a specified quality under various
conditions, while operated under set procedures
• Although both are typically separated within a
project schedule, they are in essence, one
continuous process
Purified Water System Skid
 Commissioning & Qualification
۩ Summary of key concepts during Commissioning
and qualification:
¤ Due to the interdependence between activities and those
involved, excellent communication, planning and
coordination between operations, engineering,
commissioning, and validation personnel will enable timely
and cost-effective project completion
¤ Each component of the system should be built in
accordance with plans and specifications and should be
inspected, tested and documented by qualified individuals.
¤ These activities, and production of supporting
documentation, are defined as Good Engineering Practice
(GEP)
 Commissioning & Qualification
۩ Summary of key concepts during Commissioning
and qualification:
 GEP recommends a minimum level of documentation
for all systems and equipment.
 This encompasses design, fabrication, vendor testing,
construction, field inspection and commissioning.
 If these documents are appropriately planned,
organized and authorized, they may become an
integral part of qualification support documentation,
thus avoiding redundancy and saving time and money
 Commissioning & Qualification
۩ Summary of key concepts during Commissioning
and qualification:
Ф Design criteria and documentation requirements
should be clearly defined early in the design phase, to
ensure clear expectations and appropriate planning
Ф The firms, vendors and contractors should be required,
per the system specifications:
Ф to provide the necessary documentation,
Ф to avoid unnecessary costs and delays associated with
obtaining or creating them
Ф these facilitate timely commissioning and validation
 Commissioning & Qualification

۩ Summary of key concepts during Commissioning

and qualification:
Ф During construction, timely review of documentation
and periodic “walk-throughs” can ensure that
Installation Qualification requirements are met
Ф Commissioning takes the system from a state of
substantial completion to a state of operation. It is the
phase of a project that includes mechanical
completion, start-up and turnover
 Commissioning & Qualification
۩ Summary of key concepts during Commissioning
and qualification:
Ф Commissioning incorporates a systematic method of testing
and documenting the system at the conclusion of
construction and prior to the completion of validation
activities
Ф Commissioning documents should not be created and
executed just for the purpose of regulatory compliance
Ф However, commissioning tests and documentation will
typically satisfy many installation and operational
qualification requirements
System Qualification & Documentation
۩ This documentation encompasses engineering,
installation & testing:
Ф A system description stating design intent
Ф A Schematic drawing (P & ID)
Ф Written system specifications
Ф Detailed design drawings
Ф Vendor manuals and drawings
Ф Field inspection & test reports
Ф System qualification test results
System Qualification & Documentation
۩ When compiling documentation, particular
attention should be paid to the following:
Ф Schematic documentation may be enhanced by the inclusion of a
system isometric diagram(s), indicating location and numbering
of welds, relative elevations, slope of lines and points of drainage
Schematic of Water System & Splg.xls
Ф The system specification should indicate performance criteria &
design parameters
Ф Field inspection & test reports should include cleaning and
passivation procedure and record weld parameter documentation
and inspection reports, slope verification and verification of the
absence of “dead-legs”
System Qualification & Documentation
System Qualification & Documentation
۩When compiling documentation particular
attention should be paid to the following:
Ф System qualification tests may or may not be a subject to a
pre-approved protocol addressing qualification test
requirements.
Ф In either case, test results should be reported in direct
comparison to acceptance criteria derived from system
design and operating specifications
Ф System qualification tests should include verification of all
automated functions, specified temperature control,
distribution system velocity and initial water quality
determination
System Qualification Sampling Program
۩ The qualification of water systems is unique in
that performance must be proven over an
extended period of time, and is subject to
variations in use rate and initial feed water
quality.
۩ Therefore, the sampling program associated
with pharmaceutical water systems validation
is unique & specialized
System Qualification Sampling Program

۩ Extensive sampling is required to establish

and confirm that the entire system will operate
within specified operating ranges:
Ω to develop and evaluate the system operation and
maintenance procedures, and
Ω to verify that the water produced and delivered to
the point-of-use consistently meets the required
quality specifications and acceptance criteria

۩ This portion of the program is sometimes termed

PQ
System Qualification Sampling Program

۩ Because of the critical impact that water has

upon pharmaceutical quality, the sampling
program and evaluation of results is usually
subject to a pre-approved plan or protocol,
with clearly defined acceptance criteria
۩ Also included should be procedures to deal
with deviations from specified parameters and
analytical results
System Qualification Sampling Program

۩ The sampling program consists of three

successive phases, each with a specific
purpose and sampling scheme, as outlined
later
۩ The initial phase of the sampling program
typically begins after the water system is
shown to be fully operational, as demonstrated
through integrated system testing in OQ
 System Qualification Sampling Program
PHASE DURATION
PRIMARY OBJECTIVES

* Develop appropriate operating ranges

Chemical Thrice
* Develop & finalize operating, cleaning, & maintenance Daily for
1 a day & Micro
procedures 2-4 weeks
once a day
* Demonstrate production and delivery of water of the
required quality

* Demonstrate consistent operation within established ranges

2 Daily 2-4 weeks
* Demonstrate consistent production and delivery of water of
the required quality
* Demonstrate extended performance
3 * Ensure that potential seasonal variations are evaluated & Weekly 1 year
treated
System Qualification Sampling Program
۩Phase I
¤ Purpose of this phase is to establish appropriate
operating ranges and provide data for the development of
cleaning & sanitization procedures & frequencies
• Sampling should be performed after each step in treatment
process & from each POU
Sampling Plan for Water System.xls
• Incoming feed water tested as per relevant drinking water
regulations
• The FDA Guide to Inspections of HPWS and WHO
Guidelines suggest daily sampling for two to four weeks, but
recognizes that other sampling programs may be acceptable
System Qualification Sampling
Program
۩ Phase I
RO Modules
¤ In devising the sampling scheme,
consideration should be given to:
 the system configuration,
 maintenance cycles,
 how the water is drawn for use, and
 the expected or potential variation in Chemistry &
microbiological attributes, at each potential
sampling point
 In treatment, chemistry testing is specific for each
processing step and microbiological testing between
each components is important to determine the
microbial load and the component’s ability to manage
the load (Component qualification)
System Qualification Sampling Program
۩ Phase I
¤ At the end of this phase, SOPs for system operation &
maintenance should be developed and approved for
continued interim use during next phase
 System logs, documentation for critical parameters (e.g.,
conductivity, TOC data, sanitization data etc) and responses
to critical alarms or action levels should be reviewed, to
verify the appropriate procedures are in place
 In addition, the process that will be followed to investigate a
confirmed test failure should be developed at this time. The
intent of this process is to assess whether a failure is
localized (i.e., isolated to a specific port) or systematic and
to define how different types of failures will be handled
System Qualification Sampling Program
۩Phase II
¤ Purpose of this phase is to demonstrate that the system
consistently operates within the predetermined
operating ranges and delivers water of the required
quality when operated in accordance with the SOPs
 If water is used through an attached hose, then the
sample should be taken from the hose
 Phase II allows the gathering of sufficient data to
establish microbial alert and action limits
Here the SOPs and the Specifications are firmed up.
System Qualification Sampling Program
۩Phase III
¤ Purpose of this phase is to demonstrate that, when
operated for an extended time period (typically one
year) the system produces and delivers water of the
required quality despite possible seasonal variations of
the feed water
 Sample locations, frequencies and test requirements are
based on the established procedures
 At the end of this phase the validation is considered
completed
 Ongoing monitoring & trending, then will establish a
continuing record of water quality
Acceptance Criteria
۩Acceptance criteria for water are dependent
upon its use:
 For Purified water & WFI, chemical acceptance criteria
can be as per USP
 It is expected that a well designed water system, operating
within specified design parameters will consistently be able
to meet these criteria
 Therefore, failures in chemical analysis during Phase 1 & 2
must be investigated, the reason for failure corrected, and
(except where errors in sampling or laboratory error are
clearly indicated) the sampling phase extended to re-
establish consistency of performance
Acceptance Criteria
۩ Acceptance criteria for water are dependent upon
its use:
 Microbial quality although described by the USP, is in fact,
established by the user based upon the water use.
• The USP does recommend action levels for the different
waters in its General Information chapter. These are 10
CFU/100mL for WFI and 100 CFU/mL for Purified water
• These may be employed as initial acceptance criteria for
system qualification, although some flexibility is allowable,
depending upon system design and use
• It is permissible that a single excursion followed by
acceptable re-sampling would not constitute a failure
Acceptance Criteria
۩Acceptance criteria for water are dependent
upon its use:
 In addition, because of the inherently bacteriostatic
nature of WFI production and distribution systems, it
should be expected that the large majority of samples
should be well below the initial acceptance criterion
• Therefore, for WFI it is prudent to establish a sample
average acceptance criterion, which will be below the limit
for a single sample
• Failure investigation would be handled similarly to
chemical analysis failure
Acceptance Criteria
۩Acceptance criteria for water are dependent
upon its use:
 During Phase 1 and 2, normal system microbial
limits may be established
 Acceptance criteria may be then converted to alert
and action levels for use during Phase 3 and
beyond
 This would take into account repeated excursions
from the norm as well as step increases in micro
count
Qualification Reports
۩Qualification data should be compiled and
conclusions written into summary report:
• Reviewed and approved by those responsible for
operation and quality assurance of the water system
• An interim report should be written and approved at such
time during the qualification sampling program, as it is
desired to use water in production activities
• A summary report should be prepared at the conclusion
of Phase 2, periodic updates provided throughout Phase 3
and a major update issued at the conclusion of Phase 3
Change Control & Re-qualification
۩ Changes to the system must be assessed with
regard to potential impact of the change on the
entire system
۩ Required action would be determined based on that
assessment
۩ It may involve extensive re-qualification, localized
increased in sampling frequency, or inclusion in
the routine monitoring program
 THANKS!
For inquiries please contact –
Sumant Baukhandi, PhD

Director – Pharma Institute of GMPs,

Director – pharmaACCESS

7, Phase-1, Vasant Vihar,

Dehradun-246 006
Uttaranchal State, INDIA

Landphone: 91-135 276 3092

Cellphone: 91- 99970 10901
Email ID: pigmpinstt@gmail.com ;
sumant091154@rediffmail.com

Website: www.pigmp.com