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Water
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1.1.1 1.1.2
Water
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Water
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Water
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Bacteria
Pseudomonas
Gram negative, non-fermenting bacteria
Escherichia coli and coliforms
Water
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Water
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Water
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distribution
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2.1. 2.3.
2.4. 2.5.
Water
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3.
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3.2.2
Water
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3.3.1.
2013
3.4.1. 3.4.3.
Water
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3.5.1 3.5.4.
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BWFI
manufacture of injectable products for dissolving or diluting substances or
preparations during the manufacturing of parenterals
manufacture of sterile water for preparation of injections
final rinse after cleaning of equipment and components
preparation of steam
4.3. 4.5.
Water
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Water
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HPW
Potable water
2013
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Part 2
Water purification,
storage and
distribution
Water
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Water
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Water
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Water
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sanitization method
the reliability and robustness of the water-treatment equipment in
operation
the yield or efficiency of the purification system
the ability to adequately support and maintain the water
purification equipment
the continuity of operational usage considering hours/days, days/
years and planned downtime
5.1.1 5.1.2.
the total life-cycle costs
Water
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5.1.3
Water
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Water
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float
operated
valve
sand filter
spray ball
Water is kept
circulating
raw water in
centrifugal pump
S trap to sewer
|
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To water
softener &
DI plant
break tank
Water
activated
carbon
filter
cartridge
filter
5 micrometers
Water
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brine
"hard" water
in
drain
Water
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Water
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5.2.6. 5.2.8.
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raw water
drain or recycle
Purified water
Permeate
water
Water
under
pressure
Reject
water
Feed
water
Semi-permeable
membrane
Low pressure
High pressure
5.3.1.
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5.3.3
Water
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5.4.1. 5.4.2
Water
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Second stage reject water goes back to first stage buffer tank
1st stage reject concentrate
Branch
Branch
High pressure
pump
Second stage RO water
meets Pharmacopoeia
standards
Water
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Cartridge
filter 1 m
Hygienic pump
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5.5.1. 5.5.3
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Water
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Feed Water
from
DI or RO
Cartridge
filter 1 m
Water must
be kept
circulating
Spray ball
Optional
in-line filter
0,2 m
UV light
Outlets
Heat Exchanger
Ozone Generator
Water
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Hygienic pump
Air break
to drain
Water
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Water
pipework
valves and fittings
seals
diaphragms and
Instruments
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6.2.1. 6.2.2.
Prevention of leaching
Corrosion resistance
Smooth internal finishing
Jointing
Unions and valves
Water
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6.2.2.
Prevention of leaching
Non leaching operation and sanitization
Corrosion resistance
SS316L, cleaning and passivation
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6.2
Materials
E.g. SS316L, polypropylene, PVDF
Water
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6.2
Water
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Storage Vessel
Considerations
and
components
Water
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Water
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(NMT 3D)
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6.5.4.2
Water
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Water
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Dead leg:
Measured from the ID pipe
wall to centre line of the
point-of-use valve where
significant stagnation
potential exists
Water
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Sanitary Valve
Water scours dead leg
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6.5.4.2.
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7.
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7.2
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7.2
Water
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7.2
7.2
Water
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7.3.1. 7.3.3.
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Water
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7.5.1.
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Inspection of water
purification systems
WHO Technical Report Series
No 970, 2012. Annex 2
Water
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I start with:
As much as I learn, as
much as I dont know
Water
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Chapter 1
Introducti
on
Water
Chapter 2
Key Design
Philosophi
es
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Chapter 3
Water
Options and
System
Planning
Chapter 5
Final
Treatment
Options: NonCompendial &
Compendial
Purified
Water
Chapter 6
Final
Treatment
Options:
Water For
Injection
(WFI) 7
Chapter
Pharmaceutic
al Steam
Chapter 8
Storage and
Distribution
Systems
Chapter 9
Instrumentati
on & Control
Chapter 10
Commissionin
g and
Qualification
Chapter 11
Appendix
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Water
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Water
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Water
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8.
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Water
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Water
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Water
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Water
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Water
dead legs
filters
pipes and fittings
Ionic beds
storage tanks
by-pass lines
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Water
pumps
UV lights
sample points
reverse osmosis
valves
heat exchangers
Instruments, controls, gauges, etc.
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Water
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Water
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Staining on
water storage
tanks
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Water
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testing
Sterilization
and replacement
frequency
Check
Water
burst discs
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Water
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Water
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Target
200
Alert
Action
300
500
100
300
500
Post softener
100
300
500
50
300
500
20
200
500
RO permeate
10
50
100
Points of Use
10
100
Raw water
Water
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IN C O R R E C T W A T E R T R E A T M E N T PL A N T
Water
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M O D IF IE D W A T E R T R E A T M E N T PL A N T
Water
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Water
1.
Integrity test for vent filter of PW storage tanks and WFI storage tanks have been done
(total 4 storage tanks), but it can not be ensured the link and match of the filter integrity
report against the filter/housing filter itself. No ID filter/housing on integrity report
2.
Vent filter handling is stated on doc SOP ENG-UT/MSO/LS/032, It is not mentioned whether the
integrity tested filter (with pass integrity test status) will be re-used for the next certain period or
replaced with the new one.
If it is prolong used, the cycle of usage should be identified, controlled, justified and documented
3.
Integrity test of vent filter is executed for every 6 months, last testing was June 2014.
There is no test integrity record for Jan 2014 (the previous 6 month prior to June 14)
4.
Integrity test report of vent filter is complied with singles page. It is not attached in proper form,
so the potential to page missing.
There is no approval from checker, just approved by single operator. Double approved Quality
team (QA) is really recommended since this is product quality direct impact
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6.
The monitoring time for recording 10 micron filter in DRW installation is not mentioned. SOP ENG15/MSO/LS/026
7.
8.
Water
Documentation of Monitoring system of DRW filter is not equipped by acceptance criteria so that
operator know whether it is meet spec or OOS.
Marking of acceptance criteria pressure on Magnehelic is not in place
Some piping direction was found in Blur condition, can not see clearly
The pressure monitoring of DRW Filter 08/DRW-F-234 was OUT OF ORDER STATUS. Out of order
label was in place, but its filtration system was still used for filtering process as feed water to PW
generator
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10.
11.
Alert limit or action limit of PW quality (etc: conductivity) is not conected to proper sound/light alarm to
Room supervisor or out side area of water system room
12.
All calibration labels including probe sensor, display, pressure transmitter, temperature sensor of PW
Generator/Christ Osmotron are over due
13.
Challenge of password level authorization on PW Generator Osmotron was done during observation. It
didnt represent any pass world level in place. All people during inspection can enter osmotron PLC
system using the same password. While the SOP has already been available
14.
SOP of cool loop sanitation has been available, defined frequency is every 3 months using Hydrogen
peroxide.
The record of the last 3 months has not yet shown to the auditor.
The evidence of residual H2O2 is not documented
Water
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10.
11.
Alert limit or action limit of PW quality (etc: conductivity) is not conected to proper sound/light alarm to
Room supervisor or out side area of water system room
12.
All calibration labels including probe sensor, display, pressure transmitter, temperature sensor of PW
Generator/Christ Osmotron are over due
13.
Challenge of password level authorization on PW Generator Osmotron was done during observation. It
didnt represent any pass world level in place. All people during inspection can enter osmotron PLC
system using the same password. While the SOP has already been available
14.
SOP of cool loop sanitation has been available, defined frequency is every 3 months using Hydrogen
peroxide.
The record of the last 3 months has not yet shown to the auditor.
The evidence of residual H2O2 is not documented
Water
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Water
15.
16.
17.
Period 1-14 Oct 14, record of UV intensity meter is OOS (just reached 6%).
There is no documented DVR/investigation/similar adequate doc provided.
Request more info: need to investigate whether any RISK assessment in place in respect to product quality
since the UV is DIRECT impact CPP controlled device to eliminating Ozon
18.
Challenge test to control performance of AUTHOMATIC TLV Valve placed in production (user point) during
OZON process process is not in place
The related risk assessment in respect to any unperformed AUTHOMATIC TLV is not provided.
The qualification just done on annual basis. There is no guaranty for months before re-qualification
19.
Acceptance CRITERIA of Ozon concentration prior to be used by production has not established yet
20.
There is no record for ensuring of OZONE contacted time is not less than 3 hours as per required by SOP ENGUT/MSO/LS/009.
It is recommended to develop study for effective OZONE contacted time
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21.
Sampling point no. 17 is not equipped by proper sampling valve, the position of sampling
point is not within looping system which represent PW looping condition
22.
Probe conductivity of multi steel water for producing WFI was not calibrated
23.
Recommendation:
The velocity of PW distribution is not in line with HAS and Local FDA requirements. 3000 liter/hours is
not enough for providing turbulence flow during distribution.
A risk assessment needs to be develop if the manufacturer still used their own spec
Water
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The timing for introducing concentrated chlorination solution has not defined yet (SOP ENG UT/SOP/PM/030. This
condition has to describe chlorine concentration, initial tank condition before adding the concentrated chlorine in
respect to target dose since there is no testing of residual chlorine after treatment of chlorination itself
Daily monitoring of industrial RO unit is not equipped by acceptance criteria so that conclusion (pass/fail) of that monitoring
cannot be taken. It is important data for taking further improvement. This unit is belong Darmawans control
The usage of 20 microns filters can not be traced back since there is no documented link data due to details profile of used
filter such batch no, lot no, type and other related info since there is no testing of incoming filter, CoA is just used for filter
quality justification
1.
5
Water
2.
SOP ENG UT/SOP/PM/026, monitoring of DRW filter 20 microns filters, 12/1 2014 has 0,2 Pa while the acceptance
requirements is 0,3 pa
There is no appropriate column for describing P on before and after filtration (DRW) so that the operators calculate by
themselves without proper documentation. The record of individual filter is in place
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There are no measurement devices to ensure the filtration performance of 1 filters. So on that reason, there is no
performance monitoring record of that particular filters
The frequency of filter changes are also not defined impacted by above reasons
10
Water
There is no in place technique to check the turbulence of PW inside of distribution piping. The appropriate flow meter is not in
place
Alert limit and action limit of conductivity are in place but the operator can change such water CQAs and CPPs without getting
authorization from related manager. Password management needs to re-change the password and re-training
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Water
11
The cold loop report ENG- UT/FOR/PM/026 has not yet approved by QA but the PW itself has been distributed into
production area.
QA approved is required as per established SOP since this is CRITICAL step which needs quality people decision.
The related form has been established
12
Challenge test of main distribution valve after cold sanitation is not in place. There is no adequate system to ensure that the
valve is always working properly while its valve is not equipped by the periodic qualification.
13
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Water
14
The sequence of QC sampling time and PW distribution sanitation time is not representing worst case condition,
since it is only show the best case condition. QC sampling is in Tuesday while sanitation is Sunday
15
Ozone meter for checking residual ozone is not in place, but the operator use other system for ensuring there is not residual
ozone inside of PW. After ozonization, the PW is drained, but there is no record & evidence in place for ensuring that the PW
tank is empty before refill the new PW
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Water
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