Tuesday, 13 December 2016

Procedure for Change control

1.0
PURPOSE
To lay down a procedure for monitoring & control of the initiation, review, approval & implementation of technical changes in operating procedures, specifications, manufacturing process, analytical testing methods, equipment, and utilities and operating environment.

2.0
SCOPE
This procedure is applicable to the to all the changes, which may affect the manufacturing process, formula, facility, equipment layouts, equipment design / systems & procedures (test procedures etc.), specifications. These changes may be implemented due to process, product, customer requirements Or replacement of change parts of an equipment.

3.0
RESPONSIBILITY
Section In-Charge
4.0
ACCOUNTABILITY
Head QA
5.0
PROCEDURE

5.1


5.2














5.3


5.4


5.5

5.5.1

5.5.2

5.5.3

5.5.4



5.6

5.6.1



5.6.2


5.6.3

5.6.4

5.7

5.7.1


5.7.2

5.7.3

5.8

5.8.1


5.8.2









5.8.3


5.8.4


5.8.5




5.8.6



5.9

5.9.1

5.9.2


5.9.3

5.10

5.10.1


5.10.2


5.10.3


5.10.4


5.11

5.11.1
For all the changes, prior approval shall be taken from QA (through the Change Control Procedure), before implementation.

Typical changes, which must follow change control procedure, are given below. Any other changes, which are critical in nature or can have direct impact on the product quality, shall also follow change control procedure.

  • Master formula / Batch processing & control records.
  • Manufacturing equipment / Utility equipments / Engineering equipment.
  • Manufacturing Site / location.
  • Manufacturing process / process control parameters.
  • Raw Material specifications & Finished Product specifications and all the standard test procedures.
  • Modification in Water system / HVAC system / Compressed air system
  • In-process specifications / Intermediates specifications / finished product specification / Method of Analysis. Warehousing / distribution procedures (for raw material / packing material / finished goods, requiring special conditions for storage and handling).
  • Personnel & Administration: Any changes in system.
Initiator who has to propose the change shall approach to Head – QA for issuance of change control form as attached as per Annexure –II.

The QA officer / executive shall allocate a unique sequential number to each CCF and maintain a logbook including approved as well as rejected change control requests as per Attachment-1.

The CCIF number shall consist of 10 alphanumerical characters e.g. “CC-YYY-MM-001”.

The first two alphabetical characters “CC” shall indicate “Change control form”.

The Third,fourth, character shall always be ‘Year-‘012 for the year 2012.

The next two numerical characters shall indicate the month e.g. ’01, 02, 03…..12’ .

The last 3 numerical characters represent the unique sequential serial number for the form documented, Starting from 001, 002, 003 …… 999. In every month serial number again start from 001.eg. January 01….008, February 02…..008.

Initiation of ‘Change Control Initiation Form’:

The concerned departmental officer / executive / Head shall initiate , by documenting the changes control form in any of the manufacturing procedures, specifications, manufacturing process / batch formula, analytical testing methods, equipment, utilities and operating environment.

The initiator shall record the justification for the proposed changes. All the relevant data documents, which support the proposed changes, shall be attached along-with the form.

All the attached data shall be enclosed in the form of Annexures II.

All the attachments shall be reviewed & checked by, by the initiating department.

Review of CCIF:

The CCIF shall be reviewed by department head / Tech. Director, for necessity / feasibility of the changes proposed, justification given along with the attachments, and signed off in CCF.

The CCF Shall be reviewed by EHS Deptt for safty concern.

The completed CCF shall be forwarded to the QA department for approval, prior to the implementation.

 Approval of change control initiation form: The Head-QA / Nominee.

The proposed changes shall be classified by Head-QA / Nominee, into following three categories, depending upon their impact on the product quality.

QA shall review the change control with respect to impact on product quality, necessity/ feasibility of the changes proposed, rationale / justification of the change &  compliance to cGMP along with the adequacy of the supporting data attached.

(a) Minor change  - A change that does not have any impact on the quality of the product  and operating
                                  system.
(b)Moderate change  - A change that is likely to have an impact on the quality of the product,  but does not
                                       make any significant change in the final quality of the product.
 (c) Major change - A change that has a significant impact on quality and / or safety of the final product.

Head-QA shall evaluate the CCF for the impact on the quality of the product and shall recommend any additional studies to be carried out (if required), during implementation of change.

 QA may also recommend additional training, to be given to the personnel involved, in case of changes in critical procedures.

In case of a change pertaining to the product manufactured for specific customer on contract  basis, prior approval for this change shall be taken from the customer, by sending  notification of the proposed change (with justification) and the proposed data shall be generated to support evaluation of the change. Upon receipt of acceptability from the customer, the change shall be implemented.

Head-QA shall approve the CCF, for implementation, after satisfying himself that the proposed change shall not have any adverse impact on the product quality / cGMP compliance / regulatory compliance, and that all the necessary supporting data, for justification of the changes, has been attached.

Implementation of Change:

The changes shall be implemented by initiating department, after approval of the CCF.

During implementation of the changes, necessary studies shall be carried out & data shall be collected, as recommended in the CCF.

The data generated shall be compiled by the initiating department and forwarded to QA.

Closure of CCF :

The closure of the change control initiation form shall be responsibility of the Initiator dept. head & QA head.
QA shall verify whether the recommendations made in the CCF, have been implemented.

The operating Head / Head QA shall together review the data generated during the implementation of the change control.

Finally, head-QA shall sign the closure of the CCF. The closure of the CCF shall also be recorded in the CC logbook.

The documents, which are effected by the implementation of the change control, shall be reviewed / updated, as per the requirement.

Archival of Change control forms:

After approval of a change control proposal, the Change control form shall be stored / archived in QA department, systematically.

6.0
REFERENCES     
SOP guideline by  D.H. Shah
cGMP Guideline




                                                                                                                                  


7.0
ANNEXURES

Annexure No.
Title of Annexure
Format No.
Annexure I
CHANGE CONTROL LOG BOOK
QA/019/F01-00
Annexure II
CHANGE CONTROL FORM
QA/019/F02-00


8.0
ABBREVIATIONS
Abbreviations
Full Forms
SOP
Standard Operating Procedure
QA
Quality Assurance
CCF
Change control form
EHS
Environment Health Safety
9.0
DISTRIBUTION
Master Copy
Head Quality Assurance Department

Controlled office Copy No. 1
Head Quality Assurance Deptt.

Controlled office Copy No. 3
Head Production (Tablet) Deptt.

Controlled office Copy No. 4
Head Production (Liquid) Deptt

Controlled office Copy No. 5
Head Production (External) Deptt

Controlled office Copy No. 6
Head Production (Soap) Deptt

Controlled office Copy No. 8
Head Store  Dept.(Main Block)

Controlled office Copy No. 10
Head Engineering Dept.

Controlled office Copy No. 11
Head Store  Dept.(External Block)

Controlled office Copy No. 12
EHS Head

10.0
REVISION HISTORY
S.No.
Revision No.
Effective Date
Reason for Revision
Details of Change
Authorized By
(sign & Date)
1
















                                                               















Annexure I
CHANGE CONTROL LOG BOOK
Date
Change Control No
Initiated By& Department
Details of Change Control
Approved/
Rejected
Approved By/On
Closeout of Change Control
Remark



.





















































































































































Annexure II
CHANGE CONTROL FORM
1.0 Change Initiation
Change Control Form No. CCIF-___________                 Date: ---------------
1.1
Sign &Date of Requestor
(Department)

1.2
Market
Domestic                            Export
If Export Country / Customer Name:
1.3
Change related to:
BMR         Specifications         STP          SOP         MOA                                 
Equipment Design / Configuration                   Analytical method                      
Others  (give details)
1.4
Existing Procedure


1.5
Proposed
Change Details:

1.6
Justification / Rationale for Change:


1.7
Enclosure (s)
1.
2.
3.

1.8
Initiated By/Date

Checked By/Date
Concern Dept. Head
1.9
Attachments / Supporting Data ( If Applicable)




2.0 Evaluation & Assessment of Change proposal by QA________________________________
__________________________________________________________________________________________________________________________________________________________________
2.1 Can the Change be made Permanent:     Yes              No
3.0 Category of Change: Minor        Major        Moderate       Permanent        Temprovery                   
3.2     Any validation / Qualification Documents Affected   :         Yes             No
          Any Process Affected                                                   :        Yes             No
          Any SOP   Affected                                                      :        Yes             No
          Any System Affected                                                    :        Yes            No
          Any Equipment   Affected                                           :         Yes            No
        Sign & date:   
                                                                          
        Head QA                                                                              
3.3 Training Required:  Yes / No
3.4 Training conducted on:
3.5 Comments from Head of allconcern departments including EHS Deptt. which are likely be   
       Affected by the proposed Change & whether the change is acceptable or not.

Department
Comments & change accepted-
Yes/No



Sign/Date
Designation


Sign/Date
Designation
·         If change not accepted, then discuss the reason thereof with concerned department for not agreeing with the change & inform the requester.
4.0       Implementation of Change:



4.1       Change Control Implemented By:
Implemented By Department Head
Name
Signature
Date




4.2 Observations (if any)
4.3 Quality Profile of batches affected (if applicable):
4.4 Specify if subsequent changes required in
     a) Documentation
     b)Training/retraining
     c) Stability testing/Revalidation
4.5 Proposed Change informed to concern Departments:
 Department
Designation
Sign/Date






5.0   QA Review of Implementation & Closure:
____________________________________________________________________________________________________________________________________________________________________
5.1 All recommendations fulfilled:       Yes             No
5.2 If No, Justification: _____________________________________________________________________
__________________________________________________________________________________

5.3    If No: Has the Change been reviewed      Yes            No                           
Closure Approved By User Department Head
Name
Signature
Date




Closure Approved By Head-QA






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