Packaging Performance Qualification—A Risk-Based
Transcription
Packaging Performance Qualification—A Risk-Based
PEER-R EV IEW ED Packaging Performance Qualification—A Risk-Based Approach Steen Howaldt Christiansen and Jesper Bønnelycke Torp Jensen ABSTRACT This paper describes a risk-based performance qualification (PQ) concept exclusively based on the fundamental requirements. The result is a cookbook describing a general methodology for deciding the size and number of PQ runs needed. The fundamental philosophy is that PQ must simulate normal production, including the challenges typically seen in that connection. Consequently, the actions and interventions arising in normal production contexts are tested rather than a set of specific machine parameters. The methodology description is intended to be operational. This paper focuses on packaging performance qualification as an example, but in practice the concept can be introduced for all mechanical processes because the process characteristics are all similar. In the longer term, this methodology will be proposed as “Annex C” to the Global Harmonization Task Force’s (GHTF) Quality Management Systems–Process Validation Guidance (1). INTRODUCTION Since the first US Food and Drug Administration requirements for validating pharmaceutical processes appeared back in the 1980s (2), and especially in recent years, validation seems to have become more and more of a scientific discipline in itself. Books have been written, magazines and articles have been published, courses have been held, and an army of consultants have offered their expertise to pharmaceutical companies. For more Author information, go to gxpandjvt.com/bios Often the approach has entailed philosophical considerations of the more or less concrete statements published by the authorities. These considerations always result in statements such as “It is up to you or your company to decide” or “You have to develop the rationale for doing things ... and you are the one who knows the process.” These statements provoke a similar response from “hands on” people: “Yes, we do want to establish documented evidence that provides a high degree of assurance that a specific process will constantly produce a product that meets its predetermined specifications and quality attributes (2), but how do we do it at the operational level?” The same scenario has been evident in numerous companies. Standard operating procedures (SOPs) dealing with validation have become more and more philosophical, moving away from the operational approach. And as the pharmaceutical companies learned the lessons through the 1990s and accepted “validation” as part of the everyday business, the routine solutions became more and more complex and full of rationales for fulfilling unclear requirements. To close the gap between the philosophical considerations and the operational performance of validation, the GHTF published its process validation guidance back in 1999 (ed. 1) and 2004 (ed. 2) (1). This guideline answered a lot of the questions, but it also left a few unanswered, such as the following: •W hat is the minimum performance quali- fication (PQ) batch size for assembly and [ gxpandjv t.com ABOUT THE AUTHORS Steen Howaldt Christiansen is a project manager at Novo Nordisk A/S Denmark—Diabetes Finished Products/Manufacturing Development/Finished Products. He can be reached by e-mail at [email protected]. Jesper Bønnelycke Torp Jensen is an engineer at Novo Nordisk A/S Denmark—Diabetes Finished Products/Manufacturing Development/Finished Products. He can be reached by e-mail at [email protected]. Journal of Validation T echnology [Spring 2009] 77 PEER-R EV IEW ED packaging processes? The PQ batch should be of commercial size (3), but for packaging operations some customers order three units and other customers order 500,000 units. So is it OK to run the PQ batches with three units each? Well 500,000 units seem to be the worst-case scenario. But actually it is not, because when the line is up and running it is doing the same thing again and again, irrespective of whether it has to do it for three units or for 500,000 units. So what kind of considerations and rationales can be used to determine the relevant batch size for PQ runs? •H ow many PQ batches are needed as a minimum? It is clear that “three” is not a “wild guess” answer (4, 5), but what kind of considerations and rationales can be used to determine the required PQ runs? While Annex A (“Statistical Methods and Tools for Process Validation”) and Annex B (“Example Validation”) of the GHTF process validation guidance (1) very clearly and sufficiently suggest installation qualification (IQ) and operational qualification (OQ) methodologies for fulfilling the philosophical requirements, the PQ section lacks operational methodology. This paper therefore focuses exclusively on the PQ aspects and proposes a general methodology for translating the philosophical PQ definitions into operational terms. The scope of this paper is to define and describe a risk-based approach to performance qualification for packaging processes for medical devices and pre-filled devices. This paper does not include IQ or OQ, but only touches on the purpose of theses stages of a validation process. This paper concentrates on packaging processes as an example. SCOPE The scope of the GHTF process guideline, Quality Management Systems—Process Validation Guidance (1), is limited to medical devices, but what about assembly of pre-filled devices and packaging in general? Pre-filled devices are usually registered as a drug and, hence, are covered by FDA in Current Good Manufacturing Practice in Manufacturing Processing, Packaging or Holding of Drugs, 21 CFR–Parts 210 & 211 (6), but the process characteristics for assembly of pre-filled devices and packaging processes are much more similar to the processes used for medical device manufacturing rather than pharmaceutical processes. So, as also questioned in “Validation—How Much is Required?” by Sharp J (7), is it then fruitful to adapt the meaningful testing principles used for pharmaceutical 78 Journal of Validation T echnology [Spring 2009] processes to the field of mechanical processing, where the process characteristics are different? The obvious answer is no. Assembly and packaging processes are much more similar to medical device processes than to pharmaceutical processes. As packaging processes are characteristically mechanical processes that handle a few items at a time in a serial sequence (i.e., often checked and controlled after each step), the approach can be extended to cover assembly processes in general because the process characteristics are the same. These process characteristics are somewhat in contrast to traditional pharmaceutical processes characterised by chemical reactions and mixing operations. It is up to the reader to judge whether the proposed principle methodology is meaningful for pharmaceutical processes. PACKAGING VALIDATION Packaging is mentioned in both FDA code 21 CFR 210&211 (Drugs) (6) and FDA code 21 CFR 820 (Medical devices) (8). While FDA code 21 CFR 210&211 (Drugs) essentially focuses on labelling information and content, FDA code 21 CFR 820 (Medical devices) also addresses the package itself. FDA code 21 CFR 820.130 (Medical devices) states: “Each manufacturer shall ensure that device packaging and shipper containers are designed and constructed to protect the device from alteration or damage during the customary conditions of processing, storage, handling and distribution.” This definition means that the entire (package) chain (see Figure 1) must be “ensured to work as intended.” The functions of a package are basically to contain, carry, and protect a product. To transfer a particular product from the place of manufacture to the point of use requires some kind of container—not only to contain it, but also to protect it from external damage. If the product is not intended for immediate consumption, it must be preserved by some appropriate process. Accordingly, the package will also serve as a barrier to separate the preserved items from outside contamination and spoilage. Furthermore, in a modern society the packaging is used for communication purposes such as promoting, justifying, glamorising and, especially in the case of pharmaceutical products, differentiating the content. All these aspects apply to general packaging, but what is special about pharmaceutical products is that they are much more tightly regulated than the rest of the industry in general. Figure 1 illustrates the package lifecycle. While packaging validation in a classical context solely applies to the iv thome.com S T E E N HOWA L D T C H R I S T I A N S E N A N D J E S P E R B Ø N N E LYC K E T OR P J E N S E N Figure 1: Package chain. Local distribution Wholesaler Warehouse Retail Production Consumer Process Development—Design Qualification Package construction and design must be qualified. This is typically done using a simulated transport test, a stressed transport test, a real life transport test, and a customer handling test. To some extent these test procedures are standardized in the International Organization for Standardization (ISO) series related to transport (9). Commercial Production—Materials And Suppliers Must Be Qualified Carton As the holder of a marketing authorisation is responsible for the final product, the company is also responsible for the entire supply chain, including whatever a subcontractor may have delivered. And it is common for raw materials for packaging operations (e.g., product labels, inserts, and cartons) to be provided by subcontractors or suppliers, in which case the company is not only responsible for the physical materials themselves, but also for the printed information. Quality and safety in the supply chain are normally ensured through an entire set of specifications defining the correct physical properties and correct information of a given delivery. In the design phase, it must be ensured that the specification set-up reflects the correct aspects of functional and marketing criteria, manufacturing and cost criteria, the buyer and supplier relationship, and the quality control principle. Commercial Production—Packaging Process Qualification A typical high-speed packaging line consists of several pieces of specialized machinery, usually in series, connected by a moving belt. Figure 3 shows a generic packaggxpandjv t.com One unit One unit Product Insert and accessories Carton Product Distribution Long haul Packaging/Unpackaging packaging process (i.e., labelling, insert, cartoning, wrapping, and case packaging), “package process validation” covers the entire distribution chain as well. Following the general validation model shown in Figure 2 (5), the package process validation is the sum of all the activities (i.e., qualification, certification, and verification) to determine that the entire package construction will work as intended. According to the model in Figure 2 (5), that means each element in the entire package lifecycle (i.e., process development as well as commercial production) must be qualified. Insert and accessories ing line. Depending on the specific set-up, the line can include more or less of these main processes. In some cases the line is divided into more stand-alone units, and in certain cases some of the processes are carried out manually. Validation Steps As illustrated in Figure 2, the qualification of equipment is carried out in the following well-established steps: • IQ verifies that the equipment is installed correctly in accordance with instructions (usually the manufacturer’s instructions) • OQ verifies that the equipment is able to operate as expected under all anticipated conditions, including worst case. Clearly the IQ should be completed before OQ begins. • PQ verifies that the equipment consistently produces acceptable products under normal operating conditions. The OQ should be completed before PQ begins. • Routine production monitors the trend in daily production data and market feedback data. Journal of Validation T echnology [Spring 2009] 79 PEER-R EV IEW ED Figure 2: General validation model (5). Process Validation Timeline Commercial production Process development Prepare Install equipment Installation qualification IQ DQ Operational qualification OQ Develop Process Start up Process qualification PQ Discontinue Routine production Monitor trend Monitor Validation instrument calibration equipment Product development Operations Validation Product Time Using the model for package process validation, the validation will not only include validation of the packaging equipment, but also qualification of the package design as well as of the raw materials and the suppliers (5). While IQ and OQ seem to be manageable, PQ often seems to be problematic and challenging. This has been pointed out in various places. For example, Carol DeSain states, “This does not mean an endless number of demonstration runs with each parameter pushed to a minimum or maximum limit” (10, page 22). Also, Jerry Lanese states, “How many runs do we have to make to validate this process? This question is asked every time there is a discussion about a validation project. Three is the stock answer. This response is misleading…” (4, Introduction). So how can PQ also be made manageable? Definition Of Performance Qualification Following the leading principle in Validating Medical Packaging by Ronald Pilchik (11), a strategy for removing the complexity from a system that has become too complicated is simply to wipe the blackboard, return to basics, and ask the following: • What are the exact fundamental requirements we are going to fulfil? No more, no less. • How can we translate these requirements, statement by statement, into meaningful operational terms? • How can we implement these terms, statement by statement? 80 Journal of Validation T echnology [Spring 2009] Going back to fundamental requirements, these are translated into operational terms, ending up with the recommendation in GHTF.SG3.N99-10, process validation guidance (1). Here, the following definition of performance qualification is clear (section 2.3): “Performance qualification (PQ): Establishing by objective evidence that the process, under anticipated conditions, consistently produces a product which meets all predetermined requirements.” This definition is translated into the following key objective of the PQ phase (1, section 5.5): “In fulfilment of this definition, the key objective of the PQ activity is to demonstrate that the process will consistently produce acceptable products under normal operating conditions, and challenges to the process should simulate conditions that will be encountered under actual manufacturing conditions. Challenges must include the range of conditions that will occur during normal production as they are defined by the actions and interventions allowed in written standard operating procedures (typically established in the OQ phase). The challenges should be repeated enough times to ensure that the results are meaningful and consistent.” iv thome.com S T E E N HOWA L D T C H R I S T I A N S E N A N D J E S P E R B Ø N N E LYC K E T OR P J E N S E N Figure 3: Typical packaging sub processes. Generic Packaging Line Leaflet Product Upper foil Product label Lower foil Labelling Blistering Preheat Stretch Form Cool Perforation Folding Cartoning Price sticker Price tagging Shipper box Wrapping foil Stretch banding Case packaging Palletising Shipper label Pallet label Carton This interpretation gives operational meaning: First we have to define what normal operating conditions are and second we have to identify what kind of typically challenging conditions we observe during normal production. A list of typical influencing factors is suggested in Quality Management Systems—Process Validation Guidance (1). The list in the guidance can be used for inspiration and crosschecking, but Jerry Lanese (5) suggests a more systematic and consistent methodology for identifying variables that affect “normal production.” The suggestion is to use the 5Mmethodology (i.e., man, material, machine, method, and measurement) or a fishbone diagram. Combining these two methodologies, a risk-based PQ concept can be developed. In this context the proposed concept is an alternative to the “normally used” method: run three medium-size batch orders using intensified sampling. Risk-Based PQ Concept Description— Methodology The risk-based PQ concept illustrated in Figure 4 reflects a normal production order lifecycle and the challenges seen in that connection. The steps are as follows: 1) Define normal production 2) Identify potential influencing conditions 3) Ensure all aspects are covered 4) Remove irrelevant influencing parameters from the list with a rationale 5) Identify the challenging conditions by carrying out a risk evaluation for each influencing parameter 6) E stimate repeatability for each challenging parameter gxpandjv t.com Check weighing Wrapping foil 7) E stimate and define “stable” production 8) Simulate normal production, including the challenges identified 9) Calculate a PQ sequence that simulates normal production, including challenges 10) Determine the number of PQ runs required. Define Normal Production Normal production means that a complete production order lifecycle must be simulated. A normal production order lifecycle comprises the following three major steps: • P reparation includes: Initiate order; pick materials from stock; check materials (ready-for-production); line-clearance; and, adjust production line format. • Production includes: Adjust processing parameters; check calibrations; start-up procedure; execute order; document production; empty line; reconciliation; line clearance; and, inline process control (IPC). • Shut down includes: Batch documentation; return exceeding materials; samples for inspection; and, offline process control (OPC). Each step in the lifecycle will have its own challenges. Machine parameters are typically identified during OQ. Identify Potential Influencing Conditions Competent and experienced group members must be appointed. Different brainstorming techniques can be used such as mind map and paper cards. Journal of Validation T echnology [Spring 2009] 81 PEER-R EV IEW ED Figure 4: Risk-based PQ concept. Estimate Repeatability For Each Challenging Parameter Estimate how many times a challenging condition should be repeated to ensure that the results are meaningful and consistent. For example, if a production order typically includes cartons from three different batches, then this challenging condition should be simulated three times within each PQ run to be consistent with normal production. Shut-down: • Batch doc • Samples for insp. • Reconciliation Preparation: • Pick from stock • Ready for pack • Line clearance • Adjust format Estimate “Stable” Production When running PQ, stable production is defined as the period between two interventions where you can confirm that the previous intervention had no impact on the next. Simulate Normal Production, Including The Challenges Identified Production: 1.0 Machine 2.0 Method/Procedure 3.0 Environment 3.6 Temperature 1.7 Wear 1.5 Over wrapper process parameters 3.5 Humidity 2.5 Presence of SOP 1.4 Carton machine process parameters 1.2 Labeller process parameters 3.4 Vibration 2.4 Rollowing SOP 1.3 Blister process parameters 3.3 Light 2.3 Stop for X min 3.2 Variation in pneumatic supply 2.2 Recycling of products 1.1 Line speed 2.1 Emergency stop 3.1 Variation in electrical supply Rejectable production 5.1 Refill of product 4.1 Weight is out of callibration 4.2 Heat sensor is out of calibration 4.3 Vision is out of calibration 5.2 Carton 5.3 Leaflet/insert card 5.4 Change of label rolls 6.1 Day/night shifts 6.2 Different technicians 6.3 Training 5.5 Change of PET rolls 5.6 Change of ALU rolls 5.7 Foil for over wrapper 5.8 Shipper box 4.0 Measure 5.0 Material 6.0 People Ensure All Aspects Are Covered To ensure that all aspects are covered, the fishbone diagram can be used to represent the following: • Machine • Method (procedure, SOP) • Environment • Measure • Material • Man (People). Figure 5 shows an example of a traditional packaging process. Other structured methodologies can be used. Remove Irrelevant Influencing Parameters Each identified parameter must be evaluated. It may be possible to judge some parameters as irrelevant based on an obvious argument and rationale. Identify The Challenging Conditions By Carrying Out A Risk Evaluation Each influencing parameter is evaluated in a “quality impact/possibility risk grid” (see Figure 6). The evaluation of probability/quality impact must be based on experience. If the combination of quality impact and possibility is “LOW/LOW”, then the specific challenge parameter can be excluded from PQ. The challenging parameters are the ones above the diagonal line. 82 Journal of Validation T echnology [Spring 2009] When the machine is running without any actions or interventions in the production sequence, it will repeat itself precisely, again and again. That is the nature of a machine. The challenges will only arise when there are actions or interventions in the production line or in the environment. Everything in between will be the same. Accordingly, the “in-between periods” can be shortened to simulate stable production. Calculate A PQ Sequence That Simulates Normal Production, Including Challenges A simulation sequence might be as follows: • Run the production line stably for XX minutes with a yield comparable to normal output • Simulate the set of challenging conditions one by one the number of times estimated in item 6 in a random sequence • Run the production line stably between each simulation to avoid interactions between each challenge. Finally, calculate the required number of items to be sure that the entire set of challenging conditions will be covered combined with a simulated “stable period” between each simulated challenging condition. PQ simulating normal production is illustrated in Figure 7. The simulation must include the same main elements: preparation, production, and shut down. But while normal production is characterised by regular actions and intervention in the line during production, these aspects are simulated by “constructed” challenges. iv thome.com S T E E N HOWA L D T C H R I S T I A N S E N A N D J E S P E R B Ø N N E LYC K E T OR P J E N S E N Figure 5: Example of a fishbone diagram. 1.0 Machine 2.0 Method/Procedure 1.6 Wear 3.0 Environment 3.6 Temperature 1.5 Over wrapper process parameters 3.5 Humidity 2.5 Presence of SOP 1.4 Carton machine process parameters 1.3 Blister process parameters 1.2 Labeller process parameters 3.4 Vibration 2.4 Rollowing SOP 3.3 Light 2.3 Stop for X min 3.2 Variation in pneumatic supply 2.2 Recycling of products 1.1 Line speed 3.1 Variation in electrical supply 2.1 Emergency stop Rejectable production 5.1 Refill of product 4.1 Weight is out of calibration 4.2 Heat sensor is out of calibration 4.3 Vision is out of calibration 5.2 Carton 5.3 Leaflet/insert card 5.4 Change of label rolls 6.1 Day/night shifts 6.2 Different technicians 6.3 Training 5.5 Change of PET rolls 5.6 Change of ALU rolls 5.7 Foil for over wrapper 5.8 Shipper box 4.0 Measure Define The Number Of PQ Runs Required As the PQ as a whole should simulate normal production, the number of PQ runs should reflect the number of main formats or main variations that the technicians are setting up in between the different orders. “Consistently” is the central word in the definition of performance qualification. Evidence can be established by running the main format three times as an industrial standard—and afterwards monitor the daily production performance using the ongoing batch data reviews because these activities have to be carried out anyway as they are an integrated part of all good manufacturing practice (GMP) or ISO-regulated productions. Once the format has been changed, adjusted, and run in, then the machinery will do the same again and again. Consequently, there is no need to test this more than once. The challenging parameter is the technician who will actually do the format changes, adjusting and running in the next format. This must be tested for all formats. Figure 8 illustrates the proposed PQ run model. The number of PQ runs required must reflect the number of main formats that are possible. The main format configuration will depend on the main purposes of the equipment, usually defined by certain commercial parameters. Some typical main format configurations for packaging are listed as follows: gxpandjv t.com 5.0 Material 6.0 People •D ifferent products. Packaging lines can be used to package multiple products as long as the main shape of the product and the primary containers are similar, for example equally shaped tablets with different active pharmaceutical ingredient (API). This will typically require different infeed systems and/or different processing parameters because the physical and/or chemical properties will vary from API to API. Furthermore, the barriers to mixing up tablets with different API and packing with correct packaging materials might be a challenge. • Different quantum sizes. The line could be designed to pack 3 ml as well as 10 ml, or it could be designed to pack 10, 100, and 500 tablets per bottle. This will generally require some format parts to be replaced in the labelling handling unit. • Different number of units per carton. Often a product is sold in different unit sizes, for example 3, 5, or 10 pieces per carton and often a 1-piece sample pack as well. This will typically affect the carton machine formats that need to be changed. • Different sizes of insert to be packed with the product. As different countries have different requirements for content and a number of countries require the insert text to be printed in all official languages (or in some countries three languages), the size of the insert can obviously depend on this. Journal of Validation T echnology [Spring 2009] 83 PEER-R EV IEW ED Figure 6: Example of a risk grid. Impact on quality 2.1 0.2 2.1 2.2 2.3 2.3 3.1 3.2 4.3 5.0 2.2 High 2.3 0.2 4.3 2.4 5.1 3.1 Medium 5.4 6.1 3.2 5.6 5.5 Line clearance Emergency stop Recycling of products Stop for X min Following SOP Variation in electrical supply Variation in pneymatic supply Vision is out of calibration Materials 5.1 Refill of product 5.4 Change of label rolls 5.5 Change of PET rolls 5.6 Change of ALU rolls 5.8 Petfoil for over wrapper 6.1 Day//night shift 6.2 Different technicians 6.2 Low 5.8 Probability Low Medium High Figure 7: Normal production sequence. Each PQ run should simulate a normal production sequence, including the challenges normally seen. End Start Normal production Ready for pack Production, actions and interventions End of packaging PQ simulating normal production Order initiated End of packaging Production Ready for pack Empty of line Start production Providing materials Challenge 1 Line clearance Line clearance Collect batch documentation Stable production Entering production data Challenge 2 Fill up materials Return of material to stock Stable production Approval of batch documentation etc 84 Journal of Validation T echnology [Spring 2009] iv thome.com S T E E N HOWA L D T C H R I S T I A N S E N A N D J E S P E R B Ø N N E LYC K E T OR P J E N S E N Figure 8: The PQ run model. CHANGE FORMAT PQs simulating normal production Ready Production End CHANGE FORMAT PQs simulating normal production Ready Production PQs simulating normal production End Ready Production End Number of PQ runs reflects the number of possible main formats to be changed in between the orders • Different package configuration. As advertising is allowed in some countries and prohibited in others, it is often convenient to be able to pack more or less informational or promotional material. CONCLUSION This paper has developed a risk-based PQ concept based on fundamental requirements. The result is a cookbook describing a methodology for defining a set-up for PQ runs that simulate normal production in an operational way, including the PQ batch size and the number of PQ runs. The methodology focuses on the characteristics of normal production and the associated challenges. Consequently, the interventions and actions seen in connection with normal production are tested rather than specifying a set of specific machine parameters. This paper has focused on the packaging performance qualification as an example, but in fact this concept could be introduced for all mechanical processes because the process characteristics are all similar. In the longer term, this methodology will be proposed as Annex C to the process validation guidance (1). REFERENCES 1. GHTF/SG3/N99-10:2004 (Edition 2); Quality Management Systems—Process Validation Guidance; The Global Harmonization Task Force (by Taisuke Hojo); January 2004. 2. FDA, Guideline on General Principles of Process Validation, May 1987, reprinted February 1993, http://www.fda.gov/CDER/ GUIDANCE/pv.htm. 3. Institute of Validation Technology Standards Committee, “Proposed Validation Standard VS-1, Nonaseptic Pharmaceutical Processes,” Journal of Validation Technology, Volume 6, No., February 2008. 4. Lanese, Jerry, “Three Times Is Not Even the Beginning,” Journal of Validation Technology, Vol. 7, No. 2, February 2001. gxpandjv t.com 5. Lanese Jerry, “Three Times Is Not Even The Beginning— 2008 Update,” Journal of Validation Technology, Vol. 14, No. 2, Winter 2008. 6. FDA, Current Good Manufacturing Practice in Manufacturing Processing, Packaging or Holding of Drugs, 21 CFR – Parts 210 & 211. 7. Sharp J., “Validation – How much is required?” PDA Journal of Pharmaceutical Science and Technology, May/June 1994. 8. FDA, Quality System Regulation, Good Manufacturing Practice for Medical Devices & In Vitro Diagnostic Products, 21 CFR Part 820. 9. ISO, ISO2206:1987 ed. 2, Packaging—Complete, Filled Transport Packages—Identification of Parts When Testing, 1987. ISO, ISO2244:2000 ed. 3, Packaging—Complete, Filled Transport Packages and Unit Loads—Horizontal Impact Test, 2000. ISO, ISO2247/ISTA2B: 2000 ed. 3, Packaging—Complete, Filled Transport Packages and Unit Loads—Vibration Tests at Fixed Low Frequency, 2000. ISO, ISO2248:1985 ed. 2, Packaging—Complete, Filled Transport Packages—Vertical Impact Test by Dropping, 1985. 10. Carol DeSain, Charmaine Vercimak Sutton, Validation for Medical Device and Diagnostic Manufacturers; ISBN 0935184-64-3. 11. Ronald Pilchik, Validating Medical Packaging, CRC Press, ISBN 1-56676-807-1, 2003. JVT ARTICLE ACRONYM LISTING API FDA GMP IPC IQ ISO OPC OQ PQ SOP Active Pharmaceutical Ingredient US Food and Drug Administration Good Manufacturing Practice Inline Process Control Installation Qualification International Organization for Standardization Offline Process Control Operational Qualification Performance Qualification Standard Operating Procedure Journal of Validation T echnology [Spring 2009] 85