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本帖最后由 VS____L 于 2014-12-23 17:19 编辑
前段时间看见论坛一直在讨论验证三个批次的科学性,抱着刨根问底的态度,多方打听,得到的结论如下:
1、验证三次的出处是在美国在二十世纪八十年代时候要出版工艺验证规范时候的意见征求稿中讨论得来的,理论学依据实在找不到了。
2、欧盟在他的工艺验证中也提到3的出处是源自于二十世纪八十年代的讨论稿,地址http://www.ema.europa.eu/docs/en ... /02/WC500162137.pdf,截图如附件。
3、我求助美国朋友的答复如下:
The old "validation rule of three" came about from interpretations and FDA discussions in the late 1980s regarding what was then new process validation guidelines. In the absence of true scientific understanding for what were simpler and often more manual / less complex processes (fewer degrees of freedom and less variable codependency and automated feedback control) than today, it was a generally ok rule of thumb
Personally, I don't think it was ever meant to be taken as literally and definitively as it eventually was, but that's what happens sometimes. While it works fine in many circumstances, you end up with people that either did less work than they should have two statistically or scientifically justify a process was running okay, or you had people doing way too much work for a level of confidence that they needed to achieve. Nowadays, health authorities expect you to understand and justify why your level of validation is acceptable, whether you applied three or not.
Look at any of the more recent FDA risk-based guidance documents, and you will see that FDA has very clearly steered everyone away from this "rule".
Nowadays, there are many voluntary consensus standards – ANSI, ASTM, ISO, USP, and so on - that provide the reader with the scientific fundamentals and considerations for most general applications that you might intend to validate.
以上希望能解答各位蒲友的疑惑,当时的理论学依据我朋友的解释还是一点证明不了什么;两点成线,不能反映趋势;三点能反映出一个趋势(当然是在合格的情况下,反映这个趋势的好坏)。
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