By Wayland Rushing, Ph.D.
Senior Scientific Advisor
ABC Laboratories
Analytical method transfers are a very common occurrence in
our industry. The range from simple to
complex in nature and can be a source of regulatory headaches resulting in 483’s. As a result it is still surprising the number
of times the procedure is approached almost as an afterthought or check-box
exercises without the proper thought and planning put into them. One of the most common issues which I have
observed is a failure to communicate critical information. During the initial steps it is the
originating lab’s responsibility to gather and effectively communicate the
appropriate information the receiving lab will need to successfully complete
the transfer. This includes not only the
analytical method but also may include QC, validation reports, internal SOPs
and any other critical information required for the performance of the method.
The following are just a few of the comments encountered
during failure investigations performed on method transfers which demonstrate
the importance of effective communication between sites during the performance
of a method transfer.
“Those specific instrument settings are set by SOP, so we
didn’t list them in the method, did you need them?”
“Our internal SOP allows for variance of the method
conditions as long as system suitability is met”
“The chromatograms in the method really are not
representative of what we commonly see, attached are more common examples”
In each of the above instances, the originating lab failed
to communicate critical information in the transfer package to the receiving
lab. As a result, the method transfers failed during the initial executions
resulting in delays and increased expense.
Prior to initiating the transfer here are just some
procedures/questions that could be used to ensure the proper information is
communicated:
· • Get feedback from the lab personal who normally
run the method
· • Is the representative data being communicated
really representative?
· • Is there any information critical to the method
contained in other documents, i.e. SOP’s?
· • What are the common issues encountered
internally with the method?
· • Gather the make/model of instruments used on the
method.
· • Gather the validation report, any other transfer
reports or addendums which have been
performed
By not properly preparing and communicating you can inadvertently doom the transfer to failure ever before it gets into the lab.
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