"With the FDA's risk-based initiative to cGMPs, the FDA is trying to offer an olive branch to the industry," says Bikash Chatterjee, COO of Pharmatech Associates, a consultancy serving the regulated life sciences industry. "Essentially, the FDA said, 'We're looking for sound science. If you can justify to us that the decisions you have made regarding your critical systems, processes, and equipment are scientifically sound, that's good. Processes are more sophisticated now, and we're trying to rise to meet that challenge.'"
The cGMP guidelines, however, make assumptions that add difficulty to the validation process. For example, the guidelines assume that each system is custom designed, which leads some machinery manufacturers to conclude that the guidelines don't apply to them. As pharmaceutical manufacturers push the issue, more packaging machine manufacturers find themselves being required to provide validation documentation to their customers.
--By Brian Pelletier, Contributing Editor