Back in 1994, that question came up in a public forum in New Jersey, addressed to Tom Layloff (who was at that time the director of the FDA CDER lab in St. Louis). The specific question concerned swapping out a defective pump in the middle of a run. His reply was that you should simply re-run the system suitability test(s). If you pass system suitability, then the system is, by definition, suitable for the intended purpose.
You have to take that statement with a couple of caveats:
- Layloff came from the lab side of FDA, not the regulatory side.
- It presumes that you have reasonable (and reasonably rigorous) system suitability criteria, so there is an element of judgement involved (there are a lot of validated methods, usually old ones, with bad system suitability requirements!).
Basically, what you need is an SOP that says "system suit = PQ".