We have had this intstrument for 5 years and have used it for research only. We have just started putting in a general OQ/PQ procedure for our HPLC instruments as we are entering Phase I clinicals, so there is no prior OQ, nor even a prior noise test, with which to compare. At best I could go back to some old chromatograms from various experiments.
...
Bruce, this is not an OQ procedure supplied by Agilent...we simply run under the conditions listed in the manual and measure the noise with Chemstation. Is setting the spec to what is in the manual standard practice, or is that only the ideal case when the instrument is brand new?
OK. The following are only my opinions, and others with more experience may offer different perceptions. I hope it's relevant to where you're headed....
1. It's important that all your qualifications are performed under the agreed overall quality system, eg protocals signed off in advance, and testing data signed off and released by Quality. One of the major expletives in quality systems is "retrospective", so try to avoid it...
Don't qualify equipment, other than for your peace of mind, without prior quality assurance signoff of the protocols, as the document won't be acceptable to auditors.
2. An instrument specification is a specification, so... unless the specification has a age/use related component ( not very common ) the original manufacturer's performance specification is used throughout the instrument's working life - unless the equipment has been modified/upgraded, which has to also be well documented, and there must still be specifications, as quality expects pass/fail limits.
Manufacturers service and support agreements commit to keeping the instrument within the initial specification for the agreed period, provided you don't misuse the instrument, and keep to the maintenance programme etc. If an instrument can't meet the specification, it's supposed to be quarantined until repaired/replaced. Unlike for humans, euthanasia is often the best solution for non-performing analytical toys in reegulatory environments.
3. It's possible to have bespoke instrument specifications. Auditors get seriously nervous twitches ( to accompany the drooling when they find a non-compliance ), whenever a specification is different to the manufacturer's.
The minimum energy path is to use the manufacturer's specifications, and omitting any of the manufacturer's recommended qualification tests can also trigger auditor spasms....
The documentation for any different specification has to be much more rigorous - explaining why the more relaxed limit is OK, and showing that the instrument isn't going to be used for other assays when the manufacturer's specification would be applicable.
4. As your instrument has enjoyed a varied and interesting life, don't bring that to the attention of auditors. Any evidence of quality infidelity would be seized upon, so don't mention it. Just start all the logs with a note that instrument was transferred from research status on xx date.
Have your quality people set a programme start date, and ensure all of the instruments are fully qualified, with all aspects of quality systems ( trained staff, instrument maintenance, documentation change control, controlled access, completed instrument qualifications etc. etc ) in place by that date.
It would be highly advisable to at least review, and document, the Agilent OQ/PV procedures, and also make sure that the current installation complied with critical reuirements of the Agilent IQ. There are WWW firms that offer " DIY " qualification documents/systems for most popular HPLCs.
5. You may find it cheaper to avail yourself of an external instrument service/qualification contractor - partly because any maintenance etc. is supposed to be performed by trained/skilled people using calibrated equipment. One of first things auditors look at is the training records of people using or repaining equipment.
6. Quality systems for regulatory compliance are resource intensive and expensive, but the cost of non-compliance is much, much greater...
7. Ensure your managers know they will be held accountable by auditors if appropriate resources were not provided when requested.
Don't try to save money by performing tests/maintenance without all the correctly-calibrated equipment, trained staff, and quality systems, aas you will held accountable.
If you want to train your managers, go to one of the sites like
www.labcompliance.com and review some of the FDA-483 extracts applied to analytical facilities. A year or so ago, an FDA inspector noted that laboratory testing was the richest mine for their auditors.
Please keep having fun,
Bruce Hamilton