Streamlining the qualification of computerized systems in
GxP-compliant academic cell therapy facilities
ANNA DEL MAZO-BARBARA
1
, VALENTÍN NIETO
2
, CLÉMENTINE MIRABEL
1
,
BLANCA REYES
1
, JOAN GARCÍA-LÓPEZ
1,3
, IRENE OLIVER-VILA
1
& JOAQUIM VIVES
1
1
Divisió deTeràpies Avançades, XCELIA, Barcelona, Spain,
2
Àrea Corporativa de Qualitat, Banc de Sang iTeixits,
PasseigTaulat, Barcelona, Spain, and
3
Universitat Autònoma de Barcelona, Bellaterra, Spain
To the Editor:
Compliance with Good Manufacturing Practices
(GMP) is mandatory in the development and man-
ufacture of advanced therapy medicinal products,
pushing academic developers to implement methods
for control and monitoring of bioprocess parameters
that, until recently, were only found within large cor-
porate environments [1]. These methods include
computerized systems (CS), which contribute greatly
to standardization; improvement of productivity while
ensuring conformity of product specifications; removal
of unnecessary duplicates; and reduction of downtime
and human error. Indeed, the use of CS in the phar-
maceutical industry has increased exponentially since
the 1990s, and the growing field of cell therapy is no
exception to this. The use of CS in public institutions
is still limited, however, likely because of budget re-
strictions and the perceived complexity in obtaining
qualification for information systems. Both American
and European regulations devote significant atten-
tion to CS [2,3] and consider unqualified CS a serious
deviation, particularly if their failure can compromise
product quality, and therefore safety and efficacy.
Any CS in operation in a GMP-compliant cell
therapy facility must be qualified according to its ar-
chitecture and validated for use.To achieve this, their
acceptance criteria, protocols, procedures and records
must be supported based on well-documented risk
analyses that serve as the basis for leveraging the rel-
ative importance of the validation required, categorized
according to the expected use of the CS [4]. The In-
ternational Conference on Harmonisation (ICH)
defines “risk” as “the combination of the probability
of occurrence of harm and the severity of such
harm” [5]. Quality Risk Management thus emerges
as a methodology to evaluate, monitor, verify and
document quality risks throughout a product’s life-
time. According to regulatory authorities, Quality Risk
Management is increasingly gaining acceptance as a
valuable tool for achieving an effective quality system
that considers the unavoidable existence of a basal level
of risk in the production and commercialization of
medicines. Both qualitative and quantitative risk anal-
yses are accepted by regulatory agencies, although
quantitative data are preferred because they are clearer,
more intuitive and unambiguous [5].
Here, we share a simple methodology that com-
plies with GMP regulations according to European
Medicine Agency’s GMP 11th and 15th Annexes.We
believe it is feasible to perform in academic institu-
tions, and it has been used in our GMP-compliant cell
therapy facility, which was inspected by regulatory
authorities in 2010, 2011 and 2014 [1]. The ap-
proach presented here contributes to simplifying and
streamlining CS qualification in compliance with phar-
maceutical standards.
Briefly, qualitative and quantitative risk analyses
were performed using the Ishikawa and Failure Mode
and Effects Analysis (FMEA), respectively, to deter-
mine potential causes of errors of the design, as well
as installation, operation and performance of CS, based
on the likely impact of CS on the specifications of cell-
based products for clinical use (Figure 1A,B).
First, an Ishikawa diagram is created as a prelim-
inary risk analysis aimed at identifying and classifying
the main cause(s) of deviation in product specifica-
tions.The simplicity of the initial Ishikawa risk analysis
permits quick, qualitative identification of critical pa-
rameters that are classified in six groups (equipment,
Correspondence: Joaquim Vives, MD, Divisió de Teràpies Avançades, Banc de Sang i Teixits, XCELIA, Edifici Dr. Frederic Duran i Jordà, Passeig Taulat,
116, Barcelona 08005, Spain. E-mail: jvives@bst.cat
ARTICLE IN PRESS
(Received 27 May 2016; accepted 4 June 2016)
ISSN 1465-3249 Copyright © 2016 International Society for Cellular Therapy. Published by Elsevier Inc. All rights reserved.
http://dx.doi.org/10.1016/j.jcyt.2016.06.003
Cytotherapy, 2016; ■■: ■■–■■