Wednesday, July 10, 2013

OSI PI Historian Software is Not only for Compliance

In October 1999, I joined a soon-to-be licensed biotech facility as Associate (Fermentation) Engineer. They had just got done solving some tough large-scale cell culture start-up problems and were on their way to getting FDA licensure (which happened in April 2000).

As the Manufacturing Sciences crew hadn't yet bulked up to support full-time commercial operations, there were 4 individuals from Process Sciences supporting the inoculum and production stages.

My job was to take over for these 4 individuals so they could resume their Process Science duties. And it's safe to say that taking over for 4 individuals would've not been possible were it not for the PI Historian.

The control system had an embedded PI system with diminished functionality: its primary goal in life was to serve trend data to HMIs. And because this was a GMP facility and because this embedded PI was an element of the validated system, the more access restrictions you could place on the embedded PI, the better it is for GMP and compliance.

Restricting access to process trends is good for GMP, but very bad for immediate-term process troubleshooting and long-term process understanding, thus Automation had created corporate PI: a full-functioned PI server on the corporate network that would handle data requests from the general cGMP citizen without impacting the control system.

Back in the early-2000's, this corporate PI system was not validated... and it didn't need to be as it was not used to make GMP forward-processing decisions.

If you think about it: PI is a historian. In addition to capturing real-time data, it primarily serves up historical data from the PI Archives. Making process decisions involves real-time, data, which was available from the validated embedded PI system viewed from the HMI.

Nonetheless, the powers that be moved towards a validating the corporate PI system, which appears to be the standard as of the late-2000's. 

Today, the success for PI system installations in the biotech/pharma sector is measured by how flawlessly the IQ and OQ documents were executed.   Little consideration is really given to the usability of the system in terms of solving process issues or Manufacturing Sciences efficiency until bioreactor sterility issues come knocking and executive heads start rolling over microbial contamination.

Most PI installations I run into try to solve the compliance problem, not a manufacturing problem, and I think this largely the case because automation engineers have been sucked into the CYA-focus rather than value-focus of this process information:
  • Trends are created with "whatever" pen colors.  
  • Tags are named the same as the instrumenttag that came from the control system.  
  • Tag descriptors don't follow a nomenclature
  • Data compression settings do not reflect reality...
  • PI Batch/EventFrames is not deployed
  • PI ModuleDB/ AF is minimally configured
The key to efficiencies that allow 1 Associate Engineer to take over the process monitoring and troubleshooting duties of 4 seasoned PD scientists/engineers lie precisely having a lot of freedom in using and improving the PI Historian.  

If said freedom is not palatable to the QA folks (despite the fact that hundreds of lots were compliantly released when manufacturing plants allowed the use of unvalidated PI data for non-GMP decision), the answer is to bring process troubleshooters and data scientists in on at the system specification phase of your automation implementation.

If your process troubleshooters don't know what to ask for upfront, there are seasoned consultants with years of experience that you can bring onto your team to help.

Let's be clear: I'm not downplaying the value of a validated PI system; I'm saying to get user input on system design upfront.

3 comments:

Jasben Bolt said...

Verification and Validation are the activities performed to improve the quality and reliability of the system and assure the product satisfies the customer needs.
Verification assures the product of each development phase meets their respective requirements.
Validation assures the final product meets the client requirements.

software validation

SAHIL GOYAL said...

Can you guide and help me in directives to make PI System Validated.. ?

OLY said...

As Jasben indicated above, Validation means that the final system meets the requirements.

Which means you need to have written a user requirement on what the users want.

Next, you write a functional specification on what the system must deliver.

Then you go and design the system saying how it is going to be set up. In the case of PI, you document what the settings are and why.

Then you write an installation qualification stating the procedure that needs to be followed to install and configure the PI system.

Then you write an operational qualification that tests that the installed system meets the functional specification.

Get these docs pre-approved by Quality and execute them.

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