17/18 September 2019
GMP News No. 370
11 December 2003
Adjustment versusModification – Interpretation of the Ph.Eur. Requirements
At the International HPLC Conference of the European Compliance Academythat was held in Heidelberg in spring this year, one lecture (by Dr ManfredFischer, Lilly Forschung GmbH, Hamburg) touched on the discussion pointwhether the freedoms granted by the Ph.Eur. Monograph 2.2.46 "ChromatographicSeparation Techniques" regarding the adjustment of chromatographictechniques can generally be transferred to the analytical laboratory.
The possibilitiesfor adjusting an analytical technique as described in the Ph.Eur. Monograph are quite generous: in HPLC e.g., the column length may varyby +/-70%, as may the flow rate, and the inner column diameter maydeviate by +/-25% without any need to consider this as a modification relevantto change control.
Strictly speaking, the regulations laid down in this monograph applyexclusively to analytical methods listed in pharmacopoeial monographs. Sothey cannot simply be transferred to other analytical techniques, e.g.within the framework of drug product analysis. On the other hand, it isgenerally recognised that such a monograph represents the state of the art and knowledge.
It has been discussed whether one can orientate one's own, self-developedchromatographic methods towards the Ph.Eur. Monograph. There hasbeen agreement on the fact that one should validate the method and prove bymeans of an appropriate robustness test that this method remains in factvalid over the whole adjustment range of the individual parameters. The robustness test is meant to ensure that slight changes in themethod parameters will not influence the test result during routineoperation.
Furthermore, the adjustment of a method has to be checked immediatelybefore an analytical sequence through a product-specific systemsuitability test. By means of this test it has to be proven that thechromatographic separation technique is really suitable for the analysis inhand under the current conditions and settings of the day.
From a formal point of view, it remains to say that no revalidation isnecessary in case of a method adjustment, nor is any further internal orexternal analysis or approval. In contrast to this, the modification of ananalytical technique is subject to the change control procedure: the methodhas to be revalidated, and a notification of change has to be sent to theregistration authorities.