processes, systems or facilities have already been assessed, there may be similarities
in the occurrence of failures, and the work required for this phase is reduced.
In general, potential failures are identified by team members who actually implement
the processes, systems and/or work with the facilities. The team should be
compiled from interdisciplinary members (e.g. from production, laboratory, quality
assurance, engineering, information processing) and from different hierarchies
if necessary, but should also not consist of more than 6-8 participants to ensure
that it can still function effectively. One suitable method for recording potential
failures is, for example, brainstorming.
At this point of time it is important to take into account regulatory compliance.
It means to consider all relevant requirements of authorities. Authority regulations
for which non-compliance can also be classified as a failure can be derived from
the bodies of rules (e.g. EC-GMP Guideline, CFR). Consider which document is a
law and which represents a guideline only. Never use risk management procedures
to justify not following the law. It is just as important! Yet, also consider the
state of the art, since some regulatory requirements take this into account. However,
it is not always easy to determine the state of the art. The documents from
associations (e.g. ISPE Baseline® series, PDA technical reports or ISO standards) can
provide some help. These documents describe principles of how pharmaceutical
production companies should design technical systems today. Often regulators
are involved, since these documents are created by experts. They provide a good
guide to the current state of the art.