GLP/GMP

From: Fischer, Randy (RFischer@therimmune.com)
Date: Fri Nov 05 1999 - 09:08:59 EST


Hi fellow flowers,

First, thanks to all who responded to my query about setting up a
FACSCalibur/flow cytometer for GLP/GMP, it was indeed enlightening.

Second, I have been asked to summarize the responses so others can
possibly do the same thing, so here they are.

The first consensus is that there is no consensus/standard procedure for
validating the instrument like Analytical Chemists do for their
machines.  So, here are some excerpts from the responses as it seems
like individual users need to tailor their set ups and validation
protocols.

1. All clinical flow cytometers have a "certificate of validation" that
validate
the hardware and software.  I know this because I was required to
produce it for
the GLP auditors.  Our instrument set up only involves running a bead to
confirm
alignment (DNA Check), and a second bead to shown that each day they
fall within
the same fluorescence channel (Standard Brite).  (If you're doing
relative
fluorescence intensity, then probably showing amplifier linearity and
multiple
level fluorescence checks might be needed. Like a Rainbow Beads.  I have
never
used these.).

The rest of our protocol QCs each reagent (how can you detect a defect
in lysis,
how do you know each antibody stains as it should, etc.)  We use
Cyto-Trols and
CD Chex (preserved PMBC with assay values) to QC each antibody in our
panel.
Then there is the whole issue of calibrating pipets, scales, etc.  Also
important was recording lot numbers and expriation date on every reagent
we
used.  We use a sheet for each day's run that records all of this
information
and becomes part of our results.

2. I have been doing GLP studies in flow cytometry for 5 years.
Depending on what your GLP study is, will depend on how in depth your QC
needs to be!!!
Example:  Immunophenotyping  -
Calibrite beads including APC
monthly QC for alignment
Daily check off list (usually provided by vendor)
Antibody titers and parallels for new lots
Basically you need to show that your detectors and lasers are working
properly
and consistently from day to day.

3. We are running a FACSCalibur for our quality control.(GMP)
Prerequisites are quite simple:
1. a service contract for the instrument
2. regular performance of internal quality control by FACSComp
3. validation of methods (CD34 quantification) and essential reagents
(antibodies)
4. standard operating procedures (SOP)

4. We routinely use a FACSCalibur for GLP studies. We used to run both
GLP and
non-GLP studies on the same machine. In that instance each assay was
audited by
QA. You will have to maintain records of when the machine was used, user
name,
whether the user was trained and certified for FACScalibur use, daily
QCing
(FACSCOMPing basically), printouts from the FACSComp, SOP for the assay
you wish
to run under GLP, reagents date of mfr, expiry, records of reagent use,
so on
and so forth.

5. f you are just starting out,  visit
http://www.cap.org/html/ftpdirectory/checklistftp.html and download the
Flow Cytometry Checklist and others.

6. I have used our Coulter XL to perform GLP studies.  I think what the
chemist is referring to is that your QC procedure must include analyzing
known
standards that span the expected range (multiple levels) of your
specimens.  For
a chemist, this would mean, for example, analyzing control reangents
known to
contain 10, 100 and 1000 IU of alkaline phosphatase, to show that your
assay
matches these values.  In flow cytometry, for example, you can assay
CD-Chex
which have assay values (in the normal range) for the major lymphocyte
subsets
and CD-Chex LOW  which have assay values for where CD4 counts are below
normal.
I've gone to battle with GLP inspectors because there are few QC
reagents for
flow and less with "mulitple levels".

However, for most of our studies, the GLP inspectors were content that
we run an
assay with each monoclonal antibody tested on one level of control cells
(Cyto-trol or CD-Chex) and show that our results fall within the
expected range.

Again, as it is obvious to even those of us just starting down this
path, there are no real guidelines/requirements which we can easily
follow.  The CAP checklist does give a little help in providing the
questions to be answered, but no answers to the question of what
standards/controls to use, only to use them.  If any more information
becomes available, I will of course post it to the list.

Randy Fischer

TherImmune Research Corporation
9700 Great Seneca Hwy
Rockville, MD 20850
(240) 453-6256
RFischer@therimmune.com



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