At 10:23 a.m. on May 13, 2019, Wang Rukui of workshop 207 looked over the batch record of gibberellin 9110-f180601 in QA office, and found that the specified feeding range of 10% palladium carbon in batch production record of gibberellin hydrogenation post (h3-mpd-10252-r05, version 02) was 18.0 ± 1.0kg, while the feeding range of 10% palladium carbon calculated by the formula was 15.5 ~ 17.6kg, and the two feeding ranges were inconsistent. (Note: TDS refers to total dissolved solids, ranging from 180 to 204kg).<br>This deviation was caused by the drafter of batch record of primary refined products of gibberellin outputting the calculation formula of 10% palladium carbon wrongly during drafting, resulting in the calculation formula of 18.0 × (1-palladium carbon moisture%) × TDS / gibberelline ketone weight x 95.7% (95.7% of the average production reduction yield) calculated 10% palladium carbon feeding range is inconsistent with the theoretical feeding 18.0 ± 1.0kg1 required by SOP, and the reviewer of relevant documents did not audit the error due to negligence.<br>By comparing the quality of three validation batches in 2015, seven normal production batches in 2018 and normal batches, it is found that the test quality of the batches involved in the deviation is basically the same as that of other normal batches and all of them meet the quality standard requirements. The quality and yield of gibberellic alcohol produced by related batches were normal. The results show that the 10% palladium carbon feed of these batches plays a role of catalyst in the process. According to the process risk assessment in the R & D report of small-scale and pilot scale test of gibberellin, the raw material reaction is incomplete when the 10% palladium carbon feed is low, but the quality and yield of gibberellin produced by relevant batches are normal. The results show that the calculation error of 10% palladium carbon feeding amount of these batches has no effect on the production of gibberellin.<br>According to the analysis and summary of the above aspects, in the production of primary refined products of gibberellin, the feed amount of 10% palladium carbon is less than the calculated input amount, which basically does not affect the product quality. The deviation does not affect the validation validity, and it is judged that the occurrence of the deviation has no potential impact on gibberellin products.<br>1. H3-mpd-10252-r03 ~ R08 batch production record of primary refined products of gibberellin (y69) was upgraded, and the calculation formula of 10% palladium carbon was deleted.<br>2. Train the upgraded h3-mpd-10252-r03 ~ R08 batch production record of primary refined products of gibberellin (y69), with emphasis on the deletion of the calculation formula of 10% palladium carbon and the reference basis of the actual feeding amount.
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