Date:         Thu, 26 Aug 2010 20:25:35 -0400
Reply-To:     DCHAS-L Discussion List <DCHAS-L**At_Symbol_Here**LIST.UVM.EDU>
Sender:       DCHAS-L Discussion List <DCHAS-L**At_Symbol_Here**LIST.UVM.EDU>
From:         List Moderator <ecgrants**At_Symbol_Here**UVM.EDU>
Subject:      Re: Hoods failing annual calibration
Date: August 26, 2010 5:26:28 PM EDT
Subject: RE: [DCHAS-L] Hoods failing annual 
calibration
The hoods that 
fail to meet the minimum flow are tagged "Out of Use" and our physical 
plant calls in for service to them.  Once they have been 
recalibrated to proper flow they are then placed back in 
service.
Kathleen Schmidt-Nebril, NRCC-CHO
Chemistry Division Department of Natural 
Science
Dominican 
University
River Forest, IL 
60305
708-524-6533
===
<
div style="margin-top: 0px; margin-right: 0px; margin-bottom: 0px; 
margin-left: 0px; font: normal normal normal 12px/normal Helvetica; 
min-height: 14px; ">Date: August 26, 2010 5:36:13 PM EDT
Subject: RE: Hoods failing annual 
calibration
Pat,
 
What would be the value of an 
impact assessment upon discovering an out of spec chemical fume 
hood?
 
I would guess the impact assessment mentioned in the 
work instruction is more for Quality Assurance purposes, meaning the 
scope is more properly the processes and products affected by the 
nonconformance.  Even so, it could be valuable to run a safety 
impact assessment - minimally it could build credibility for the 
safety program.  =93A protective device was down for X period of 
time - what problem did that introduce?  If none, do we need the 
protective device?  Why / Why not?=94  Be sure you have firm 
answers!
 
Real quickly, in a GMP lab, if you have a work 
instruction you are not following (usage logs for hoods), you either 
want to start following it or modify the work instruction.  A sharp 
auditor would start poking hard to find other work instructions you are 
not following.
 
As for what to do, I think many organizations have a 
policy along the lines of, =93Repair immediately upon discovery of out 
of spec performance - here are the ways we check to ensure proper 
performance.=94  I think it=92s smart to also add, =93Evaluate 
impact of out of spec performance,=94 but that is probably not in most 
policies.
 
Hope that helps!
-Nick