Good Manufacturing Practice for Medicinal Products Manufacturers including Site Master File guidance Presented by: Boon Meow Hoe, Dy Director / Senior GMP Auditor, Overseas Audit Unit(OAU), Audit Branch (AB) Audit & Licensing Division (ALD) Health Product Regulatory Group (HPRG) Health Sciences Authority )HSA) 1 Topics Topics (A) An update on PIC/S memberships (B) PIC/S publications (C) An update on proposed revision to PIC/S GMP Guide in the pipeline in the PIC/S pipeline in the PIC/S pipeline In the EMA (EU) pipeline (D) Site Master File (E) Q&A. Discussion 2 An Update on PIC/S Membership An Update on PIC/S Membership An Update on PIC/S Membership An Update on PIC/S Membership 3 PIC/S Membership PIC/S Membership Slovenia / Agency for Medicinal Products and Medical Devices (JAZMP) Submitted & accepted Membership Accession Application on 28 Oct 2008 At last PIC/S COMMITTEE OF OFFICIALS MEETING held on 7 & 8 November 2011 at South Africa/Cape Town, PIC/S accepted Slovenia November 2011 at South Africa/Cape Town, PIC/S accepted Slovenia / JAZMP to join the PIC/S Scheme with effect from 1 January 2012. 40 YEARS ANNIVERSARY AND 40 th MEMBERS WITH THE ACCESSION OF SLOVENIA / JAZMP 4 To-date: PIC/S has 40 participating authorities (38 Countries) Austria Belgium Cyprus Czech Republic Denmark Estonia Latvia Lithuania Malta Netherlands Poland Portugal Switzerland Ukraine Norway Liechtenstein Iceland South Africa Israel Estonia Finland France Germany Greece Hungary Ireland Italy Romania Slovakia Slovenia Spain Sweden United Kingdom Argentina Canada USA Australia Singapore Malaysia 5 SINGAPORE CANADA 40 PIC/S Members January 2012 USA Slovenia AUSTRALIA ARGENTINA SOUTH AFRICA MALAYSIA ISRAEL UKRAINE 6 PIC/S Publications PIC/S Publications 7 Documents for industry PIC/S GMP Guide Site Master Files Documents for inspectorates Inspectorates Documents for inspectors Q&A Documents Aide-Memoires Current PIC/S Publications Current PIC/S Publications Aide-Memoires Guidance documents Documents for the public Information documents Press Release PIC/S Seminars Miscelleneous 8 Documents for industry PIC/S GMP Guide PE 009-9 ZIP-File PIC/S GMP GUIDE 2009-09-01 PE 009-9 (Intro) PIC/S GMP GUIDE (INTRODUCTION) 2009-09-01 PE 009-9 (Part I) PIC/S GMP GUIDE (PART I: BASIC REQUIREMENTS FOR MEDICINAL PRODUCTS) 2009-09-01 Current PIC/S Publications (Conti.) Current PIC/S Publications (Conti.) PE 009-9 (Part II) PIC/S GMP GUIDE (PART II: BASIC REQUIREMENTS FOR ACTIVE PHARMACEUTICAL INGREDIENTS) 2009-09-01 PE 009-9 (Annexes)PIC/S GMP GUIDE (ANNEXES) 2009-09-01 Site Master Files PE 008-4 EXPLANATORY NOTES FOR INDUSTRY ON THE PREPARATION OF A SITE MASTER FILE 2011-02-15 PI 019-3 SITE MASTER FILE FOR SOURCE PLASMA ESTABLISHMENTS 2007-09-26 PI 020-3 SITE MASTER FILE FOR PLASMA WAREHOUSES 2007-09-25 9 Documents for inspectorates Inspectorates PICS 1/95 (Rev 5) PIC/S SCHEME 2012-01-12 PS/INF 21/2002 (Rev 13) PARTICIPATING AUTHORITIES & PARTNERS 2012-01-13 PIC Convention PIC CONVENTION 2006-12-07 PI 002-3 QUALITY SYSTEM REQUIREMENTS FOR PHARMACEUTICAL INSPECTORATES 2007-09-25 Current PIC/S Publications (Conti.) Current PIC/S Publications (Conti.) QUALITY SYSTEM REQUIREMENTS FOR PHARMACEUTICAL INSPECTORATES 2007-09-25 PI 010-4 PROCEDURE FOR HANDLING RAPID ALERTS AND RECALLS ARISING FROM QUALITY DEFECTS 2010-12-21 PI 013-3 STANDARD OPERATING PROCEDURE PIC/S INSPECTION REPORT FORMAT 2007-09-25 PI 031-1 STANDARD OPERATING PROCEDURE TEAM INSPECTIONS 2012-01-13 PI 037-1 PIC/S RECOMMENDATION ON RISK-BASED INSPECTION PLANNING 2012-01-16 10 Documents for inspectors Q&A Documents PS INF 20 2011 QA DISTRIBUTION ACTIVITIES FOR APIs - MAY 2010 2011-04-06 Aide-Memoires PI 009-3 AIDE-MEMOIRE INSPECTION OF UTILITIES 2007-09-25 PI 021-2 AIDE MEMOIRE ON GMP PARTICULARITIES FOR CLINICAL TRIAL PRODUCTS 2007-09-26 PI 023-2 AIDE MEMOIRE ON INSPECTION OF QUALITY CONTROL LABORATORIES 2007-09-25 PI 024-2 AIDE MEMOIRE ON INSPECTION OF BIOTECH 2007-09-25 PI 025-2 AIDE-MEMOIRE ON MEDICINAL GASES 2007-09-25 PI 028-1 AIDE-MEMOIRE ON PACKAGING (Entry into force on 1 March 2009) 2009-01-21 Current PIC/S Publications (Conti.) Current PIC/S Publications (Conti.) PI 030-1 AIDE-MEMOIRE ON THE INSPECTION OF APIS 2009-01-21 Guidance documents Technical guides PE 005-3 PIC/S GMP GUIDE FOR BLOOD ESTABLISHMENTS 2007-09-27 PE 010-3 GUIDE TO GOOD PRACTICES FOR THE PREPARATION OF MEDICINAL PRODUCTS IN HEALTHCARE ESTABLISHMENTS (PE 010-3) 2008-10-01 PI 005-3 GUIDANCE ON PARAMETRIC RELEASE 2007-09-27 PI 006-3 VALIDATION MASTER PLAN INSTALLATION AND OPERATIONAL QUALIFICATION NON-STERILE PROCESS VALIDATION CLEANING VALIDATION 2007-09-25 PI 007-6 VALIDATION OF ASEPTIC PROCESSES 2010-12-21 PI 008-3 PIC/S GUIDE TO INSPECTIONS OF SOURCE PLASMA ESTABLISHMENTS AND PLASMA WAREHOUSES (INSPECTION GUIDE) 2007-09-25 PI 011-3 GOOD PRACTICES FOR COMPUTERISED SYSTEMS IN REGULATED GXP ENVIRONMENTS 2007-09-25 PI 012-3 RECOMMENDATION ON STERILITY TESTING 2007-09-25 PI 014-3 ISOLATORS USED FOR ASEPTIC PROCESSING AND STERILITY TESTING 2007-09-25 PI 032-2 TECHNICAL INTERPRETATION OF REVISED ANNEX 1 TO PIC/S GMP GUIDE 2010-01-08 11 Documents for the public Information Documents PIC/S BROCHURE MAY 2011 EDITION 2011-06-09 PS W 8 2005 PIC/S BLUEPRINT 2006-05-02 Press Releases (e.g.) PR Nov 2011 PRESS RELEASE NOVEMBER 2011 2011-11-18 PR 02 Jun 2011 PRESS RELEASE NO 2 JUNE 2011 2011-06-09 PR 01 Jun 2011 PRESS RELEASE NO 1 JUNE 2011 2011-06-09 Annual Reports Current PIC/S Publications (Conti.) Current PIC/S Publications (Conti.) Annual Reports 12 Documents for the public PIC/S Seminars B 028 THE INTERFACE BETWEEN GOOD CLINICAL PRACTICES AND MANUFACTURING PRACTICES 2004-10- 27 (Montebello, Canada, October 2002) SB 029 THE INSPECTION OF QUALITY CONTROL LABORATORIES 2004-10-27 (Bratislava, Slovak Republic, June 2003) SB 030 THE INSPECTION OF API MANUFACTURERS 2007-01-17 (El Vendrell, Spain, June 2004) SB 031 PRIMARY PACKAGING MATERIAL, LABELLING & PREVENTION OF MIX-UPS 2007-01-17 (Bucharest, Romania, September 2005) SB 032 QUALITY RISK MANAGEMENT AND RELATED ICH TOPICS 2007-01-17 (Dsseldorf, Germany, 31 May - 2 June 2006) SB 033 INSPECTION OF MANUFACTURERS OF SOLID DOSAGE FORMS 2008-01-30 (Singapore, November 2007) SB 034 GOOD DISTRIBUTION PRACTICES 2008-10-15 (Krakow, Poland, May 2008) SB 035 ASEPTIC & STERILE MANUFACTURING FROM API TO FINISHED DOSAGE FORMS 2010-09-06 (Uppsala, Sweden, November 2009) SB 036 GMP INSPECTION OF MANUFACTURERS OF TRADITIONAL / HERBAL MEDICINAL PRODUCTS 2011-02-28 Kuala Lumpur, Malaysia, November 2010 Current PIC/S Publications (Conti.) Current PIC/S Publications (Conti.) Lumpur, Malaysia, November 2010 SB 037 GOOD PHARMACEUTICAL INSPECTION PRACTICES 2011-12-27 Cape Town, South Africa, November 2011 Miscelleneous PS/INF 1/2010 EXAMPLE OF QUALITY RISK MANAGEMENT IMPLEMENTATION 2010-01-08 An informal Working Group within PIC/S has developed an example of methodology for the implementation of Quality Risk Management (QRM) in industry. This example of methodology is not intended to be issued by PIC/S as a recommendation or as a guideline for industry and / or for GMP inspectors but it could be used by PIC/S for training purposes. Whether this example is used by industry for other purposes is of no concern to PIC/S and will not influence the outcome of PIC/S inspections. PIC/S-PDA&ISPE JOINT WORKSHOP 2009-01-29 PIC/S co-organised a joint workshop with PDA and ISPE on the Manufacture of Sterile Medicinal Products (EU-PIC/S GMP revised Annex 1) which took place in Geneva on 13-14 November 2008 (read press release). 13 PIC/S GMP Guide = Introduction + Part I + Part II + 20 Annexes Part I of the PIC/S GMP Guide Originally, the PIC/S GMP Guide (PIC Basic Standards of 1972) derives from the WHO GMP Guide and was further developed subsequently. In 1989, the EU adopted its own GMP Guide, which in terms of GMP requirements was equivalent to the PIC/S GMP Guide. Since that time, the EU and the PIC/S GMP Guides have been developed in parallel and History of PIC/S GMP Guide History of PIC/S GMP Guide the EU and the PIC/S GMP Guides have been developed in parallel and whenever a change has been made to one, the other has been amended so that both Guides are practically identical. Part II of the PIC/S GMP Guide On 22 May 2001, PIC/S adopted the GMP Guide for API (ICH Q7A) as a stand-alone guide (PE 007). On 29-30 May 2006, PIC/S made it Part II of the current Guide. 14 Part I of the PIC/S GMP Guide Revisions History of PIC/S GMP Guide Revisions History of PIC/S GMP Guide Date Version Number Reasons for revision 21 December 2000 PH 1/97 (Rev.) Revision of Annex 14 Renumbering of all annexes Change in the editors address and insertion of copyright statement Inclusion of revision history 10 August 2001 PH 1/97 (Rev. 2) Amendment of para. 42 of Annex 1 Revision of Annex 6 New Annex 15 New Annex 17 Amendment to the glossary 15 January 2002 PH 1/97 (Rev. 3) New Annex 4 New Annex 5 Reference to Annex 18 of EC GMP Guide 1 September 2003 PE 009-1 Amendment of Annex 1 (mainly section 3) 1 July 2004 PE 009-2 Revision of Annex 13 Change in the Editors co-ordinates 15 Revisions History of PIC/S GMP Guide (Conti.) Revisions History of PIC/S GMP Guide (Conti.) Date Version Number Reasons for revision 1 January 2006 1 June 2006 1 August 2006 PE 009-3 Revision of Chapter 1 (Add PQR) PE 009-4 o Revision of Chapter 6 (Add On-Going stability Programme) PE 009-5 Corrections to revision of Chapter 6 Revision of Chapter 8 (add requirements on counterfeit products) Reorganisation of the PIC/S GMP Guide in Part I, Part II and Annexes 5 April 2007 PE 009-6 Reorganisation of the PIC/S GMP Guide in Part I, Part II and Annexes (EU level came into operation in Oct 2005) Incorporation of PE 007 (APIs guide) as Part II New Annex 19 (EU level came into operation on 1 Jun 2006) Revision of the Introduction Change in the Editors co-ordinates 1 September 2007 PE 009-7 Revision of General Introduction (History) and Introduction to Part II Deletion of footnotes in Chapter 6 (Part I) and Annex 13 15 January 2009 PE 009-8 Revision of Chapter 1 (Part I) (Add QRM) Revision of Annex 1 New Annex 20 (QRM) (EU level came into operation in Mar 2006) 1 September 2009 PE 009-9 Revision of Annex 3 Manufacture of Radiopharmaceuticals (EU level came into operation on 1 Mar 2009) 16 Changes Changes An update on revision to PIC/S GMP Guide Adopted by PIC/S In the PIC/S pipeline (i.e. adopted by EMA but not PIC/S) In the EMA (EU) pipeline (i.e. not adopted by both EMA and PIC/S) 17 No change since last HPRG Regulatory Workshop 2011 conducted on 20 January 2011 PIC/S has not published / released any new changes Changes to PIC/S Guide Changes to PIC/S Guide PIC/S has not published / released any new changes since last revision -- Version: PE-009-9 released on 1 Sept 2009 18 A new consultation procedure between PIC/S and the European Medicines Agency (EMA) had been discussed in Harmonisation of guidance documents Harmonisation of guidance documents EMA Consultation Consultation PIC/S European Medicines Agency (EMA) had been discussed in order to ensure further improvements in the harmonisation between the EU and the PIC/S GMP Guides and related documents. This new procedure aims at informing each party of ongoing revisions of current documents and endorsement of new documents, including the sharing of early drafts in order to facilitate appropriate involvement in the adoption process. 19 Adopted by PIC/S Adopted by PIC/S PIC/S Recommendation for Risk-based Inspection Planning in the GMP Environment Status: Adopted and entered into force on 1 st January 2012. 20 In the In the PIC/S PIC/S pipeline pipeline (i.e. adopted by EMA but not PIC/S) (i.e. adopted by EMA but not PIC/S) Part I , Part II & Annexes EU/EMA PIC/S Annex 6 (Manufacture of medicinal gases) Adopted and has come into operation on 31 st July 2010. TBA Annex 7 (Manufacture of herbal medicinal products) Adopted and has come into operation on 1 st September 2009. TBA Annex 11 (Computerised systems) Adopted and has come into operation on 30 th June 2011. TBA operation on 30 th June 2011. Annex 13 (Manufacture of investigational medicinal products) Adopted and has come into operation on 31 st July 2010 TBA Annex 14 (Manufacture of products derived from human blood or human plasma) Adopted and has come into operation on 30 th November 2011. TPA Part I -- Chapter 4 (Documentation) Adopted and has come into operation on 30 th June 2011. TBA Part II (API) introduction of QM principles Adopted and has come into operation on 31 st July 2010. TBA 21 In the In the PIC/S PIC/S pipeline pipeline (i.e. adopted by EMA but not PIC/S) (i.e. adopted by EMA but not PIC/S) Part I , Part II & Annexes EU/EMA PIC/S Part III of the GMP guide Part III of GMP Guide was created and include: Site Master File; ICH Q9; and ICH Q10 TBA Site Master File: Formal integration into EU system PIC/S version of Site Master File approved and published by EC. The revised document entered into force on 1 January 2011. On 15 Feb integration into EU system January 2011. On 15 Feb 2011, the PIC/S Secretariat added a footnote into the revised SMF without formally amending the document. The footnote indicates that a D-U-N-S reference is required for Site Master Files submitted to EU/EEA authorities for manufacturing sites located outside of the EU/EEA. 22 REVISION OF ANNEX 6 MANUFACTURE OF MEDICINAL GASES Status: At EU level, this revised Annex 6 has come into operation on 31 st July 2010. PIC/S level: Not adopted yet, it is likely to be adopted at next PIC/S CoO meeting (Switzerland/Geneva ) in May 2012 The proposed revised Annex 6 was initiated as a consequence of the restructuring of the GMP Guide and the need to modify the requirements of Part II of the Guide for applicability to medicinal gases. There was also a need to define more clearly Revisions to the GMP Guide in the Revisions to the GMP Guide in the PIC/S PIC/S pipeline pipeline for applicability to medicinal gases. There was also a need to define more clearly what should be considered as a starting material as opposed to a bulk pharmaceutical product. The opportunity has also been taken to update the annex in general. On 1 Feb 2012, we received the following progress update: (i) Australia/TGA had underlined that a number of terms were unclear or needed to be better defined, e.g. paragraph 29 required traceability without specifying to which extent (i.e. per individual cylinder, batch or customer?). It was proposed the best way to address this issue was for PIC/S to adopt a Question & Answer document. (ii) Canada/HPFBI suggested to amend paragraphs 35 and 36 dealing with the sealing of cylinders and mobile cryogenic vessels to authorise devices in addition to seals (e.g. Cylinders and mobile cryogenic vessels should be fitted with tamper-evident seals or devices). 23 REVISION OF ANNEX 7 - Manufacture of Herbal Medicinal Products Status: At EU level, this revised Annex 7 has come into operation on 1 st Sept 2009. PIC/S level: Not adopted yet, it is likely to be adopted at next PIC/S CoO meeting (Switzerland/Geneva ) in May 2012 The proposal is based on the revision of Annex 7 to the EU GMP Guide. Annex 7 has been revised to also apply to active substances used as starting materials for the manufacture of herbal medicinal products following the adoption of ICH Q7A as Part II of the EU GMP Guide. Revisions to the GMP Guide in the Revisions to the GMP Guide in the PIC/S PIC/S pipeline pipeline herbal medicinal products following the adoption of ICH Q7A as Part II of the EU GMP Guide. Good Agricultural and Collection Practice (GACP) requirement was introduced. Paragraph 7 of EU Annex 7 reads as follows: Herbal medicinal product manufacturers must ensure that they use only herbal starting materials manufactured in accordance with GMP and the Marketing Authorisation dossier. Comprehensive documentation on audits of the herbal starting material suppliers carried out by, or on behalf of the herbal medicinal product manufacturer should be made available. Audit trails for the active substance are fundamental to the quality of the starting material. The manufacturer should ensure that the suppliers of the herbal substance / preparation are in compliance with Good Agricultural and Collection Practice. 24 REVISION OF ANNEX 7 - Manufacture of Herbal Medicinal Products (Conti.) Revised paragraph 7 regarding GACP requirement Australia / TGA has expressed its concerns on the compulsory requirement for GACP-compliance. TGA has thus counter proposed: The manufacturer should verify, where appropriate, whether the suppliers of the herbal substance / preparation are in compliance with Good Agricultural and Collection Practice (or equivalent) and if not apply appropriate Ensure that Revisions to the GMP Guide in the Revisions to the GMP Guide in the PIC/S PIC/S pipeline pipeline Agricultural and Collection Practice (or equivalent) and if not apply appropriate controls in line with QRM. Italy / AIFA is in favour of the original EU version. AIFA has also counter proposed: The manufacturer should ensure that the suppliers of the herbal substance / preparation are in compliance with Good Agricultural and Collection Practice (published by the European Medicines Agency or by WHO) in order to perform appropriate controls in line with QRM. 25 REVISION OF ANNEX 7 - Manufacture of Herbal Medicinal Products (Conti.) The final proposal: Revised paragraph 7 regarding GACP requirement Taking into both proposals made by Australia / TGA and Italy / AIFA into consideration: .The manufacturer should verify, where appropriate, whether the suppliers of the herbal substance / preparation are in compliance with Good Agricultural and Collection Practice* and if not apply appropriate controls in line with QRM. Revisions to the GMP Guide in the Revisions to the GMP Guide in the PIC/S PIC/S pipeline pipeline * EMA, WHO or equivalent (This reference to the EMA or WHO take the form of a footnote and the words or equivalent would be added). 26 Proposed Revision of ANNEX 11 (Computerised Systems) and Chapter 4 Status: At EU level, this revised Annex 11 has come into operation on 30 th Jun 2011. PIC/S level: Not adopted yet, it is likely to be adopted at next PIC/S CoO meeting (Switzerland/Geneva ) in May 2012 Revisions to the GMP Guide in the Revisions to the GMP Guide in the PIC/S PIC/S pipeline pipeline Key proposed changes: Revised in parallel with Chapter 4 27 REVISION OF ANNEX 13 MANUFACTURE OF INVESTIGATIONAL MEDICINAL PRODUCTS Status: At EU level, this revised Annex 13 has come into operation on 31 st July 2010. PIC/S level: Not adopted yet, it is likely to be adopted at next PIC/S CoO meeting (Switzerland/Geneva ) in May 2012. Key Changes Revisions to the GMP Guide in the Revisions to the GMP Guide in the PIC/S PIC/S pipeline pipeline Key Changes The revision was initiated in order to reinforce the principle of independence between production and quality control functions in cases where the number of personnel involved is small. Changes have been made to sections 36 and 37 in order to supplement, for investigational medicinal products, the guidance for reference and retention samples given in Annex 19. A few editorial changes have been made in the interest of consistency with terminology used throughout the GMP Guide. 28 On 1 Feb 2012, we received the following progress update: (i) Australia/TGA highlighted the following issue: the proposed text (in particular paragraph 26b and Table 1, entry b) allows that for closed 'blinded' trials, the labelling does not include any information regarding name/identifier and strength / potency of the clinical trial material. This may lead to confusions in hospital pharmacies and can easily be avoided by including a requirement (within clause 26b and Table 1 entry b) to include in the labelling a statement of both the 'verum' and the placebo, for example: "acetylsalicylic acid 300mg or placebo tablets". Such a labelling requirement would still leave the blinded character of the trial intact while avoiding confusion in case of emergency. Revisions to the GMP Guide in the Revisions to the GMP Guide in the PIC/S PIC/S pipeline pipeline trial intact while avoiding confusion in case of emergency. (ii) Israel/ISCP commented that there was no mention of required labels for cytotoxic products or articles requiring special storage conditions (e.g. "store at 2C-8C"). In addition, the term "immediate container", which was outmoded in the revised Annex 13, still appeared in paragraph 30. It was proposed to integrate the above comments as footnotes in the revised Annex 13 of the PIC/S GMP Guide. 29 Proposed Revision of ANNEX 14 (Medicinal Products Derived from Human Blood or Plasma) Status: At EU level, this revised Annex 14 has come into operation on 31 st July 2010. PIC/S level: Not adopted yet, it is likely to be adopted at next PIC/S CoO Revisions to the GMP Guide in the Revisions to the GMP Guide in the PIC/S PIC/S pipeline pipeline PIC/S level: Not adopted yet, it is likely to be adopted at next PIC/S CoO meeting (Switzerland/Geneva ) in May 2012 Key changes: - Plasma for fractionation from 3 rd countries - Demarcation between GMP and Blood legislation 30 CHAPTER 4 of the GMP Guide (Documentation) Status: At EU level, this revised Chapter 4 (Documentation)has come into operation on 30 th June 2011. (Same as Annex 11 on Computerized systems) PIC/S level: Not adopted yet, it is likely to be adopted at next PIC/S CoO meeting (Switzerland/Geneva ) in May 2012 Revisions to the GMP Guide in the Revisions to the GMP Guide in the PIC/S PIC/S pipeline pipeline Key changes: Revised in parallel with Annex 11 Revised section on Principle Revised section on Required GMP documentation (by type) inclusion of Site Master File, Instructions (directions, or requirements) type Specifications; Manufacturing formulae, Processing, Packaging and Testing Instructions; Procedures (SOPs); Protocols; and Technical agreements. 31 CHAPTER 4 of the GMP Guide (Documentation) (Conti) Records/Report type- Records; Certificates of Analysis; Reports Revised section on Generation and control of documentation All types of document should be defined and adhered to. The requirements apply equally to all forms of document media types. Complex systems need to be understood, well documented, validated, and adequate controls should be in place. Many documents (instructions and/or records) may exist in hybrid forms, i.e. some elements as electronic and others as paper based. Relationships and control measures for master documents, official copies, data handling and records need to be stated for both hybrid and homogenous systems. Appropriate controls for electronic documents such as templates, forms, and master documents should be implemented. Appropriate controls should be in place to ensure the integrity of the record throughout the retention period. Revised section on Retention of documents Revisions to the GMP Guide in the Revisions to the GMP Guide in the PIC/S PIC/S pipeline pipeline Revised section on Retention of documents It should be clearly defined which record is related to each manufacturing activity and where this record is located. Secure controls must be in place to ensure the integrity of the record throughout the retention period and validated where appropriate. Specific requirements apply to batch documentation which must be kept for one year after expiry of the batch to which it relates or at least five years after certification of the batch by the Qualified Person, whichever is the longer. For investigational medicinal products, the batch documentation must be kept for at least five years after the completion or formal discontinuation of the last clinical trial in which the batch was used. Other requirements for retention of documentation may be described in legislation in relation to specific types of product (e.g. Advanced Therapy Medicinal Products) and specify that longer retention periods be applied to certain documents. For other types of documentation, the retention period will depend on the business activity which the documentation supports. Critical documentation, including raw data (for example relating to validation or stability), which supports information in the Marketing Authorisation should be retained whilst the authorization remains in force. It may be considered acceptable to retire certain documentation (e.g. raw data supporting validation reports or stability reports) where the data has been superseded by a full set of new data. Justification for this should be documented and should take into account the requirements for retention of batch documentation; for example, in the case of process validation data, the accompanying raw data should be retained for a period at least as long as the records for all batches whose release has been supported on the basis of that validation exercise. 32 CHAPTER 4 of the GMP Guide (Documentation) (Conti) Revised section on Other E.g. 4.29 There should be written policies, procedures, protocols, reports and the associated records of actions taken or conclusions reached, where appropriate, for the following examples: - Validation and qualification of processes, equipment and systems; - Equipment assembly and calibration; - Technology transfer; - Maintenance, cleaning and sanitation; - Personnel matters including signature lists, training in GMP and technical matters, clothing and Revisions to the GMP Guide in the Revisions to the GMP Guide in the PIC/S PIC/S pipeline pipeline - Personnel matters including signature lists, training in GMP and technical matters, clothing and hygiene and verification of the effectiveness of training. - Environmental monitoring; - Pest control; - Complaints; - Recalls; - Returns; - Change control; - Investigations into deviations and non-conformances; - Internal quality/GMP compliance audits; - Summaries of records where appropriate (e.g. product quality review); - Supplier audits. 33 REVISION OF Part II (Basic Requirements for Active Substances used as Starting Materials) Status: At EU level: this revised Part II has come into operation on 31 July 2010. PIC/S level: Not adopted yet, it is likely to be adopted at next PIC/S CoO meeting (Switzerland/Geneva ) in May 2012 Changes: Revisions to the GMP Guide in the Revisions to the GMP Guide in the PIC/S PIC/S pipeline pipeline Changes: The proposed revised Part II was initiated in order to incorporate principles of QRM corresponding to similar changes made to Part I, Chapter 1 of the Guide. A new section on QRM was introduced as section 2.2. The remaining sections of chapter 2 are renumbered. No other changes have been made. 34 Proposed new Part III of the GMP guide Status: EU Level :Both revision to SMF explanatory notes and Part III concept - adopted and published at EU level. PIC/S Level : Revision to SMF explanatory notes adopted with effect from 1 Jan 2011; Part III concept -- Not adopted by Revisions to the GMP Guide in the Revisions to the GMP Guide in the PIC/S PIC/S pipeline pipeline from 1 Jan 2011; Part III concept -- Not adopted by PIC/S yet SMF has also become a standard expectation of EU authorities. It is proposed to create a new informational Part III of the EU GMP Guide for collection of GMP related documents which are not themselves GMP guidelines and have no statutory force (i.e. non-binding documents) but which complement the GMP guidelines and related regulatory procedures such as inspections. It is expected that in the future, further documents will be added to the new Part III [E.g. introductory part of GMP Guide, ICH documents (Q9 and Q10) are proposed to be included in Part III]. 35 Proposed Revisions to the EU GMP Guide Proposed Revisions to the EU GMP Guide -- -- In the EU (EMA) In the EU (EMA) pipeline pipeline (i.e. Not adopted yet) (i.e. Not adopted yet) Part I , Part II & Annexes EU/EMA PIC/S Part I Chapter 1 and 2 New texts of chapter 1 proposed during last EMAs GMP/GDP IWG meeting. Revision of chapter 2 will be done after consolidation of chapter 1. Participating Authorities requested to send their feedback on proposed revisions by 15 Feb 2012. Part I Chapters 3 and 5 (Dedicated Facilities) EMAs Safety Working Party has published Concept Paper on development of toxicological tools. Participating Authorities are invited to comment on proposed Concept Paper Part I Chapters 5 (API Slight changes proposed during last New draft is invited for Part I Chapters 5 (API pedigree) Slight changes proposed during last EMAs GMP/GDP IWG meeting. New draft is invited for comments till 15 th Feb 2012. Part I Chapters 5 (control of starting materials) Q&A was prepared, awaiting approval. Q&A is invited for comments till 15 th February 2012. Part I Chapter 6 (Quality Control) Work on text has been started; first draft will be available for next EMAs GMP/GDP IWG meeting. After first draft will be shared with PIC/S. Part I Chapter 7 (Contract Manufacturer and Analysis) Last draft sent for publication by EC. will be shared with PIC/S. Part I Chapter 8 (notification of product shortage) First draft should be available for next EMAs GMP/GDP IWG meeting. First draft will be shared with PIC/S once it is available. 36 Proposed Revisions to the EU GMP Guide Proposed Revisions to the EU GMP Guide -- -- In the EU (EMA) In the EU (EMA) pipeline pipeline (i.e. Not adopted yet) (i.e. Not adopted yet) Part I , Part II & Annexes EU/EMA PIC/S Annex 2 (Biologicals) Final draft prepared and was shared with PIC/S. Adopted and sent to EC for publication. Will be tabled for adoption at next PIC/S CoO (Switzerland/Geneva) in may 2012. Annex 16 (update of text) Proposed overall revision of annex Concept paper from EMA will Annex 16 (update of text) Proposed overall revision of annex 16 Concept paper will be ready for next EMAs GMP/GDP IWG meeting. Concept paper from EMA will be shared with PIC/S once available. GDP Guide GDP Guideline approved for public consultation. The work should be coordinated with PIC/S working group. Format of GDP licence approved for pilot phase till end of 2011. Ongoing work of PIC/S working group. Proposed EU GDP guide are to be sent to PIC/S PA for their comments and local public consultation. (this has to be confirmed by chair of PIC/S working group as discussed at last PIC/S committee meeting). 37 Part I Proposed Revision of CHAPTER 1 (Quality Management ) & CHAPTER 2 (Personnel) Status: EU/EMA: New texts of chapter 1 proposed during last EMAs GMP/GDP IWG meeting. Revision of chapter 2 will be done after consolidation of chapter 1. PIC/S: Participating Authorities requested to send their feedback on proposed revisions by 15 Feb 2012. Revisions to the GMP Guide in the Revisions to the GMP Guide in the EMA(EU) EMA(EU) pipeline pipeline Proposed changes made to Chapter 1 is to harmonise with ICH Q10 (Part III) A pharmaceutical quality system designed for the entire product lifecycle. The following key changes are recommended to be added to Chapter 1: - Quality Management System Achieve Product Realisation Establish and Maintain a State of Control Facilitate Continual Improvement 38 Part I Proposed Revision of CHAPTER 1 (Quality Management ) & CHAPTER 2 (Personnel) Continue Quality Manual (or equivalent) Management responsibilities CAPA Revisions to the GMP Guide in the Revisions to the GMP Guide in the EMA(EU) EMA(EU) pipeline pipeline Process Performance and Product Quality Monitoring Management of Outsourced Activities and Purchased Materials Management Review & monitoring of the QMS formalised periodic review process internal and external factors to be considered output from review process (documentation, timely and effective communication of results) 39 Part I Proposed revision of CHAPTER 3 (Premises and Equipment) & CHAPTER 5 (Production) Status: EU: EMAs Safety Working Party has published Concept Paper on development of toxicological tools. PIC/S: Participating Authorities are invited to comment on proposed Concept Paper Key Proposed Changes: Dedicated and self-contained Facilities Proposed Revisions to the EU GMP Guide in the Proposed Revisions to the EU GMP Guide in the EMA(EU) EMA(EU) pipeline pipeline Dedicated and self-contained Facilities CHAPTER 3 -- PREMISES AND EQUIPMENT (Existing) 3.6. In order to minimise the risk of a serious medical hazard due to cross-contamination, dedicated and self-contained facilities must be available for the production of particular medicinal products, such as highly sensitising materials (e.g. penicillins) or biological preparations (e.g. from live micro-organisms). The production of certain additional products, such as certain antibiotics, certain hormones, certain cytotoxics, certain highly active drugs and non-medicinal products should not be conducted in the same facilities. For those products, in exceptional cases, the principle of campaign working in the same facilities can be accepted provided that specific precautions are taken and the necessary validations are made. The manufacture of technical poisons, such as pesticides and herbicides, should not be allowed in premises used for the manufacture of medicinal products. 40 Part I Proposed revision of CHAPTER 3 (Premises and Equipment) & CHAPTER 5 (Production) CHAPTER 5 PRODUCTION (Existing) -- Prevention of cross-contamination in production 5.18. Contamination of a starting material or of a product by another material or product must be avoided. This risk of accidental cross-contamination arises from the uncontrolled release of dust, gases, vapours, sprays or organisms from materials and products in process, from residues on equipment, and from operators' clothing. The significance of this risk varies with the type of contaminant and of product being contaminated. Amongst the most hazardous contaminants are highly sensitising materials, biological preparations containing Proposed Revisions to the EU GMP Guide in the Proposed Revisions to the EU GMP Guide in the EMA(EU) EMA(EU) pipeline pipeline hazardous contaminants are highly sensitising materials, biological preparations containing living organisms, certain hormones, cytotoxics, and other highly active materials. Products in which contamination is likely to be most significant are those administered by injection, those given in large doses and/or over a long time. 41 Part I Proposed revision of CHAPTER 3 (Premises and Equipment) & CHAPTER 5 (Production) CHAPTER 5 PRODUCTION (Existing) -- Prevention of cross-contamination in production 5.19 Cross-contamination should be avoided by appropriate technical or organisational measures, for example: a) production in segregated areas (required for products such as penicillins, live vaccines, live bacterial preparations and some other biologicals), or by campaign (separation in time) followed by appropriate cleaning; b) providing appropriate air-locks and air extraction; Proposed Revisions to the EU GMP Guide in the Proposed Revisions to the EU GMP Guide in the EMA(EU) EMA(EU) pipeline pipeline b) providing appropriate air-locks and air extraction; c) minimising the risk of contamination caused by recirculation or re-entry of untreated or insufficiently treated air; d) keeping protective clothing inside areas where products with special risk of cross contamination are processed; e) using cleaning and decontamination procedures of known effectiveness, as ineffective cleaning of equipment is a common source of cross-contamination; f) using closed systems of production; g) testing for residues and use of cleaning status labels on equipment. 42 Part I Proposed revision of CHAPTER 3 (Premises and Equipment) & CHAPTER 5 (Production) Chapter 3 3.6 & Chapter 5 5.18 & 5.19 Lack of clarity I existing GMP Guide w.r.t. when a medicinal product should be manufactured in dedicated , self-contained facility. Proposed amendment on 3.6 dedicated facilities to include ICH Q9 QRM principles Risk assessment should include a toxicological evaluation of the product being manufactured in a shared facility. Proposed Revisions to the EU GMP Guide in the Proposed Revisions to the EU GMP Guide in the EMA(EU) EMA(EU) pipeline pipeline The need to develop a Toxicological tool to conduct toxicological assessment (absence of guidance w.r.t. a method of deriving acceptable exposure limits for cross contamination between products manufactured using shared facilities) Concept paper agreed by EMAs Safety Working Group (SWG) and GMP/GDP IWF in Sept 2011. First draft to be discussed at next meeting in Feb 2012. 43 Proposed amendment to CHAPTER 5 : Production (API pedigree) Status: EU: Slight changes proposed during last EMAs GMP/GDP IWG meeting. PIC/S: New draft is invited for comments till 15 th Feb 2012. Key proposed changes Qualification of Suppliers of Starting Materials Supply chain traceability for starting materials Proposed Revisions to the EU GMP Guide in the Proposed Revisions to the EU GMP Guide in the EMA (EU) EMA (EU) pipeline pipeline Supply chain traceability for starting materials Testing for starting materials Control of contamination (Dedicated facilities) 44 Proposed amendment to CHAPTER 5 : Production (API pedigree) What is Pedigree? A pedigree is a family tree for an active pharmaceutical ingredient (API) tracing its history or supply chain from critical raw material(s) used in the manufacture of the API to the manufacturer of the dosage form. Proposed Revisions to the EU GMP Guide in the Proposed Revisions to the EU GMP Guide in the EMA (EU) EMA (EU) pipeline pipeline The pedigree should be reviewed periodically to ensure that it is up to date (Chapter 1 proposal) GMP Guide revision (Chapter 5 proposal):Pedigree = Traceability 45 Proposed revision of CHAPTER 6 (Quality Control) Status: EU: Work on text has been started; first draft will be available for next EMAs GMP/GDP IWG meeting. PIC/S: After first draft will be shared with PIC/S. Key proposed changes: Proposed Revisions to the GMP Guide in the Proposed Revisions to the GMP Guide in the EMA (EU) EMA (EU) pipeline pipeline Key proposed changes: Analytical method transfer 46 Proposed Revision of CHAPTER 7 (Contract Manufacture and Analysis to be renamed as Outsourced Activities) Status: EU : Last draft sent for publication by EC. PIC/S : will be shared with PIC/S. Key proposed changes: Proposed Revisions to the GMP Guide in the Proposed Revisions to the GMP Guide in the EMA (EU) EMA (EU) pipeline pipeline Key proposed changes: Harmonise with ICH Q10 guideline (Outsourced activities -ICH terminology) Proposed revised Chapter 7 provides updated guidance on outsourced GMP regulated activities beyond the current scope of contract manufacture and analysis operations. The title of the Chapter has been changed to reflect this. 47 Proposed Revision of CHAPTER 8 (Complaints and Product Recall) Status: EU: First draft should be available for next EMAs GMP/GDP IWG meeting. PIC/S: To be shared with PIC/S once available Key proposed changes: To consider a revision in the light of discussions at a meeting of Quality Proposed Revisions to the GMP Guide in the Proposed Revisions to the GMP Guide in the EMA (EU) EMA (EU) pipeline pipeline To consider a revision in the light of discussions at a meeting of Quality Defect contact points held at EMA on 7-8 October 2009 on product shortage notifications and to introduce specific Quality Risk Management concepts in the context of this chapter. i.e. reporting where product shortage arises due to manufacturing issues 48 Proposed Revision of ANNEX 2 of the GMP Guide (Biological Medicinal Products) Status: EU :Final draft prepared and was shared with PIC/S. Adopted and sent to EC for publication. The European Commission will decide about the entry into force of the revised EU Annex 2. PIC/S :Consulting PIC/S Participating Authorities, in particular, non-EEA Proposed Revisions to the GMP Guide in the Proposed Revisions to the GMP Guide in the EMA (EU) EMA (EU) pipeline pipeline PIC/S :Consulting PIC/S Participating Authorities, in particular, non-EEA Participating Authorities, on some unresolved issues . Key proposed changes Annex 2 of the EU GMP Guide has been revised as a consequence of the restructuring of the GMP Guide, new manufacturing technology and concepts, the increased breadth of biological products to include several new product types such as transgenic derived products and the Advanced Therapy Medicinal Products, (ATMPs) together with associated new EU legislation. The GMP guidance drawn up for the latter products is to meet the requirements of Article 5 of Regulation 1394/2007 and to align with details in Directive 2009/120/EC. 49 Good Distribution Practice (GDP) Guide Status EU: Public consultation ended on 31 Dec 2011, coordinated with PIC/S GDP working group. PIC/S: From a GDP Working Group, forming an Expert Circle on GDP 1 st meeting proposed to be conducted on 18-20 April 2012 in Helsinki/Finland with a view to adopt EMAs revised Guidelines on Good Distribution Practice. Other Revisions to the GDP Guide in the Other Revisions to the GDP Guide in the PIC/S PIC/S pipeline pipeline Reasons for change: The content of the EMA Guidelines on Good Distribution Practice published in 1994 is no longer adequate. It needs to be reviewed to take into account advancements of practices for an appropriate storage and distribution of medicinal products in the European Union. Moreover, it should take into account the amendments to the Community Code which have been introduced with Directive 2011/62/EU of the European Parliament and of the Council amending Directive 2001/83/EC on the Community code relating to medicinal products for human use, as regards the prevention of the entry into the legal supply chain of falsified medicinal products. 50 PIC/S Explanatory Notes for pharmaceutical manufacturers on the preparation of a site master file SMF SMF preparation of a site master file (SMF) (PE 008-4 dated 1 January 2011) Revision adopted on 1 January 2011 51 PIC/S Explanatory Notes PIC/S Explanatory Notes for pharmaceutical manufacturers on the for pharmaceutical manufacturers on the preparation of a site master file (SMF) preparation of a site master file (SMF) (PE 008 (PE 008--4 dated 1 January 2011) 4 dated 1 January 2011) Revision adopted on 1 January 2011 Revision adopted on 1 January 2011 Status: At PIC/S level: this revised document has been adopted and has come into operation on 1 January 2011 (First time in history that a document is adopted by PIC/S before EU level) At its meeting in Kuala Lumpur (8-9 November 2010), the PIC/S Committee has adopted the revision of the Explanatory Notes for Industry on the Preparation of a Site adopted the revision of the Explanatory Notes for Industry on the Preparation of a Site Master File (PE 008-4). The main objectives of the revision are the simplification of the document and the implementation of requirements in relation with quality risk management. On 15 February, the PIC/S Secretariat added a footnote into the revised SMF without formally amending the document. The footnote indicates that a D-U-N-S reference is required for SMFs submitted to EU/EEA authorities for manufacturing sites located outside of the EU/EEA. At EU level: this revised document has also been adopted (Ref:Brussels, SANCO/C8/AM/sl/ares(2010)1064603). 52 PIC/S Explanatory Notes PIC/S Explanatory Notes for pharmaceutical manufacturers on the for pharmaceutical manufacturers on the preparation of a site master file (SMF) preparation of a site master file (SMF) (PE 008 (PE 008--4 dated 1 January 2011) 4 dated 1 January 2011) Revision adopted on 1 January 2011 Revision adopted on 1 January 2011 Both documents are almost identical. 53 PIC/S new SMF Guide Rev. 4 (PE 008-4) 1 Jan 2011 EU new SMF Guide 10 Feb 2011 1. Document History 2. Introduction 3. Purpose 4. Scope SMF SMF (Table of Contents) ) 5. Content of SMF 6. Revision History 7. Appendices for a Site Master File 54 Purpose of the Site Master File A Site Master File is a dossier prepared by the manufacturer that contains specific information about the Quality Management systems, policies and activities of the Company, Manufacturing Site and/or quality control of manufacturing operations carried out by the Site. This Explanatory Note is a guide to prepare a Site Master File that This Explanatory Note is a guide to prepare a Site Master File that can be utilized in planning and conducting GMP inspections. A Site Master File is essential for pharmaceutical companies as it is the basis for the regulatory authority to prepare for a GMP inspection. The SMF has become compulsory in the EU/EEA as the revised Chapter 4 of the EU GMP Guide has already come into operation on 30 th June 2011(the SMF will be included in Part 3 of the EU/EEA GMP Guide). The Commission has published the EU/EEA SMF on its website. 56 Format of the Site Master File Format of the Site Master File SMF should contain information on the Sites GMP related activities. SMF is a detailed document but should not exceed 25-30 pages plus Appendices. Dossier should have an Edition Number, and effective and expiry dates and should be updated and reviewed to ensure it is dates and should be updated and reviewed to ensure it is representative of current Site activities. Format and headings should follow the outlined guidance notes. 57 Scope of the Site Master File Scope of the Site Master File These Explanatory Notes apply to the preparation and content of the SMF. Manufacturers should refer to regional / national regulatory requirements to establish whether it is mandatory for manufacturers of medicinal products to prepare a SMF. These Explanatory Notes apply for all kind of manufacturing operations such as production, packaging and labelling, testing, relabelling and repackaging of all types of medicinal products. The outlines of this guide repackaging of all types of medicinal products. The outlines of this guide could also be used in the preparation of a SMF or corresponding document by Blood and Tissue Establishments and manufacturers of Active Pharmaceutical Ingredients. 58 Overview on changes Overview on changes Several possibilities regarding the indication of the geographic location of the site have been added A listing of the GMP inspections conducted in the past 5 years must be included in the Site Master File Higher importance is attached to the topic "supplier qualification" (the indication of the supply chain is now required) Introduction of the PQR point Introduction of the PQR point New requirement on the description of relevant utilities (steam, compressed air, nitrogen, etc.) Concrete information on the storage of documents outside the premises is required Description of the system which ensures appropriate environmental conditions during transportation Measures taken against illegal infiltration in the supply chain 59 New Requirements New Requirements Notes address supply chain with Risk Management and incorporate ICH Q 8, 9 and 10 General Company Information GPS details must be provided to ensure accurate location of the facility Information on GMP inspections, dates, relevant authority and outcomes Quality Management System of the Company Information regarding relevant standards for the company (ISO, ICH etc) Dates and approvals for accreditation's and certified activities Description of validation and change control policies Actual names of responsible person(s) and QP(s) ;additional detail on their role Information on PAT and real time release Included Company Risk Management policies, qualification and oversight of suppliers Compliance with TSE guidelines 60 1. GENERAL INFORMATION ON THE MANUFACTURER 1.1 Contact information on the manufacturer (also see 4.1) 4 th bullet point - Identification number of the site as e.g. GPS details, D-U-N-S (Data Universal Numbering System) Number (a unique identification number provided by Dun & Bradstreet) of the site or any other geographic location system 1 . Why? SMF (Changes) SMF (Changes) Why? This new requirement is to better identify the location of manufacturing site(s). These additional data are GPS co-ordinates, and (if available) a DUNS number. The purpose is to provide more reliability of the site location. Experience showed that the way the applicants express their address may be either incomplete or inconsistent. The GPS coordinates or DUNS number will allow NDRA to unambiguously identify the location of a manufacturing site. 60 Identification number: DUNS (Data Universal Numbering System) What? An unique, separate and distinct nine-digit number assigned to each business location developed and maintained solely by a private company known as Duns & Bradstreet (D&B). This D&B DUNS Number is used by industries and organizations around the world as a global standard for business identification and tracking. SMF (Changes) SMF (Changes) world as a global standard for business identification and tracking. This number can be applied for through the company website (http://www.dnb.com/). Local contact: Dun & Bradstreet (Singapore) Pte Ltd Tel: (65) 6513 8347, Fax : (65) 6778-4627 Address :20 Harbour Drive, PSA Vista #06-02, Singapore 117612 (There is a charge of SGD 37.45 (inclusive of 7% GST) per DUNS Number request). Your D-U-N-S Number will be sent to you within 3 days from receipt of the request and payment confirmation. 61 Identification number: GPS details, GPS CO-ORDINATES (Global Positioning System) Which system (or datum)? Provide GPS co-ordinates as per the WGS 84 system (World Godetic System). Which unit should be used for GPS coordinates? Latitude (North or South) and longitude (East or West), preferably expressed in the SMF (Changes) SMF (Changes) Latitude (North or South) and longitude (East or West), preferably expressed in the format: DD MM SS,S (Degrees Minutes Seconds to 1 decimal place). Alternatively the latitude and longitude may be expressed in Degrees to at least 5 decimal places or Degrees Minutes to at least 3 decimal places. 62 Identification number: GPS details, Which location? Co-ordinates should preferably identify the main entrance of the manufacturing site involved in the production . If the location for which the co-ordinates are given is not the main entrance, this should be specified clearly in the application form. How to measure/obtain GPS coordinates? SMF (Changes) SMF (Changes) How to measure/obtain GPS coordinates? Preferably, use a GPS device, calibrated with the units and system mentioned above. or Use Google Earth to identify the site entrance and copy the co-ordinates displayed in the lower part of the map, with the format of the units and system mentioned above. 63 Identification number: DUNS (Data Universal Numbering System) GPS details, Other geographic location system PIC/S Foot note: 1 : A D-U-N-S reference is required for Site Master Files submitted to EU/EEA authorities for manufacturing sites located outside of the EU/EEA. SMF (Changes) SMF (Changes) Notes: EDQM -- Since 15 April 2011, applicants for new certificates of suitability (CEP) or revisions of CEPs are requested to provide information in the application form to better identify the location of their manufacturing site(s). These additional data are GPS co-ordinates, and (if available) a DUNS number. (i.e. Providing the DUNS number is not mandatory in the framework of the submission of a CEP dossier). 64 1.2 Authorised pharmaceutical manufacturing activities of the site. - .. - - - List of GMP inspections of the site within the last 5 years; including dates and name/country of the Competent Authority having performed the inspection. A copy of current GMP certificate (Appendix 3) or reference to the EudraGMP database should be included, if available. SMF (Changes) SMF (Changes) 2. QUALITY MANAGEMENT SYSTEM OF THE COMPANY 2.1 Description of the quality management system of the company Provide information on quality management systems, maintenance of the systems and senior management responsibilities Provide reference to the relevant standards (i.e. ISO, ICH) Provide information of accredited and certified activities carried out by the company 65 SMF (Changes) 2. QUALITY MANAGEMENT SYSTEM OF THE COMPANY (Conti) 2.2. Release procedure of finished products - Detailed description of qualification requirements (education and work experience) of the Authorised Person(s) / Qualified Person(s) responsible for batch certification and releasing procedures; - General description of batch certification and releasing procedure; - Role of Authorised Person / Qualified Person in quarantine and release of finished products and in assessment of compliance with the Marketing Authorisation; - The arrangements between Authorised Persons / Qualified Persons when several Authorised Persons / Qualified Persons are involved; - Statement on whether the control strategy employs Process Analytical Technology (PAT) and/or Real Time Release or Parametric Release. 66 2.3 Management of suppliers and contractors - A brief summary of the establishment/knowledge of supply chain and the external audit program; - Brief description of the qualification system of contractors, manufacturers of active pharmaceutical ingredients (API) and other critical materials suppliers; - Measures taken to ensure that products manufactured are compliant with TSE (Transmitting animal spongiform encephalopathy) guidelines. - Measures adopted where counterfeit/falsified products, bulk products, active pharmaceutical ingredients or excipients are identified; SMF (Changes) SMF (Changes) pharmaceutical ingredients or excipients are identified; - Use of outside scientific, analytical or other technical assistance in relation to manufacture and analysis; - List of contract manufacturers and laboratories including the addresses and contact information and flow charts of supply-chains for outsourced manufacturing and Quality Control activities; e.g. sterilisation of primary packaging material for aseptic processes, testing of starting raw materials etc, should be presented in Appendix 4; - Brief overview of the responsibility sharing between the contract giver and acceptor with respect to compliance with the Marketing Authorisation (where not included under 2.2). 67 2. QUALITY MANAGEMENT SYSTEM OF THE COMPANY (Conti) 2.4 Quality Risk Management (QRM) - Brief description of QRM methodologies used by the manufacturer; - Scope and focus of QRM including brief description of any activities which are performed at corporate level, and those which are performed locally. Any SMF (Changes) SMF (Changes) performed at corporate level, and those which are performed locally. Any application of the QRM system to assess continuity of supply should be mentioned. 2.5 Product Quality Reviews - Brief description of methodologies used 68 4. PREMISES AND EQUIPMENT 4.1 Premises - Short description of plant; size of the site and list of buildings. If the production for different markets, i.e. for local, EU, USA, etc. takes place in different buildings on the site, the buildings should be listed with destined markets identified (if not identified under 1.1); - Simple plan or description of manufacturing areas with indication of scale (architectural or engineering drawings are not required); - Lay outs and flow charts of the production areas (in Appendix 6) showing the room SMF (Changes) SMF (Changes) - Lay outs and flow charts of the production areas (in Appendix 6) showing the room classification and pressure differentials between adjoining areas and indicating the production activities (i.e. compounding, filling, storage, packaging, etc.) in the rooms; - Lay-outs of warehouses and storage areas, with special areas for the storage and handling of highly toxic, hazardous and sensitising materials indicated, if applicable; - Brief description of specific storage conditions if applicable, but not indicated on the lay-outs. 69 4.2.3 GMP critical computerised systems - Description of GMP critical computerised systems (excluding equipment specific Programmable Logic Controllers (PLCs). 5. DOCUMENTATION SMF (Changes) SMF (Changes) - Description of documentation system (i.e. electronic, manual); - When documents and records are stored or archived off-site (including pharmacovigilance data, when applicable): List of types of documents/records; Name and address of storage site and an estimate of time required retrieving documents from the off-site archive. 70 6. PRODUCTION 6.1. Type of products (references to Appendix 1 or 2 can be made): - Type of products manufactured including list of dosage forms of both human and veterinary products which are manufactured on the site list of dosage forms of investigational medicinal products (IMP) manufactured for any clinical trials on the site, and when different from the SMF (Changes) SMF (Changes) manufactured for any clinical trials on the site, and when different from the commercial manufacturing, information of production areas and personnel - Toxic or hazardous substances handled (e.g. with high pharmacological activity and/or with sensitising properties); - Product types manufactured in a dedicated facility or on a campaign basis, if applicable; - Process Analytical Technology (PAT) applications, if applicable: general statement of the relevant technology, and associated computerised systems. 71 6.2 Process validation - Brief description of general policy for process validation; - Policy for reprocessing or reworking. 8. DISTRIBUTION, COMPLAINTS, PRODUCT DEFECTS AND RECALLS 8.1 Distribution (to the part under the responsibility of the manufacturer) - Types (wholesale licence holders, manufacturing licence holders, etc) and locations SMF (Changes) SMF (Changes) - Types (wholesale licence holders, manufacturing licence holders, etc) and locations (EU/EEA, USA, etc.) of the companies to which the products are shipped from the site; - Description of the system used to verify that each customer / recipient is legally entitled to receive medicinal products from the manufacturer; - Brief description of the system to ensure appropriate environmental conditions during transit, e.g. temperature monitoring/ control; - Arrangements for product distribution and methods by which product traceability is maintained; - Measures taken to prevent manufacturers products to fall in the illegal supply chain. 72 Appendices of Site Master Files Appendix 1 - Copy of valid manufacturing authorization Appendix 2 - List of products (dosage forms and/or APIs) manufactured including for dosage forms the INN- names of APIs used Appendix 3 - Copy of valid GMP Certificate Appendix 4 - Organizational charts Appendix 5 - Lay outs of production areas including process, equipment, waste and personnel flows Appendix 6 - Schematic drawings of water systems Appendix 7 - List of major production and laboratory equipment used indicating the frequency for re-qualification Appendix 8 - List of contractors including the addresses and contact information 73 Q & A Q & A 74 THANK YOU THANK YOU THANK YOU THANK YOU THANK YOU THANK YOU Together we will meet the challenges of the future 75 TOPIC: APPLICATION OF QUALITY RISK MANAGEMENT Good Manufacturing Practice for Medicinal Products Manufacturers Good Manufacturing Practice for Medicinal Products Manufacturers QUALITY RISK MANAGEMENT Presented by: Lai Weng Fai Acting Director / Senior GMP Auditor Licensing & Certification Branch (LCB) 15 February 2012 1 OUTLINE OF PRESENTATION OUTLINE OF PRESENTATION Quality Risk Management (QRM) Brief Background Implementing QRM Expectations Areas of Application - Examples Summary 2 QRM QRM Brief Background Brief Background tbc tbc Risk management has been part of the pharmaceutical industry for many years. GMP requirements are designed to address risk. o The holder of a manufacturing authorisation must ... ensure that medicinal products ... are fit for their intended use ... and do not place patients at risk due to inadequate safety, quality or efficacy. place patients at risk due to inadequate safety, quality or efficacy. [Chp 1, Principle] o The responsibilities placed on any one individual should not be so extensive as to present any risk to quality. [Chp 2 , Clause 2.1] o the specific GMP requirements for sterile products (PIC/S GMP Guide, Annex 1) are designed to mitigate the risk of sterility failure. 3 QRM QRM Brief Background Brief Background tbc tbc GMP specifies a risk based approach. o A risk assessment approach should be used to determine the scope and extent of validation [Annex 15, Principle]. o A risk analysis of the sterility assurance system focused on an evaluation of releasing non-sterilised products should be performed [Chp 17, Clause 3.7] performed [Chp 17, Clause 3.7] Specifications in pharmacopoeial monographs include tests for known potential contaminants. 4 QRM QRM Brief Background Brief Background PIC/S GMP Guide greater emphasis on formalising these processes and using formal risk management tools. From a GMP perspective, we are only concerned with risks associated with product quality (Purity, Identity, Potency, Safety, etc.) i.e., Quality Risk Management. Manufacturer is responsible for assessing risks to the medicinal products Manufacturer is responsible for assessing risks to the medicinal products and managing these risks to an acceptable level. 5 Implementing QRM Implementing QRM Expectations Expectations tbc tbc In the PIC/S GMP Guide (since 15 Jan 2009): Chapter 1 Quality Management [Principle] To achieve the quality objective reliably there must be a comprehensively designed and correctly implemented system of Quality Assurance incorporating Good Manufacturing Practice, Quality Control and Quality incorporating Good Manufacturing Practice, Quality Control and Quality Risk Management. It should be fully documented and its effectiveness monitored. The basic concepts of Quality Assurance, Good Manufacturing Practice, Quality Control and Quality Risk Management are inter-related. 6 Implementing QRM Implementing QRM Expectations Expectations tbc tbc In the PIC/S GMP Guide (since 15 Jan 2009): Chapter 1 Quality Management Quality Risk Management 1.5 Quality risk management is a systematic process for the assessment, control, communication and review of risks to the quality of the medicinal product. It can be applied both proactively and medicinal product. It can be applied both proactively and retrospectively. 7 1.6 The quality risk management system should ensure that: - the evaluation of the risk to quality is based on scientific knowledge, experience with the process and ultimately links to the protection of the patient; - the level of effort, formality and documentation of the quality risk management process is commensurate with the level of risk. Implementing QRM Implementing QRM Expectations Expectations tbc tbc Quality Risk Degree to which a set of inherent properties of a product, system or process fulfills requirements combination of the probability of occurrence of harm and 8 probability of occurrence of harm and the severity of that harm(to the patient) Systematic process for the assessment, control, communication and review of risks to the quality of the drug (medicinal) product across the product lifecycle. It can be applied both proactively and retrospectively. & Management QRM Implementing QRM Implementing QRM Expectations Expectations tbc tbc What do GMP auditors look out for? Written Policy/Procedure Various aspects of business operations where QRM will be applied. General approach to both planned and unplanned risk assessment. Methods to be used (commensurate with risk level). Methods to be used (commensurate with risk level). Implementation of QRM within companys QMS Relevant procedures updated & integrated with QMS. Formal methods defined (where applied). Training of staff involved in QRM activities. Involvement of senior management in the identification & implementation of QRM principles within the company. 9 Implementing QRM Implementing QRM Expectations Expectations tbc tbc Systematic Approach Local SOPs guide user into performing and documenting risk analysis. System of archival and on-going review of significant risk assessments used to justify operational activities, validations, etc. One-off risk assessments should be documented, approved and retained. retained. Evidence of proactive and retrospective risk assessments in place where required. 10 Implementing QRM Implementing QRM Expectations Expectations tbc tbc Outcomes of assessment Risk-based decisions are well informed, science-based and comprehensible, and taken by decision makers with appropriate competence & authority. Ultimate linkage to patient safety. Assumptions & supporting reasons properly documented. Assumptions & supporting reasons properly documented. Justifiable assessments Level of efforts/resources deployed in the QRM activity commensurate with the criticality of the identified problem. High potential risk more thorough evaluation & report. Low potential risk may be a one line justification. 11 Implementing QRM Implementing QRM Expectations Expectations tbc tbc QRM Issues Commonly Observed 1. Failure to apply/consider QRM 2. Inappropriate/incorrect application of QRM Inadequate or no assessment of impact on product quality/linkage to patient safety. patient safety. Lack of scientific evidence supporting decisions. Lack of process understanding and/or regulatory requirements. Review of assessments without systematic approach. Risk management used to justify a preconceived outcome. Invalid assumptions made to suit the preconceived outcome. Variable tolerance of risk inconsistent decision-making. 12 Implementing QRM Implementing QRM Expectations Expectations tbc tbc QRM Issues Commonly Observed In general, in a typical audit process: Auditors will review the QRM processes as part of the QMS section of the audit (e.g. product complaints, recalls, deviations, PQR, etc.). Auditors will be pragmatic regarding the level of scrutiny and degree of Auditors will be pragmatic regarding the level of scrutiny and degree of formality expected of the outcome of QRM exercise. Auditors will be flexible and ready to debate/accept outcome based on good science. If necessary, auditors may request company to produce a formal summary of the risk assessment, key decisions and conclusions, or take copies of complex assessments for further evaluation outside of the audit. 13 Implementing QRM Implementing QRM Expectations Expectations tbc tbc QRM Non-Conformities (NC) NCs will be categorised dependent on the significance of the findings, the activities undertaken by the manufacturer and the number of observations relating to the incorrect application of QRM. QRM-related NCs may be grouped with other QMS-related NCs (QRM is expected to be an integral part of the QMS). expected to be an integral part of the QMS). Major NC will generally be cited where the manufacturer is completely lacking a QRM system. Critical NCs may reference QRM where the risk assessments have inappropriately supported release of products that pose a threat to patient safety. 14 Implementing QRM Implementing QRM Expectations Expectations tbc tbc QRM Non-Conformities (NC) If the manufacturer has not undertaken an appropriate approach to implementing the new requirements, an NC will be reported and will usually be cited as an minor' NC against the relevant part of the GMP standard. Wherever companies demonstrate they are meeting the minimum Wherever companies demonstrate they are meeting the minimum expectations , no NC will be cited. 15 Areas of Application Areas of Application tbc tbc Risk Assessment Risk Analysis Risk Identification Initiate Quality Risk Management Process A General QRM Process Model 16 Team approach Risk Review R i s k C o m m u n i c a t i o n Risk Evaluation unacceptable Risk Control Risk Reduction Review Events Risk Acceptance Output / Result of the Quality Risk Management Process R i s k M a n a g e m e n t t o o l s Areas of Application Areas of Application tbc tbc Core Principles of Quality Risk Management: 1) Compliance with applicable laws. Risk assessment should be used to assess how to ensure compliance and to determine the resulting prioritization for action not for a decision regarding the need to fulfill applicable regulations or legal requirements. 2) Risk can only be effectively managed when it is identified, assessed, 2) Risk can only be effectively managed when it is identified, assessed, considered for further mitigation, and communicated. 4 stages of effective QRM process (risk assessment, risk control, risk communication & risk review). 3) All quality risk evaluations must be based on scientific and process- specific knowledge and ultimately linked primarily to the protection of the patient (Figure 1 next). 17 Areas of Application Areas of Application tbc tbc 18 Figure 1 Quality risk evaluation pyramid Areas of Application Areas of Application tbc tbc Core Principles of Quality Risk Management: 4) Effective risk management requires a sufficient understanding of the business, the potential impact of the risk, and ownership of the results of any risk-management assessment. 5) Risk assessment must take into account the probability of a negative event in combination with the severity of that event. in combination with the severity of that event. Definition of risk = Probability of occurrence of harmand severity of that harm 6) It is not necessary or appropriate to always use a formal risk-management process (e.g., standardized tools). use of informal risk management process (e.g. empirical assessment) is acceptable for less complex areas which have lower potential risk. 19 Areas of Application Areas of Application tbc tbc Risk assessment supporting tools: Determine the appropriate risk assessment tool/methodology A key early step in the execution of a risk analysis . No single best choice of risk assessment tool/methodology The selection based on: o the depth of analysis required o complexity of the subject risk of concern o the familiarity with the assessment tool Risk ranking and filtering and flowcharting most popular tools used for basic risk-assessment activities. 20 Areas of Application Areas of Application tbc tbc Risk assessment supporting tools: Failure Mode Effect Analysis (FMEA) appeared to be the most frequently used methodology for more advanced risk analysis. Often a combination of various tools may be required to facilitate risk assessment. assessment. 21 PIC/S GMP Guide Annex 20 on Quality Risk Management Appendix 1 Risk Management Methods & Tools Not an exhaustive list. 1) Basic Risk Management Facilitation Methods 2) Failure Mode effects Analysis (FMEA) Areas of Application Areas of Application tbc Common risk management tools Common risk management tools 22 2) Failure Mode effects Analysis (FMEA) 3) Failure Mode, Effects & criticality Analysis (FMECA) 4) Fault Tree Analysis (FTA) 5) Hazard Analysis & Critical Control Points (HACCP) 6) Hazard Operability Analysis (HAZOP) 7) Preliminary Hazard Analysis (PHA) 8) Risk Ranking & Filtering 9) Supporting Statistical Tools Areas of Application Areas of Application tbc tbc Common risk management tools Common risk management tools 23 Areas of Application Areas of Application tbc tbc Severity categorization Severity categorization an e.g. an e.g. 24 Areas of Application Areas of Application tbc tbc Some Examples 25 Some Examples [1] Equipment Replacements [1] Equipment Replacements Functional Equivalence Functional Equivalence tbc Background Obligation to ensure that manufacturing equipment is properly designed, installed, tested, operated, and maintained throughout their service lifetimes. Manufacturing equipment will likely require both preventive and corrective maintenance activities that may involve the replacement of corrective maintenance activities that may involve the replacement of parts within the systems. Appropriate change controls to be applied to parts replacements ensure that manufacturing equipment remains in a validated state. If replacement parts are exactly identical to the original parts little issue with change control considerations. 26 [1] Equipment Replacements [1] Equipment Replacements Functional Equivalence Functional Equivalence tbc However, it is not uncommon for procuring and installing replacement parts that are not identical to the original parts. due to changes affected by parts suppliers (e.g., product re-designs, discontinuations). A risk-management approach used to assess whether replacement parts are functionally equivalent (i.e., like-for- whether replacement parts are functionally equivalent (i.e., like-for- like) with original parts ensure proper change control while also preventing unnecessary revalidation activities. 27 [1] Equipment Replacements [1] Equipment Replacements Functional Equivalence Functional Equivalence tbc In this case study, a risk-management approach was taken by the manufacturer to identify the following: Risks associated with equipment parts changes that might adversely impact the validated state of manufacturing equipment Risks associated with the process of determining whether original and replacement parts are functionally equivalent replacement parts are functionally equivalent Proper roles and responsibilities of the team of SME involved What are the outputs? A generic, robust, and repeatable process for performing functional-equivalence assessments. Define organizational roles and responsibilities supporting the process. 28 [1] Equipment Replacements [1] Equipment Replacements Functional Equivalence Functional Equivalence tbc Risk Question & Risk Assessment Method Risk question: Who should be involved to assess whether replacement parts are functionally equivalent with original parts? Company chooses to develop one risk assessment model for overall Company chooses to develop one risk assessment model for overall (generic) assessment of functional equivalence to achieve these aims: Identify potential gaps, inconsistencies, and redundancies within the process that had historically been used for replacement parts functional equivalence determinations. Identify new or improved activities. 29 [1] Equipment Replacements [1] Equipment Replacements Functional Equivalence Functional Equivalence tbc Risk Question & Risk Assessment Method The team examined the risk question and core activities involved in the historical functional equivalence assessment process. Identified the following observations: Functional equivalence assessment process was historically dependent upon human judgment, expertise, and experience. upon human judgment, expertise, and experience. Process risks (e.g., potential breakdowns of the process) were qualitative in nature and difficult to quantify with specificity. Risk assessment team selected Fault Tree Analysis (FTA) as risk assessment method. FTA is well suited for analysis of qualitative fault conditions that may be related to human performance factors. 30 [1] Equipment Replacements [1] Equipment Replacements Functional Equivalence Functional Equivalence tbc Risk Identification, Analysis & Evaluation The risk assessment process involved a review and analysis of the change control system to determine how equipment parts replacements could potentially cause unwanted or undetected change to the equipment's validated state. state. The analysis was organized into the fault tree structure (Figure 1 next). 31 [1] Equipment Replacements [1] Equipment Replacements Functional Equivalence Functional Equivalence tbc Figure 1 Fault Tree Analysis [Equipment changes & validation impact] 32 [1] Equipment Replacements [1] Equipment Replacements Functional Equivalence Functional Equivalence tbc Figure 1 Fault Tree Analysis Figure 2 Fault Tree Analysis [Functional equivalence assessment] 33 [1] Equipment Replacements [1] Equipment Replacements Functional Equivalence Functional Equivalence tbc Risk Control For each of the 2 areas of significant risk identified in the FTAs, associated risk control plans were established, as follows: Training curricula were created to define the training and qualification criteria for personnel initiating functional equivalence assessments. Roles and responsibilities for each functional area participating in Roles and responsibilities for each functional area participating in functional equivalence assessments were elaborated in the form of executable checklists . thorough and consistent assessment to be done. 34 [1] Equipment Replacements [1] Equipment Replacements Functional Equivalence Functional Equivalence tbc Risk Control This approach resulted in: Minimising both gaps and redundancies in the assessment efforts Creating a common assessment record format to facilitate overall review of the assessment package Functional area checklist details unique areas of consideration for the Functional area checklist details unique areas of consideration for the assessment and with assessment conclusions and signatures of the assessor(s). Example of a checklist from Engineering function at Table 1 (see next). 35 [1] Equipment Replacements [1] Equipment Replacements Functional Equivalence Functional Equivalence tbc Table 1 Checklist template 36 [1] Equipment Replacements [1] Equipment Replacements Functional Equivalence Functional Equivalence tbc Risk Documentation & Communication The outputs of this risk management effort comprise the documented justification for revisions to the quality system documents: Training and qualification curricula for personnel initiating change controls where functional-equivalence will be assessed Equipment change control standard operating procedures on the Equipment change control standard operating procedures on the functional equivalence assessment process for parts replacements Maintenance systems inventory process control flow. Training is required to be performed on these updated documents and training records are periodically audited for compliance. 37 [1] Equipment Replacements [1] Equipment Replacements Functional Equivalence Functional Equivalence Risk Review Routine internal audits and document reviews are performed throughout each of the functions impacted by this risk assessment (i.e., training, change control, and equipment maintenance). Adverse findings or trends identified during these audits/reviews provide indication whether the risk assessment needs to be revised or provide indication whether the risk assessment needs to be revised or fine tuned. 38 [2] Process Deviation [2] Process Deviation Empty Product Capsules Empty Product Capsules tbc Background A finished product manufacturer produces pain-free capsules, which are indicated as an anti-epileptic and for treatment of neuropathic pain. Multiple customer complaints of empty capsules were received. Lot ABC was fully distributed in the market and no stock of the affected batch remains within company control. affected batch remains within company control. There is no evidence of product tampering. Batch record review indicated that during processing, a loose dosator was replaced on the encapsulation equipment. Following replacement and prior to resuming encapsulation,: perform acceptance testing of capsules (as per SOP) product met requirements. 39 [2] Process Deviation [2] Process Deviation Empty Product Capsules Empty Product Capsules tbc Background Further investigation revealed that the loose dosator caused empty capsules to be produced. This empty capsule removal system includes a reservoir for holding empty capsules rejected during the manufacturing process. Loose dosator atypically high number of reject empty/low fill Loose dosator atypically high number of reject empty/low fill capsules were produced overflowing of holding reservoir. The reservoir was physically located over the acceptable capsule flow. Holding reservoir overflowed potential for rejected capsules to fall back into the acceptable capsule exit chute re-introduced to the lot. 40 [2] Process Deviation [2] Process Deviation Empty Product Capsules Empty Product Capsules tbc Risk Question & Risk Assessment Method Risk Question: Do a small number of potential low fill or empty capsules in a single batch of product pose an unacceptable risk to patients, and secondarily, to the company? In this case study, the risk factors are more qualitative than quantitative. In this case study, the risk factors are more qualitative than quantitative. Failure Mode Effects Analysis (FMEA) is specifically designed to systematically study processes for possible failure modes and then to develop actions to mitigate these failure modes. Need to consider additional element detectability of the defect. Is it possible for the pharmacist or the patient to readily detect empty capsules? 41 [2] Process Deviation [2] Process Deviation Empty Product Capsules Empty Product Capsules tbc Risk Question & Risk Assessment Method The FMEA technique is an optimal tool for this application as this standard methodology includes all three risk components (i.e., probability, severity, and detectability). Hence, the risk methodology selected for the subject case study is: FMEA. 42 [2] Process Deviation [2] Process Deviation Empty Product Capsules Empty Product Capsules tbc Risk Identification, Analysis & Evaluation FMEA process involves the identification of potential risks that could be caused by empty capsules in the market & possible consequences of each risk. sufficient data may not always be available risk identification based on best available data, scientific knowledge risk identification based on best available data, scientific knowledge and historical experience Examples of potential risks: patients may receive empty capsules, product supply shortage audit observation from internal auditor/regulatory authority etc. 43 [2] Process Deviation [2] Process Deviation Empty Product Capsules Empty Product Capsules tbc Risk Identification, Analysis & Evaluation Numerical ratings for the FMA analysis are based on the following criteria: 1) Severity of the failure 2) Frequency of the failure 3) Ability to detect the parameter A numerical ranking of 13 is applied to each evaluated hazard, as demonstrated in the example FMEA risk-score ranking table using a three- point ranking scale (Table 1 next). 44 [2] Process Deviation [2] Process Deviation Empty Product Capsules Empty Product Capsules tbc Table 1 45 [2] Process Deviation [2] Process Deviation Empty Product Capsules Empty Product Capsules tbc Risk Identification, Analysis & Evaluation In the FMEA analysis, the company determined: If risk evaluation score moderate or greater appropriate risk mitigating actions required to lower the risk to an acceptable level. if the score for an evaluated hazard > 9 corrective measures to the reduce risk of failure will be taken. reduce risk of failure will be taken. If after attempting risk mitigation, the score could not be lowered below 9, the resulting risk would not be accepted. For those items with a score below the defined threshold, risks will be accepted. Conclusions are documented. An example worksheet for calculating the Risk Evaluation Score for this analysis is presented in Table 2 (next). 46 [2] Process Deviation [2] Process Deviation Empty Product Capsules Empty Product Capsules tbc Table 2 47 [2] Process Deviation [2] Process Deviation Empty Product Capsules Empty Product Capsules tbc Risk Control Risk reduction and acceptance decisions focused on patient safety. Despite the apparently low number of empty/low fill capsules that may be present, there was no assurance that the numbers of empty capsules in the market was low. Capsule shell is opaque a pharmacist or patient unable to detect an Capsule shell is opaque a pharmacist or patient unable to detect an empty or partially filled capsule readily. 48 [2] Process Deviation [2] Process Deviation Empty Product Capsules Empty Product Capsules tbc Risk Control Most importantly, the potential medical consequence for some patients due to receiving and administering an empty or partially filled capsule was severe. As a result of the potentially high risk associated with some patients taking empty/low-fill capsules, and the inability of the company to implement empty/low-fill capsules, and the inability of the company to implement appropriate risk mitigating actions to lower this risk (i.e., severity and ability to detect) to an acceptable level, the decision was taken to initiate a product recall. 49 [2] Process Deviation [2] Process Deviation Empty Product Capsules Empty Product Capsules tbc Risk Documentation & Communication Site procedures require preparation and Quality division endorsement of a deviation report. The risk assessment output was incorporated into a number of existing work processes and their associated documentation. To prevent re-introduction of rejected product to the product, an To prevent re-introduction of rejected product to the product, an automated sensor was incorporated into the empty capsule reject reservoir. When activated, this sensor automatically shuts down the encapsulation machine should rejected capsules in the reservoir reach the sensor level, thereby preventing overflow. The overflow sensor with automated equipment shutdown was applied to all encapsulation machines at the firm. 50 [2] Process Deviation [2] Process Deviation Empty Product Capsules Empty Product Capsules Risk Documentation & Communication Additionally, the results of the FEMA analysis and recommendation for product recall were presented at an internal management meeting : Minutes of risk analysis and associated conclusions were documented. Affected regulatory agencies were formally notified of the recall decision. decision. Risk Review & Conclusion To gain additional understanding of the extent of the defect that reached the market through: Evaluation of product complaints. Adverse event reports. Further examination of product received from the product recall. 51 [3] [3] GMP Self GMP Self- -Inspection Inspection tbc Background Formal self-inspection - an integral part of an effective quality system in a GMP-compliant pharmaceutical manufacturing facility. Involved periodic internal audits of site operations (e.g., quality, manufacturing, engineering, logistics) and associated systems with potential GMP impact. potential GMP impact. Overall administration of the internal audit program is the responsibility of the quality control (QC) unit. The QC unit is responsible to identify the focus, frequency and resources to support the internal audits as well as to determine the effectiveness of the conducted audits. Internal audits are typically conducted according to a predetermined schedule and on a regular basis. 52 [3] [3] GMP Self GMP Self- -Inspection Inspection tbc Background The manufacturing site is a diverse finished product facility. Ideally, the site would be able to perform internal audits of all site operations and systems within a given calendar year but not always easy to do so. One potential approach to administer an effective internal audit system is One potential approach to administer an effective internal audit system is to determine audit frequency based upon the criticality of the various operations. The site maintains a list of current operations and also periodically reviews and understands the performance of these operations and associated systems. The companys management recognizes that there are certain internal systems that could benefit from additional attention. 53 [3] [3] GMP Self GMP Self- -Inspection Inspection tbc Background Site management wants to ensure that resources are applied to those operations having the highest potential for GMP impact. Use of quality risk management (QRM) as a tool to effectively prioritise a and allocate resources for internal audits of various functional areas. 54 [3] [3] GMP Self GMP Self- -Inspection Inspection tbc Risk Question & Risk Assessment Method Risk Question: What is the optimal internal audit schedule to ensure that those operations and associated systems with the greatest potential impact on product quality and, therefore, potentially the patient, are audited on a more frequently than those determined to be less critical? more frequently than those determined to be less critical? An internal audit is a diverse activity with more qualitative characteristics than quantitative ones. Therefore, the selected risk assessment tool will produce a qualitative description of risk (e.g., high, medium, or low). An additional objective of the selected tool assist in the organization of data as the assessment moves to the next stage of the process. 55 [3] [3] GMP Self GMP Self- -Inspection Inspection tbc Risk Question & Risk Assessment Method The developed list of site operations and associated systems ensures identification of the potential risks. Hence, a complex risk assessment tool is not required. A simple tool that allows for qualitative analysis and evaluation is sufficient. Risk assessment methodology selected: Risk ranking and filtering. Risk assessment methodology selected: Risk ranking and filtering. 56 [3] [3] GMP Self GMP Self- -Inspection Inspection tbc Risk Identification & Analysis The site has prepared a master list identifying all operations and associated systems which have potential impact on product quality (Table 1 next). 57 [3] [3] GMP Self GMP Self- -Inspection Inspection tbc Table 1 Risk evaluation score 58 [3] [3] GMP Self GMP Self- -Inspection Inspection tbc Risk Identification & Analysis The risk analysis stage of the QRM process estimates the potential harm(s) associated with each potential risks. The analysis may be qualitative or quantitative in nature, or a combination of the two. The risk score will be determined by combining the probability/likelihood The risk score will be determined by combining the probability/likelihood of a problem in a given site operation and the outcome. The risk evaluation score is calculated as follows: (Probability Score Outcome Score) = Risk Evaluation Score Numerical value of 1, 2, or 3 is assigned to correspond with a low, medium, or high risk analysis determination, respectively. 59 [3] [3] GMP Self GMP Self- -Inspection Inspection tbc Risk Identification & Analysis The probability and outcome scores and subsequent risk evaluation scores for the selected operations are presented in Table I. If desired, the evaluation could be further modified to include consideration of the length of time since the last audit was performed. Formula for determining the risk evaluation score can be modified to Formula for determining the risk evaluation score can be modified to include the time since the last audit as follows: (Probability Score x Outcome Score) + (Years since last audit) = Risk Evaluation Score With application of QRM, the site is now able to better prioritize resource utilization to focus auditing efforts on those areas with the highest risk scores. 60 [3] [3] GMP Self GMP Self- -Inspection Inspection tbc Risk Control Risk is reduced by identifying site operations above a specific threshold score from the risk ranking, and scheduling internal audits for those operations. Inherent risk will be accepted for those site operations which are below that threshold. that threshold. For those operations, an internal audit will be deferred until audits have been completed for those operations with a higher risk ranking. 61 [3] [3] GMP Self GMP Self- -Inspection Inspection tbc Risk Review During development of annual schedule review the risk assessment process and assumptions made. The site will confirm that included operations/systems are still in use, remove those that are not and add any new operations/systems to the process. process. Examples of changes that may potentially impact risk of site operational systems include: changes to control systems changes to equipment and processes changes in suppliers/contractors organizational restructuring 62 [3] [3] GMP Self GMP Self- -Inspection Inspection tbc Risk Documentation & Communication Communication of the utilized QRM process should include all key stakeholders of the affected departments to ensure organizational buy-in and support. Documentation needed and endorsed by site Quality Unit: Output of QRM process Output of QRM process The audit schedule Associated risk analysis justifying the approach Effective communication to stakeholders. 63 Summary Summary tbc The concept of QRM is not necessarily new to pharmaceutical manufacturers and inspectors in GMP environments. But there is a greater emphasis now on adopting more formalised approaches to QRM. Effective QRM facilitates better and more informed decisions, and provide regulators with greater assurance of a companys ability to deal with potential risks. potential risks. The degree of rigor and formality of QRM should reflect available knowledge and be commensurate with the complexity and/or criticality of the issue to be addressed. When integrated in quality systems, QRM is intended to enable and enhance compliance with regulatory requirements and science-based decisions. If QRM is done properly, there should be increased assurance of quality (and possibly cost savings). 64 Summary Summary The QRM process should not be used as an excuse to delay or avoid compliance gaps/issues or complying with regulatory requirements. There is no one size fits all risk management methods for all application areas. Manufacturer is responsible for identifying areas of application, identifying risk to product quality and managing that risk. identifying risk to product quality and managing that risk. QRM will be reviewed at each GMP audit. Auditors will be flexible and ready to debate/accept outcome based on good science. 65 Further Reading Further Reading T. Frank et al., Pharm. Technol. 35 (7), (8), (10), (12) 2011 PIC/S Guide to GMP (PE 009-9) & Annex 20 (www.picscheme.org) QRM Implementation of ICH Q9 in the pharmaceutical field, PS/INF 1/2010 Application of hazard analysis and critical control point (HACCP) methodology to pharmaceuticals, Quality assurance of pharmaceuticals. methodology to pharmaceuticals, Quality assurance of pharmaceuticals. A compendium of guidelines and related materials. Vol. 2, 2 nd updated edition. Good manufacturing practices and inspection. Geneva, WHO, 2007. ICH Q9 Briefing Pack (www.ich.org) ICH Q8/Q9/Q10 Training Material (www.ich.org) www. tga.gov.au www.mhra.gov.uk 66 Thank you for your attention! Thank you for your attention! 67
HPRG JOINT REGULATORY WORKSHOP Year: 2012 Case Study Review of a Quality System Procedure
INTRODUCTION: THE COMPANY PTE LTD is a local manufacturer of a range of western pharmaceutical products in various finished dosage forms and is in the midst of conducting its routine self inspection. You are one of the auditors in the inspection team and you are provided with a copy of the supplier qualification procedure 1 for review. (Please refer to your workshop folder for the copy.)
TASK: Review the SOP and i) identify (by circling it) the possible non-conformities against the PIC/S GMP Guide and ii) Identify areas for improvement (if any). Please note that the associated documents and forms related to the SOP are not needed to complete this case study.
OUTCOME OF SOP REVIEW: The outcome of the review will be presented at the end of the case study.
1 The content of this document, including the name of the company and name of the signatories are fictitious and is written for the purpose of this workshop. Any resemblance to actual names or scenario should be deemed as mere coincidence.
THE COMPANY PTE LTD
Title: RAW MATERIAL SUPPLIER ASSESSMENT, APPROVAL AND MONITORING
1.0 PURPOSE Procedure to approve suppliers of Raw Materials (including primary packaging material) for production use in accordance with the current GMP requirements for finished pharmaceutical products. Note: References to Raw Materials throughout this procedure include primary packaging materials.
2.0 RESPONSIBILITY 2.1 Quality Assurance (QA) is responsible for: 2.1.1 Implementation of the procedure. 2.1.2 Review of all supplier approval documentation to ensure it is in compliance with this procedure, GMP requirements and that only supplier that are capable of supplying materials which meet THE COMPANY PTE LTD requirements are approved. 2.1.3 Maintenance of regulatory filings and notifications as a result of new/changed suppliers. 2.1.4 Assessment of impact of changes to THE COMPANY PTE LTD products and notification where deemed necessary.
2.2 Supply Chain (SC) is responsible for: 2.2.1 Implementation of the procedure. 2.2.2 Maintaining the Approved Suppliers List. 2.2.3 Ensuring that materials are ordered from approved suppliers 2.2.4 Serve as primary contact and coordinator with suppliers.
2.3 Quality Control (QC) is responsible for: 2.3.1 Implementation of the procedure. 2.3.2 Ensuring that analysis of samples is performed as per documented procedures and that results are submitted for filing as per this procedure. 3.0 SCOPE The procedure provides for approving of all suppliers of Raw Materials for THE COMPANY PTE LTD manufacturing facility.
THE COMPANY PTE LTD
Title: RAW MATERIAL SUPPLIER ASSESSMENT, APPROVAL AND MONITORING
Approved supplier A supplier which is fully approved for the supply of Raw Materials for production use. Non manufacturing material A material or item that is not used in the manufacturing process but is used in some ancillary capacity where there is no direct product contact e.g. boiler salt, battery acid, sodium hypochlorite. Critical raw material A raw material which is the active ingredient of a product or which has major impact on formulation of the product as categorized by SC. Primary Packaging Materials Packaging that is intended to be in direct contract with the product.
5.0 PROCEDURE RAW MATERIALS SUPPLIERS 5.1 The need for a new supplier and/or material is identified by the department using the material or SC. In the case of new product development, process development, new product support or research and development, material must be at a minimum provisionally qualified before it is going to be used in manufacturing.
5.2 SC will identify potential suppliers and will initiate initial discussions regarding pricing, raw material and service requirements. As part of this, SC will confirm the suppliers ability to provide material meeting THE COMPANY PTE LTD requirements by either: 5.2.1 Forwarding a copy of the THE COMPANY PTE LTD specifications and requirements for the material to the supplier for confirmation they can supply to those requirements and/or 5.2.2 Request copy of the suppliers specification for the material being evaluated, this will be reviewed internally at THE COMPANY PTE LTD to confirm it meets requirements.
5.3 If the supplier is an existing approved supplier of other Raw Materials, SC & QA will determine and document if existing questionnaires or scope of supply cover the new material and can be applied to the new approval.
5.4 If deemed necessary above, SC submits questionnaire to the prospective supplier for completion area.
5.5 SC will request any samples of material required. 5.5.1 Non-Critical Raw Materials - Three samples from three different lots of material (min 30g each). 5.5.2 Critical Raw Materials Three samples from three different lots of material (min 150g each).
THE COMPANY PTE LTD
Title: RAW MATERIAL SUPPLIER ASSESSMENT, APPROVAL AND MONITORING
NOTE: In exceptional circumstances, if the supplier cannot provide 3 samples from 3 different batches, this will be assessed with QA and a risk assessment performed to develop a rationale for alternative sample submission requirements. This must be reviewed and approved by Site Director and QA.
5.7 Samples received are submitted to QC for testing with the Supplier Approval Sheet with section 1 completed.
5.8 QC Analysis of Raw Materials 5.8.1 Each sample is assigned the next sequential QC number and detail of the sample recorded in the QC number register. The QC number of each sample and the corresponding suppliers lot number must be recorded on the Supplier Approval Sheet. 5.8.2 Samples are analyzed as per the current version of the relevant monograph. If there is no current monograph available, testing is performed per the suppliers specification/certificate of analysis. The completed analysis requisition is reviewed by the QC supervisor. 5.8.3 On completion of QC testing, all critical Raw Materials must be Use-tested. For non-critical Raw Materials, QC Management may decide that further analysis or Use testing is required. 5.8.4 Where Use testing is required, the sample will be submitted to the R&D Dept accompanied by a Use Test Request Sheet (QAD-025). 5.8.5 The R&D Dept will submit the product formulated from the material to the QC Dept accompanied by the completed Use Test Request sheet recommending material acceptance or otherwise. 5.8.6 The completed analysis requisition and Use test sheet is reviewed by the QC department. 5.8.7 On completing QC analysis of the Use test, QC Management fills Section 2 of the Supplier Approval Sheet. 5.9 An on-site audit is not mandatory, the need for an on-site audit will be determined based on risk factors such as intended use of the material, criticality of the Raw Material and other risks as deemed appropriate. This will be documented on the supplier approval form. Audit is normally carried out by the Marketing Department.
5.10 For suppliers of critical Raw Materials, an on-site audit is always recommended. 5.10.1 If an audit is recommended but cannot be performed within the timeframe that the material is required, the supplier may be approved once the audit has been added to the supplier audit schedule subject to all other requirements for supplier approval have been completed and are satisfactory. This will be justified and documented on the supplier approval form.
5.11 If the review of QC and Use testing is acceptable, then the supplier is approved. THE COMPANY PTE LTD
Title: RAW MATERIAL SUPPLIER ASSESSMENT, APPROVAL AND MONITORING
5.12 If the review of QC and Use testing concludes that the supplier cannot be approved then a determination will be made as to whether continue with this supplier and work with them to determine the reason for the failure and correct it or to find another supplier.
5.14 If the supplier is deemed acceptable, the paperwork is completed and the Approved Suppliers List updated by SC. Completed documentation is filed as per documentation section below. Orders may be placed with the supplier for approved products. SC will issue an MSDS for new Raw Materials to Safety (as necessary) who in turn will circulate it to all relevant functional areas.
NOTE: For non-manufacturing material which has no product contact, detailed testing and evaluation is not required.
6.0 SUPPLIER MONITORING
6.1 Problems with suppliers subsequent to approval must immediately be brought to the attention of QA and SC by raising the Material Feedback Sheet (QAD-188)
6.2 SC will communicate these to the supplier and will request a written response.
6.3 The response will be reviewed by QA and SC for acceptability. Further clarification/corrective action will be requested if deemed necessary.
6.4 If the response remains unsatisfactory, the supplier maybe removed from the Approved Suppliers List
6.5 On an annual basis, suppliers of critical Raw Materials will be contacted to identify any changes to their details which will have an impact on the goods they provide. 6.5.1 Audit or re-audit of existing suppliers may be performed if deemed warranted based on poor performance during the year or as part of the investigation of a material issue.
7.0 REGULATORY REQUIREMENTS
7.1 Where the supplier/manufacturer of a Raw material is changed, QA must assess the impact of this change on the quality of product manufactured. This assessment must be filed with the supplier approval documentation. 7.1.1 Where applicable a regulatory submission may be necessary to comply with regulatory requirements of the products registered. THE COMPANY PTE LTD
Title: RAW MATERIAL SUPPLIER ASSESSMENT, APPROVAL AND MONITORING
Supplier Approval Sheet (QAD-135) Supplier Assessment Questionnaire (QAD-162) Use Test Request Sheet (QAD-025) Service Supplier Qualification Sheet (QAD-194) Service Supplier Assessment Questionnaire (QAD-193) Approved Supplier List
Workshop 5 Workshop 5 Good Manufacturing Practice for Medicinal Products Manufacturers Good Manufacturing Practice for Medicinal Products Manufacturers CASE STUDY REVIEW OF A QUALITY SYSTEM PROCEDURE PROCEDURE Presented by: Ng Liong Thiam Dy Dir (GMPL Unit) Audit Branch (AB) Introduction Introduction A GMP case study on the review of a quality system procedure of a pharmaceutical manufacturer. Main purpose of case study is to encourage active participation and information sharing on the application of GMP principles. The quality system documents that we will be reviewing today is a procedure on supplier qualification. Give an overview on the aspect of supplier qualification Overview of Supplier Qualification Overview of Supplier Qualification Purchasing of starting material for production use important function involve staff with knowledge of the suppliers Starting material should only be purchased from approved suppliers named in the relevant specification. All aspects of requirements of the starting material is to be discussed with the suppliers: Specification Control and production aspects including handling Labeling and packaging requirement Approach taken for complaints and rejection Supply requirement Others Overview of Supplier Qualification Overview of Supplier Qualification Changes in supply of raw materials should be subject to a formalized change control process. The purchase, handling and control of primary and printed packaging material should be accorded attention similar to that given to starting materials. materials. Overview of Supplier Qualification Overview of Supplier Qualification Supplier qualification system and procedure(s) should be established Gathering information and identify potential suppliers Questionnaires Supplier records (if any) Others Assessing of suppliers including the material to be supplied QC testing Use testing Site inspections Review of track records (if applicable) Overview of Supplier Qualification Overview of Supplier Qualification Supplier qualification system and procedure(s) should be established (cont) Approving of suppliers review of assessment made e.g. testing report, audit report etc supply agreement (if applicable) formalize the approval/rejection process including the updating of approved supplier list Monitoring of suppliers document all transaction including supply problem, quality problem, and complaints follow-up on CAPA and complaint (if any) conduct periodic audit or re-audit (if necessary) updating of changes by supplier periodic review of qualification status Case Study Exercise Case Study Exercise Introduction Mocked up and written for the purpose of this workshop Local manufacturer in midst of conducting its self inspection and you are one of the internal auditors Task Task Review the SOP Identify possible non conformities against GMP Guide and Identify area for improvement (if any) SOP Review Given some time to review the SOP and discuss Associated documents and forms to the SOP are not required to complete the case study Outcome will be presented after the SOP review Review of Case Study Review of Case Study Approval section on page 1 inadequate there is no functional titles for the signatory Header section of page 1 - the effective date is earlier than the approved date which means SOP is effective before approval Paragraph 4 on Definition the term non-critical raw material was not defined (to differentiate it from the critical raw material) which will explain the rational for the difference in sampling requirement as mentioned in paragraph 5.5 between the two groups of material Paragraph 5.8 on QC Analysis is too detail for this procedure should be parked under the QC procedure (and put under responsibility of QC) Review of Case Study Review of Case Study Missing subsection: 5.6 and 5.13 Paragraph 5.9 Auditing by Marketing Department: In this case, the Marketing Department should have the adequate GMP training in order to assess effectively the supplier. As far as possible, QA should take part in the audit. take part in the audit. Paragraph 5.9 states that an audit is not mandatory and based on a number of risk factors however it fall short of giving guidance on risk factors when an on-site audit has to be performed Paragraph 5.10.1 the use of material before audit when it has been deemed necessary is an issue should be covered by applying risk minimisation factors such as additional sampling Review of Case Study Review of Case Study Paragraph 5.11 Supplier Approval reviewing only the QC report and Use testing report for approval not adequate. Should also include others like the questionnaire, the audit report, the previous track records (if any) etc. Any gap identified should be clarified and evaluated as to whether the approval process can proceed. approval process can proceed. Paragraph 5.14 & 6.4 states SC will update the supplier list such list should also be approved by QA who is the owner of this SOP. Review of Case Study Review of Case Study Supplier monitoring inadequate Paragraph 6.1 to 6.4 suggest monitoring for acceptability is only on problem area (if any) this should be more detailed to include other key performance indicators e.g. Supply track records, response to request etc Paragraph 6.5 - Changes to the supplier of critical raw material should be pre-notified by the supplier on their own accord in a timely manner for review and approval (if necessary) not only annually. Paragraph 6.5.1 - A maximum time interval between two audits should be determined for critical raw-material suppliers. Review of Case Study Review of Case Study Paragraph 8 on related documents section is inadequate: Approved Suppler List should be a controlled document with a unique document number (i.e. QAD number) Material Feedback Sheet (QAD-188) mentioned in paragraph 6.1 is not referenced under this section not referenced under this section Service supplier document (QAD-194 and QAD-193) not referred to in this SOP was listed here Missing reference essential to this SOP e.g. Change Control procedure, guidance documents on how to perform on-site audits Conclusion Conclusion The list of possible non-conformities and areas for improvement presented as the outcome of the case study in the previous slides is not to be taken as exhaustive. A copy of this presentation is available at the counter on your way out after the workshop session. way out after the workshop session. Thanks to the Steering Committee of the PIC/S Expert Circle on API for sharing a model of the case study presented during the 4 th Expert Circle Meeting on API held in Singapore in Oct 2011. THANK YOU THANK YOU