Beruflich Dokumente
Kultur Dokumente
Götz Harnischfeger
ICS-UNIDO Training course on: Development, quality assurance and regulatora aspects
ofherbal medicinal products; Panama City, Panama, 21. -25. November 2005
When manufacturing medicinal products in general and herbal medicinal products in
particularwith this GMP (good manufacturing procedure) outline in mind, the patient can be
assured of recieving a product of reliable strength unchanged from batch to batch with
continuously high quality and efficacy. Under this acronym GMP, defined as
that part of quality assurance which ensures that products are consistently produced and
controlled to the quality standards appropriate to their intended use and as required by the
Originally developed on a national and/or continental level, the GMP documents have been
harmonized and formally effected by the WHO to provide a suitable tool for certification,
government control and licensing in the international trade (1,2). The guidelines encompass
practically proven recommendations and procedures for controlling the manufacture of all
The basic requirements around which the GMP guidelines are formulated are depicted in the
table below.
pharmaceutical industry, in this case to the processing of herbal starting material and for the
adjoining manufacture of herbal medicinal products. The line separating these two is
sometimes difficult to draw, since intermediates in one case might, at the same time, in
another be finished pharmaceutical products. Examples are the herbal tea or the simple plant
tincture. GMP restricts itself not only to the manufacturing steps themselves but includes
starting materials, intermediates and the final product as well. The same general principles are
valid throughout.
To understand the general concept of GMP from a praxis-orientated point of view, it is
helpful to focus primarily on systems and sequences of the manufacturing steps with their
critical areas, assuming an inspectors way of assessing a process. Cross reference can then be
The evaluation for quality and safety levels aimed at by such assessment covers the
following:
etc.)
- the herbal product (intermediate and final) and ist compliance with the
risks
Implementing the GMP system might look difficult, since on first sight it appears that
enormous investments have to be made deterring from action. However, the monetary outlay
can be reduced considerably, if the approach to GMP starts with those aspects which cost
little or no money but require only some logic rethinking and physical effort. Starting with
these, it is amazing, how far one gets along on the path of GMP compliance.
General evaluation
In a first step a written check-list is prepared in order to identify and focus on critical aspects
helpful for analysing the final (marketed) product. The list might be organised in the
following way:
- the therapeutic use of the product, the primary and secondary active
components, if known
environmental conditions
- labeling requirements
This frame of reference establishes an outline for a more detailed analysis. Thus with high
probability all the necessary parameters important for pharmaceutical quality are defined and
covered.
As mentioned, the general set of rules had to be annexed to take care of specific problems in
latter has formalised the use of GMP to such an extend, that the basic issue is hardly
It has to be recognised, that herbal medicinal products have no special status in GMP. Most
of the rules for the various aspects shown before apply to them as well. There are, however,
some peculiarities in the complex of production and quality control. A general outline of these
The basic requirements for GMP are outlined in figure 2. Some comments in the light of my
It is a necessity, that the manufacturing process is invariable, giving fixed target parameters
Since the quality of every batch of raw material (plant drugs) varies, an equalizing step
It has an advantage, if the product batch is quarantained after every step in its manufacture
and resumption of processing should only continue, if an analysis at the control laboratory has
The main focus of a manufacturer has to rest on an exactly specified quality (acceptance
quality) of the herbal starting material, i.e. its identity, purity, content of active substance or
marker, micro-bioburden, specified technical parameters etc., which has to belaid out in a
pharmacopoiea type monograph. Since by its very nature the quality of every batch of herbal
starting material varies within a certain range, an equalizing step should be applied and
looked for at the earliest possible occasion. The process and target specification should be
A critical variable is the bioburden of the herbal material. A validated method of reduction
The acceptance quality of excipients and solvents should be similarly specified in writing.
processing protocols should be available for every batch recieved (4,5). This has been dealt
with previously.
the compliance with the required quality. To underscore the importance of quality control and
adequate acceptance criteria for herbal drugs, it is worthwhile to know, that a large percentage
Another point of importance is the storage of the various materials. For this purpose an annex
to the WHO-GMP (4) and also a special GMP, Good Storage Practice (7) has been enacted.
These special requirements for herbal products adress mostly concerns with dust as carrier of
microbial contamination.
However, most of the microbes are no hazard to human health. Testing for guiding types of
>23% their quantity will decrease by several orders of magnitude. However, if water is used
as extraction solvent, microbes on the herbal starting material certainly constitute a problem.
In this case, dust should be kept at a minimum. In general, it is advisable to have dust
Evaluation: processing
The GMP for ”Active Pharmaceutical Ingredients” (APIs) of EMEA (6) defines the border
line separating the processes where the strict rules of GMP strictly apply from those where
they are only advisable. In herbal medicinal products, GMP starts after the initial extraction
step (fig.4 ).
Process evaluation
The critical step: a ”critical” step is a matter of definition. It usually is reserved for process
concerned with the safety of the finished product, e.g. pyrogenicity and purity in sterile
products, where special sets of parameters have to be kept. In the normal manufacturing of
phytomedicines, e.g. making of tinctures and extracts, the conditions can, as a rule, be
classified as uncritical
The processes: The best way to proceed with process evaluation according to GMP is by
using a flow diagram, which breaks down the respective manufacturing process into
individual, single steps (example given in fig. 5). Every single step has to be carefully
do not need to be validated, as long as the DEV ratio and the nature of the solvent are fixed.
However, the many parameters influencing extraction (fig.6) have to be specified. This is also
valid for the related procedure of steam destillation, a technology used mostly for the
production of essential oils (fig.7). The figure gives a simple scheme together with the
On the other hand, vaguely described processes, like the example of ”stir frying” of the
Pharm. Sin. Given in the following scheme have to be evaluated in more detail (fig.8).
The next step in process evaluation is a close look at all the manufacturing steps as a system,
i.e. as an integrated sum of individual manufacturing procedures. From this one can deduce:
It is expensive to perform all necessary monitoring procedures ona batch to batch base. In
order to cut down on the amount of analytical effort, the constant parts of manufacturing ( as
well as the afore mentioned routine analytical methods ) have to be validated. This is done
following a stringent procedure, to make sure that especially critical steps within a process are
properly controlled. The following figure (fig. 9 ) is an outline of the points which have to be
The entire processing has to be transparent, not only by SOPs and validation documents but
The formal makeup of an SOP will be treated in short. It is outlined in fig. 10.
It is advisable to formulate the SOP in a ”step by step” way, with room for remarks and
signatures of the operator. In this way, a copy of the SOP can be used as documented batch
protocol.
Operators should undergo training at least every quarter, especially in hygiene and safety
awareness (see below). Faulty operating of machinery should be discussed within the working
crew and remedies should be proposed. The supervisor present should write areport signed by
everybody present.
cond.)
SOPs and advice for all these aspects have to be laid down in writing. Floor plans showing
the locations of power lines, water and sewer installations, air condition layout and locations
of hazard fighting equipment should be present. Important is an alarm plan and its regular
update.
In general, it is advisable, to have dust eliminating ventilation at all those places installed,
where it is generated.
Bioburden
Thee bioburden not only of starting material and final product but especially of the
environment is a critical variable. In this case, a validated method for reduction should exist,
whose results are closely monitored at regular intervals. Especially water should be checked.
The same should take place for the premises and equipment. The recommended values for
Evaluation: personnel
The expression ”qualified person” needs to be elaborated. In my experience, the senior level
medicines, knowledge and a way of thinking which has to be acquired tediously by chemists
or engineers.
There are no special requirements in the area of training and personnel hygiene outside
manufacturing directive, analysis method or training and maintenance action, on paper. This
requires in consequence proper archivation procedures with easy access for the individual
- manufacturing permit
- contracts
- job descriptions
- training certificates
- SOPs
It is important to note, that no single production step should take place without a detailed
protocol signed by at least two responsible persons. Such batch records allow to reconstruct
the entire process of manufacturing for every individual lot in case of problems. Necessary is
also an ”Out of Specification” (OOS) SOP. A periodic review of the protocols, mostly
annually, yields in addition valuable information about small shifts in quality parameters and
The requirements for quality control, which have been discussed at length before in context
with GLP, are resummarised in figure 15. In many cases, the sampling procedures and
stability testing fall also under the responsibility of the QC unit ( fig.16 )
Other aspects
rather large amount of accompanying rules and guide-lines, most of them semi-official. There
are regulations available for establishing a master qualification plan (DIN-ISO), quality
assurance systems (DIN-ISO), PIC documents for inspection, validation etc., ICH documents
on purity, stability testing etc. and a whole set of GLP and GCP guidelines of the EC. They
will not be discussed in the context, but their existence and at least partial relevance to herbal
An analysis of warning letters of the FDA, a public instrument of this agency to enforce GMP
compliance lists the following, most frequent defaults (8, Fig. 17).
The list provides some hints to where special attention is needed to improve GMP status.
Most of the listed deviations can be remedied by changing organisational procedures and
investing thought and effort, not necessarily money. It is my opinion, that adequate GMP