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ICH Q7A GMP

Guidance for APIs


Section 2
Quality
Management
Quality Management
ICH Q7A GMP GUIDANCE FOR APIs

• Principles
• Responsibilities of the Quality Unit
• Responsibility for Production Activities
• Internal Audits (Self Inspection)
• Product Quality Review

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Quality Management
ICH Q7A GMP GUIDANCE FOR APIs

Most of the guidance in this


section is not new….

But in some cases, puts into writing


or clarifies current expectations

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2.1 Principles
ICH Q7A GMP GUIDANCE FOR APIs

• Quality should be the


responsibility of ALL
• A quality system is
needed
• Independence of
Quality Unit(s)
• All activities recorded
at the time performed

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2.1 Principles
ICH Q7A GMP GUIDANCE FOR APIs

Release of Materials
• Persons authorized to release intermediates
and APIs should be specified

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Release Under Quarantine
ICH Q7A GMP GUIDANCE FOR APIs

No materials released or used before


satisfactory completion of evaluation by
Quality Unless appropriate systems in place to
allow for such use
API released to third parties only after
release by Quality
May be transferred under quarantine to
another unit under company control when
authorized by Quality with appropriate
controls/documentation (10.2) 6
Glossary Definition
ICH Q7A GMP GUIDANCE FOR APIs

Critical:
Describes a process step, process
condition, test requirement, or other
relevant parameter or item that must be
controlled within predetermined
criteria to ensure that the API meets
its specification.
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2.1 Principles
ICH Q7A GMP GUIDANCE FOR APIs

Deviations
• Deviations documented and explained
• Critical deviations investigated
and documented

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2 Responsibilities
ICH Q7A GMP GUIDANCE FOR APIs

2.2 Responsibilities of the Quality Unit


• Involved in all quality-related activities
• Review and approve all quality related documents
• Non-delegatable activities
2.3 Responsibility for Production Activities
• Intentionally did not refer to “Production Unit”
• Depending on company some of these functions are
performed by production, engineering, technical
maintenance, etc
• Did not want to impose organizational structure
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2 Responsibilities
ICH Q7A GMP GUIDANCE FOR APIs

Responsibilities that
should NOT be
delegated

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Clarification of terms
ICH Q7A GMP GUIDANCE FOR APIs

Release: final authority

Review and approval: authority but this may


be shared authority. More than one group or
person may be required to review and approve.

Making sure: that other group performs and


quality oversees or checks
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2.2 Quality Responsibilities
ICH Q7A GMP GUIDANCE FOR APIs

Responsibilities that should NOT be delegated


• Releasing or rejecting all APIs
• Releasing or rejecting intermediates for use
outside the control of the manufacturing company
• Reviewing completed batch production and lab
control records of critical process steps before
release of the API
• Performing product quality reviews

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2.2 Quality Responsibilities
ICH Q7A GMP GUIDANCE FOR APIs

Responsibilities that should NOT be delegated


Approving
• All specifications and master production instructions
• All procedures impacting the quality of APIs or
intermediates
• Contract manufacturers
• Changes that potentially impact the quality of APIs
or intermediates
• Validation protocols and reports

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2.2 Quality Responsibilities
ICH Q7A GMP GUIDANCE FOR APIs

Responsibilities that should NOT be delegated


Making sure that
• critical deviations are investigated and resolved
• internal audits are performed
• effective systems are used for maintaining and calibrating critical
equipment
• materials are appropriately tested and the results reported
• there is stability data to support retest or expiry dates and storage
conditions

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2.3 Quality and Production
Responsibilities
ICH Q7A GMP GUIDANCE FOR APIs

Some similarities, but intentional differences

QU P
• Approving all • Preparing, reviewing,
specifications and master approving instructions for
production instructions the production of APIs
and intermediates

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2.3 Quality and Production
Responsibilities
ICH Q7A GMP GUIDANCE FOR APIs

Some similarities, but intentional differences

QU P
• Reviewing completed • Reviewing all
mfg records for critical production records and
process steps before ensuring these are
release of API for completed and signed
distribution

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2.3 Quality and Production
Responsibilities
ICH Q7A GMP GUIDANCE FOR APIs

Some similarities, but intentional differences

QU P
• Making sure that • Making sure that the
effective systems are necessary calibrations
used for maintaining and are performed and
calibrating critical records are kept
equipment
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2.4 Internal Audits
ICH Q7A GMP GUIDANCE FOR APIs

• To verify compliance with the


principles of GMP for APIs
• Performed regularly in
accordance with an approved
schedule

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2.4 Internal Audits
ICH Q7A GMP GUIDANCE FOR APIs

• Audit findings and corrective action


– documented
– brought to attention of responsible
management

• Corrective actions completed in


timely and effective manner

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2.5 Product Quality Review
(Annual Product Review)
ICH Q7A GMP GUIDANCE FOR APIs

• Regular quality review


to verify the consistency
of the process
• Normally conducted
and documented
annually

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2.5 Product Quality Review
ICH Q7A GMP GUIDANCE FOR APIs

Review should include:


• critical in-process controls and critical API test results
• batches failing specifications
• critical deviations or non-conformances
• changes to process or analytical methods
• results of stability monitoring program
• quality related returns, complaints, recalls
• adequacy of corrective actions
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2.5 Product Quality Review
(Annual Product Review)
ICH Q7A GMP GUIDANCE FOR APIs

Results should be evaluated


and an assessment made of
need for corrective action or
revalidation

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ICH Q7A GMP
Guidance for APIs
Section 2
Quality
Management

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