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CHAPTER 1
PHARMACEUTICAL
QUALITY SYSTEMPharmaceutical Quality System
6 Principle © Quality Control
Pharmaceutical .
© Quality System © Prdusggucilty
Good Manufacturing
Practice for Medicinal Quality Risk
Products (GMP) ManagementPRINCIPLE
The holder of a Manufacturing Authorisation must manufacture medicinal products so as to ensure
that they are fit for their intended use, comply with the requirements of the Marketing Authorisation
F Clinical Trial Authorisation, as appropriate, and do not place patients at risk due to inadequate
safety, quality or efficacy. The attainment of this quality objective is the responsibilty of senior
management and requires the participation and commitment by staff in many different
departments and at all levels within the company, by the company’s suppliers and by its
distributors, To achieve this quality objective reliably there must be a comprehensively designed
‘and correctly implemented Pharmaceutical Quality System incorporating Good Manufacturing
Practice and Quality Risk Management. It should be fully documented and its effectiveness
monitored. All parts of the Pharmaceutical Quality System should be adequately resourced with
competent personnel, and suitable and sufficient premises, equipment and facilities. There are
additional legal responsibilities for the holder of the Manufacturing Authorisation and for the
Authorised Person(s).
The basic concepts of Quality Management, Good Manufacturing Practice (6MP) and Quality Risk
Management are interrelated. They are described here in order to emphasise their relationships
‘and their fundamental importance to the production and controlof medicinal products.Pharmaceutical
Quality SystemPharmaceutical Quality System
11 Quality Management covers all matters, which influence the
quality of a product. Quality Management therefore incorporates
Good Manufacturing Practice.
1.2 GMP applies to the lifecycle stages of the product. However the
Pharmaceutical Quality System can extend to the pharmaceutical
development lifecycle stage as described in ICH QI0, which
facilitate innovation and continual improvement and strengthen
the link between pharmaceutical development — and
manufacturing activities.
13 The size and complexity of the company’s activities should be
taken into consideration. While some aspects of the system can be
company-wide and others site-specific, the effectiveness of the
system is normally demonstrated at the site level.
¢
“OF
A
==]14 A Pharmaceutical Quality System appropriate for the
manufacture of medicinal products should ensure that:
(i) Product realisation and consistent delivery of products with
appropriate quality attributes;
(ii) Product and process knowledge is managed throughout all
lifecyclestages;
(iii) Medicinal products are designed and developed following
Good Manufacturing Practice;
(iv) Production and control operations are clearly specified and
Good Manufacturing Practice adopted;
(v) Managerial responsibilities are clearly specified;(vi) Arrangements are made for the manufacture, supply and use of the
correct starting and packaging materials, the selection and monitoring of
suppliers and for verifying that each delivery is from the approved supply
chain;
(vii) Processes are in place to assure the management of outsourced
activities;
(viii) A state of control using effective monitoring and control systems for
process performance and product quality;
(ix) The results of product and processes monitoring are taken into
account in batch release, in the investigation of deviations, and, with a
view to taking
preventive action to avoid potential deviations occurring in the future;
(x) All necessary controls on intermediate products, and any other in-
process controls and validations are carried out;(x) Continual improvement is facilitated through the implementation of qu
improvements appropriate to the current level of process and product knowledge;
(di) Arrangements are in place for the prospective evaluation of planned changes
‘and their approval prior to implementation taking into account regulatory notification
and approval where required;
(iii) after implementation of any change, an evaluation is undertaken to confirm the
quality objectives were achieved and that there was no unintended deleterious
impact on product quality;
(xiv) An appropriate level of root cause analysis should be applied during the
investigation of deviations, suspected product defects and other problems.
This can be determined using Quality Risk Management principles. in cases where the
true root cause(s) of the issue cannot be determined, consideration should be given
to identifying the most likely root cause(s) and to addressing those. Where human
error is suspected or identified as the cause, this should be justified having taken
care to ensure that process, procedural or system based errors or problems have not
been overlooked.inal products are not sold or supplied before an Authorised Person
has certified that each production batch has been produced and controlled in
‘accordance with the requirements of the Marketing Authorisation and any other
regulations relevant to the production, control and release of medicinal products;
(xvi) satisfactory arrangements exist to ensure, as far as possible, that the
Medicinal products are stored, distributed and subsequently handled so that
quality is maintained throughout their shelf life;
(xvii) There is a process for self-inspection and/or quality audit, which regularly
‘appraises the effectiveness and applicability of the Pharmaceutical Quality
system,
i Wy X1.5 Senior management has the ultimate responsibility to ensure an effective
Pharmaceutical Quality System is in place, adequately resourced and that roles,
respon
throughout the organisation. Senior management's leadership and active
participation in the Pharmaceutical Quality System is essential. This leadership
should ensure the support and commitment of staff at all levels and sites within
the organisation to the Pharmaceutical Quality System.
ies, and authorities are defined, communicated and implemented
1.6 There should be peri
management, of the operation of the Pharmaceutical Quality System to identify
‘opportunities for continual improvement of products, processes and the system
itself.
fic management review, with the involvement of senior
1.7 The Pharmaceutical Quality System should be defined and documented. A
Quality Manual or equivalent documentation should be established and should
contain a description of the quality management system including
management responsibilities.GOOD
MANUFACTURING
PRACTICE FOR
MEDICINAL
PRODUCTSpeered
eb ee
iter ona
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‘Assystemis avaiable torecall any batch of
eee enn
foereneateaty
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Ce ta
coerced
ey
perceivesQUALITY CONTROL
Concerned with
sampling,
specifications and
testing,
Including
Organisation,
documentation
and release
proceduresBasic Requirements of Quality Control
Requirement that must be followed in QC are:
NSTC Ce MC OUR) ceo aka OC
‘Taken by approved personnel and methods
mS dulled ee AV ell)
Records are made, manually and/or by recording instruments
complying with the qualitative and quantitative composition of the
Marketing Authorisation or Clinical Trial Authorisation
cela e oun eC UT Ro
No batch of product is released for sale or supply prior to
certification by an Authorised Person
Sufficient reference samples of starting materials and products are
PCT RU rte ALU aPRODUCT QUALITY REVIEW (PQR)
is a mechanism to ensure that data captured by the Pharmaceutical
Quality System (PQS) is reviewed for trends.
110
© Regular periodic or rolling quality reviews of all authorised medicinal
products,
© including export only products,
@ should be conducted with the objective of verifying the consistency of the
existing process,
© the appropriateness of current specifications for both starting materials and
finished product,
© to highlight any trends and to identify product and process improvements.
=
NOTE: Such reviews should normally be conducted and documented annually. fPRODUCT QUALITY REVIEW
(i) those from new sources and in particular the review of supply
eae alec eat
(ii) A review of critical in-pri ntrols and finished product
cCHvicy FO | &
(ili) A review of all i TI if
Fy ol-Teflitorel (olan elated
(iv) A review of all significant deviations or non-conformances, and
PCy icra seen eee a tnd em reread
(v) A review of all changes carried out to the processes or analytical
methods;PRODUCT QUALITY REVIEW
(vi) A review of Marketing Authorisation variations submitted,
granted or refused, including those for third country (export only)
dossiers;
(viii) A review of all quality-related returns, complaints and recalls
and the investigations performed atthe time;
- (x) For new Marketing Authorisations and variations to Marketing
Authorisations,a review of post-marketing commitments;
Ww (xi) The qualification status of relevant equipment and utilities,
(xii) A review of any contractual arrangements.um
no
- PRODUCT QUALITY REVIEW
The manufacturer and/or Marketing Authorisation holder should evaluate the
results of the review and an assessment made as to whether corrective and
preventive action or any revalidation should be undertaken, under the
Pharmaceutical Quality System.
Quality reviews may be grouped by product type, e.g. solid dosage forms, liquid
Cree eee oe a Rael atic
Crore cun ee Mee ee aaa Tala eet hoy
Oe en nee kee RR a eee iam g
ene seals ee hucd neers temas
Swe Re OR ea ROME ree lel ole ted
Marketing Authorisation holder should ensure that the quality review is performed
eR A UU elo leQUALITY RISK
MANAGEMENT
Quality Risk Managementis a systematic
process for the assessment, control,
communication and review of risks to
the quality of the medicinal product. It
can be applied both proactivelyand
retrospectively.
a
=
N
wy Bs
iThe principles of Quality as
Managementare that:
(i) The evaluation of the risk to quality is based
on scientific knowledge, experiencewith the
process and ultimately links to the protection of
the patient;
(ii) The level of effort, formality and
documentation of the Quality Risk
Management process is commensurate with
the level of risk.
Examples of the processes and applications of Quality Risk Management canbe
found inter alia in Annex 20 or ICHQ9.THANK YOU
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