FP5007 Sop GMP 1
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Simply put, GMP is the means by which the patient gets the medicine that he or she expects and nothing else. Anon.
26.1 INTRODUCTION
It is generally accepted within the pharmaceutical industry that a system of control is essential to ensure that medicinal products are manufactured to required standards. The term good manufacturing practice (GMP) is universally used to describe the system or systems upon which this assurance is based. GMP is applied, regulated and controlled in different ways across the Globe. Within the United States of America GMP is described in the Code of Federal Regulations (CFR) in a surprisingly short series of paragraphs commonly referred to as the CFRs.1 The USA also adds the word current and thus abbreviates the term to cGMP. Although the CFRs are apparently written as rigid mandatory regulations, the US regulatory agency, the Food and Drug Administration (FDA) expects industry to constantly improve standards through advanced technology by using the FDAs guidance documents or by following case law. A particularly useful way to sense the FDAs current thinking on standards within the industry and how they should change is by reading the warning letters issued to companies whose operations fall short of expectations, which are published in a redacted form on its website. At the time of writing the FDA has issued a major report detailing a revised approach to the application of GMP in the 21st century, which it considers should be based on a sound quality system but also encompass comprehensive risk assessment at each point of the process.2 Within the European Union (EU), GMP is imposed by two Directives which state that manufacturers of human and veterinary medicinal products must carry it out.3,4 Two further Directives lay down the principles and guidelines of GMP5,6 while a fth imposes GMP on the manufacturer of an investigational medicinal product (IMP).7 The principles of GMP expressed in Directives 2003/94/EC and 91/412/EEC are brief legal statements of what GMP actually is which should be read and followed with care by the manufacturer (As 91/356/EEC the human GMP Directive was almost identical to the veterinary version, simply being a legal nicety to separate human and veterinary legislation. The recent requirements for GMP of IMPs forced additions to the Articles and repeal of the original
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Directive). Nevertheless, those responsible for the regulation of medicinal products within the EU recognised that the industry needed more detail to help interpretation. The Directives make provision for detailed guidelines to be published to which manufacturers and agents of competent authorities (regulatory bodies of Member States) should refer.8 (These detailed guidelines will hereinafter be referred to as the Guide to GMP.) Other countries or trading blocks have similar provisions for their own interpretations of GMP. Since the USA and Europe host a massive concentration of the pharmaceutical industry (and buy a lot of its products) this chapter will describe the interpretations of GMP with respect to those two systems but it is reasonable to assume there are no major conicts of interpretation with other systems.
Introduction: Good Manufacturing Practice Table 1 Section and chapter headings of the CFRs and the Guide to GMP
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USA code of Federal Regulations Part 211 Organisation and personnel Buildings and facilities Equipment Control of components and drug product containers and closures Production and process controls Packaging and labelling control Holding and distribution Laboratory controls
Guide to good manufacturing practice Quality management Personnel Premises and equipment Documentation Production Quality control Contract manufacture and analysis Complaints and product recall Self-inspection
The same Directives dene pharmaceutical quality assurance as: . . . the sum total of the organised arrangements made with the object of ensuring that medicinal products are of the quality required for their intended use. While there is no definition given in the USA CFRs it seems to be an assumption that GMP (or more correctly, cGMP) is the total application of the regulations laid down, for in the absence of conformance with any one of them, the product is considered to be adulterated.9 Ofcial definitions are all very well for legal purposes but they give no clear indication of what is actually involved in the implementation or application of GMP. On that score there is no shortage of information for the manufacturer. The regulations and guidance documents lay down only the primary expectations. Table 1 provides a comparison between the contents of the CFRs and the Guide to GMP. It is clear that the USA approach is more specic in detail than the European document although each regulatory authority effectively covers all areas in some way, for example the specic requirements for tamper-evident packaging found in the CFRs are imposed by other regulations within Europe. Additional guidance for specic products, or for areas of interest demanding detailed guidance from the regulators, is provided in a series of Annexes to the Guide to GMP. The FDA also publishes Guidance for Industry documents, which spell out detailed requirements on specic manufacturing situations. Information on how a regulator might treat a particular aspect is given in the FDAs specic Inspection Guides intended as aids to its investigators. Inspectors in the rest of the world turn to the PIC/S guidance and recommendation documents for inspectors.10 Thus, there is no shortage of regulations, ofcial guidance and advice on GMP although the sheer volume seems overwhelming to the industry initiate. For clarication it is useful to refer to the Guide to GMP and examine each of its chapters in turn, illustrated by examples both of good practice and what happens when it is not followed.
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spectrum of the industry, from complex and lengthy biotechnical operations, to simple, rapid batch manufacturing. It must also be interpreted within each of the Member States of the EU, which by no means resembles the federal nature of the USA. In this way each manufacturer can ensure compliance while being able to manage operations in a exible way.
Dispense materials
Test Product
Figure 1
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Quality management systems are discussed elsewhere in this book (Chapter 40). However, the general design of such systems tends to be common. A set of top-level statements of policy sets out management intent on key areas of the manufacturing process. A second level series of guidance documents expands on how the intent is to be turned into practice. Third and fourth tier documents set out operation procedures in detail and provide records of operations and results. The objective of the QA system is to ensure that decisions are not made on an ad hoc day-to-day basis, depending on circumstances or urgency. Decisions should, in effect be made by the system itself. Managements role is to monitor that the system operates satisfactorily and will maintain control of the pharmaceutical manufacturing operations. A useful example is the way that Change Control should be managed. The manufacturer has an obligation to make the medicinal product according to its marketing authorisation and must not deviate from it unless a variation is submitted to the appropriate authority and approval has been received (various authorities differ in the extent and manner of submissions of variations before approval is given but the principle remains the same). Without procedures underwritten by clear policy from management, changes, which are not reviewed by appropriate people and which are not authorised, can rapidly shift compliance to non-compliance. Example 1: It is tempting for the purchasing department to buy-in a raw material from a less expensive source and to persuade the laboratory to test and approve it. Production may nd that material from the new source requires a change to the manufacturing process to achieve the product specication. In achieving one specication it might lose control over anotherhardness of a tablet at the expense of thickness is a good example. The thicker tablet does not t its blister pack quite so well, leading to a stability problem and a shorter shelf life. Example 2: The site laboratory suffers a breakdown of an analytical instrument. It conveniently nds a laboratory within another company close by with a similar instrument and arranges for the samples to be tested there. This second laboratory is not listed on the companys manufacturing authorisation as an alternative testing site. The company policy on adherence to the marketing and manufacturing authorisations should be clear. If a change-control system had been in place which required review and approval by all interested parties, backed up by submission to the regulatory authority, then the loss of control shown by these examples would not happen.
26.2.2 Personnel
If there is one area of adherence to GMP that can make or break a pharmaceutical company it is in relation to the people it recruits, trains and develops. The Guide to GMP requires an adequate number of personnel with the necessary qualications and practical experience. It is up to the manufacturer to decide what each of these adjectives mean in relation to the operations in question but it is not hard to envisage that each one can lead to animated discussion! Particular requirements are quite clear. There must be an organisation chart and there must be two key personnel, the Head of Quality Control (QC) and the Head of Production, who must be independent from each other. Under European law there must also be a third individual known as the Qualied Person (QP), unless one of the rst two can also act in this capacity. It is worth noting here that the CFRs do not demand named individuals but do require a QC unit. In many recent (19982003) warning letters the FDA has cited the absence of a quality unit as the main reason why a company has failed to meet GMP requirements. It must be assumed that if there is a QC unit there must be someone at the head of it, whatever their title.
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The Heads of Production and QC have individual and shared responsibilities which can be summarised as follows: The Head of the Production Department should: ensure products are produced and stored correctly approve instructions relating to production and ensure strict implementation ensure production records are evaluated and signed check maintenance ensure validations are done ensure training is carried out.
The Head of the QC Department should: approve or reject materials and products evaluate batch records ensure testing is carried out approve specications and other QC procedures approve and monitor contract analysts check maintenance of his department ensure validations are done ensure training is carried out.
Shared responsibilities include: authorisation of procedures monitoring and control of the environment hygiene process validation training approval and monitoring of suppliers approval and monitoring of contract manufacturers designation and monitoring of storage conditions retention of records monitoring compliance to GMP inspection, investigation and taking of samples to monitor factors which may affect product quality.
It is well worth noting that training gures both as an individual and shared responsibility for the named Heads, emphasising the importance of this topic. Untrained personnel operating within the manufacturing, packaging and testing environment are dangerous, since they can act in an unaware, albeit well-meaning way. Example 3: An untrained packaging operator picked up an apparently good pack of product from the oor and put it back on the nearest packaging line, where it was assembled with others. The pack actually came from an adjacent line packing product with the same name but of a higher strength. Because the high strength pack was collated amongst others of low strength it went unnoticed in the dispensary and a patient suffered serious side effects. Example 4: An untrained dispensary operator did not appreciate the difference between two materials which were identical except for a different sufx on the label which indicated the viscosity grade. The material was used in a tablet granulation which seriously affected dissolution of the product in vivo.
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These are typical examples of actions carried out by individuals who were unaware of the serious consequences of simple mix-ups. Proper and thorough training, repeated and updated on a regular basis, is essential within the pharmaceutical-production environment. Such training must include all those who work directly on production, packaging or testing but attention should also be given to those whose activities take them into the production or testing areas on an occasional basis, for example maintenance engineers. Ofce-based personnel who work in purchasing, human resources and nance should be taught which areas they can access without an escort, if any, what to wear and how to behave when in them. Key personnel and those in responsible positions should have appropriate qualications to understand the theoretical basis of the activities they carry out. An important example is the facility that manufactures sterile products. It should be managed and supervised by graduates with a microbiology or biology qualication who appreciate the very special requirements demanded. Some authorities require any aspect of pharmaceutical production to be supervised by a pharmacist.
26.2.3 Premises and Equipment 26.2.3.1 Premises. As a general rule, production facilities must be located in an area which will
not adversely affect the operations carried out within. The design and construction must also suit the activities. However, often the managers of a pharmaceutical factory are faced with a fait accompli when it comes to the facilities in which they operate. The operation may have started many years before when the facility was newly built but since then the products handled within and the activities of any factories surrounding the site may have changed dramatically. Nevertheless the managers have a responsibility to develop the facilities, upgrade and adapt them as required, to accommodate the changing circumstances. If the external environment becomes contrary to the operations, for example in the worst case, next to a land-ll site for waste and rubbish which attracts vermin and ies, there may be little choice but to move. It may be possible in less serious situations to ensure that the external activities will not affect the products. In any case there is an obligation to keep out insects and other animals and to monitor the effectiveness of any programme to do that. It is an expectation of GMP to maintain premises and to keep them clean and hygienic. It therefore follows that they should be appropriately lit with temperature and humidity controls to maintain suitable working conditions which permit these requirements. Operations which might cause serious contamination of medicinal products with toxic materials, are not permitted. Thus production and storage of non-medicinal products and especially pesticides and herbicides are not allowed in the same facility although certain cosmetics may be (Note, however, that in the case of veterinary ectoparasiticides it is permitted to manufacture in pesticide specic areas in the same premises as other veterinary products).11 It is expected that highly sensitising materials such as penicillins are produced and handled in separate facilities altogether. Other products, including certain other antibiotics, hormones, cytotoxics, and other highly active drugs should have dedicated areas although production on a campaign basis can be authorised. If so, validation of the cleaning and changeover procedures must be thorough. An aspect which cannot be over-emphasised for any facilities but especially in storage, production and laboratory areas, is the provision of sufcient space. Lack of space causes many examples of cross contamination, mix-ups and deterioration of product or packaging. Example 5: During a period of intense production activity in one facility, storage space within the warehouse came under pressure. As a consequence the general rule of one item one pallet was ignored and boxes of leaflets for two different products were stored next to each other on the same pallet. The wrong boxes were included in a consignment to the packaging line and the
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leaflets packed in the product. Luckily the mistake was spotted in a pharmacy but the subsequent recall was very embarrassing for the company. The materials of construction and nish for any area must be appropriate to the activities carried on within. Surfaces must be smooth to allow cleaning operations to be effective but must also be of suitable materials so as not to shed particles or contaminate the product. Floor surfaces in particular must be sound and capable of withstanding vigorous cleaning agents. There are many proprietary materials for all surfaces and the manufacturer is well advised to search extensively for suitable items and to seek advice from other manufacturing sites as to their experience with various options. Personnel should be provided with separate facilities for rest and refreshment. The wearing of working clothes in refreshment areas should be avoided if at all possible and certainly should be forbidden where facilities are shared with non-production personnel and visitors. Suitable areas should be provided for personnel for changing clothes and for washing and toilets.
26.2.3.2 Equipment.
The Guide to GMP is surprisingly short in its treatment of equipment. This is remarkable when considering the effect of improper, poorly maintained and uncalibrated equipment on the quality of the nal product. The range of processes covered by pharmaceutical equipment is enormous, from simple measurements through complex processing operations to huge packaging lines. Additionally, equipment is often serviced not by the production department that uses it but by an engineering department reporting separately to senior management. A particular aspect required of the Quality System is that such relationships are well organised and properly managed. Repair and maintenance activities result in engineering operatives moving from area to area with the potential for cross-contamination from their work clothes. The rst requirement of a piece of equipment is that it will not harm the product exposed to it and should do the job it is intended for. Thus it should be constructed of suitable materials. Those parts coming into contact with the product should not react with it nor release or absorb any materials. If plastics are used this may be of special importance. Nowadays, it is a generally expected requirement of GMP that all pieces of equipment that affect quality will be subject to a systematic maintenance programme. Aspects of such a programme which ensure it will be effective are: a master list of equipment designation of quality critical and non-critical equipment a schedule of maintenance for each piece which species among other things which parts may be changed without seeking further authority procedures to specify action if the maintenance interval is delayed or missed altogether records of maintenance showing any parts that were changed or adjustments made procedures to remove any piece of equipment which becomes defective, redundant or obsolete. Example 6: A maintenance engineer was called to replace an O ring in the seal of a valve. The material was supposed to be black neoprene, deliberately chosen so that any particulates it released would be immediately visible. The engineer did not have a similar replacement and inserted a white nylon ring instead. White particulates were later found in an injectable product produced with the equipment. It is expected that measuring equipment will be subject to a planned calibration programme with similar aspects to the above. Additionally there must be strict procedures to be followed in the event that: a calibration interval is delayed or missed the instrument is found to be outside its calibrated parameters.
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In the last case any action should include a review of all those batches of product which might have been affected by an incorrect measurement. Each piece of equipment should have a log book(s) or similar record(s) which records all maintenance, calibration and cleaning carried.
26.2.4 Documentation
The quality of a companys documentation system reveals the quality of its Quality Assurance System. Documents should be clearly written, well laid out, easy to follow and with sufcient room to ll in information and results where needed. Those who manage the documentation system must ensure that documents are maintained up-to-date and that only current documents are made available to the operations. It is especially important that necessary changes to documents can be carried out within a short time. Needless bureaucracy that hinders and delays corrections to typographical errors or obvious mistakes leads to frustrations and continued use of the incorrect document, probably with hand-written amendments. This effect, which is frequently found when document management is poorly controlled or left to junior sta, is a significant indicator of a weak QA system, not as some would have it, the opposite. The Guide to GMP sets out the minimum requirements for various documents expected to be found in the manufacturing site. The four basic types of document are stated to be Specications, Manufacturing Formula, processing and packaging instructions, Procedures (Chapter 27) and Records. The latter is further subdivided into records of Receipt, Sampling, Testing and Other procedures including for example Validation, Pest Control and Recalls. Figure 1 suggests that there must be many other examples within the system. It is also a reminder that a document system should be designed as part of the QA system. Proper design leads to minimisation of the number and type of documents used. An example of poor design is the proliferation of similar procedures covering minor differences. Example 7: A company had separate procedures to cover each type of change within its operations e.g. materials, processes, packaging and test methods. The evaluation of each change and the form used to control them was actually almost identical. This system also failed to recognise that many related minor changes actually made one critical change. By consolidating the separate procedures the company eliminated many pages of repetitive procedures and related changes were properly evaluated for their overall effect on the quality of the product. Thus a valuable action by auditors is to ask for a list of standard operation procedures, choose those which seem similar to each other and on examination, compare them for similarities or as more often happens, conicts between identical activities in different areas.
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Thus the manufacturer should make efforts to avoid cross-contamination. It may be possible to do this effectively in a number of ways, depending on the circumstances and the products involved. Total segregation of facilities is an obvious but expensive option, which may be unavoidable in certain instances. Lesser options include the provision of air-locks between areas at risk or providing independent air-handling units. Organisational arrangements such as ensuring that one person does not work on different products without a change of clothing may be effective. In any case, cleaning, decontamination and monitoring procedures should have demonstrated effectiveness. Test methods used for residues should be evaluated for their ability to detect the very low levels that may be present.
26.2.5.3 Validation.
Significant additional guidance on validation was introduced by the relatively recent inclusion of Annex 15 in the Guide to GMP. Nevertheless some general principles are worth repeating here: all manufacturing processes should be validated significant amendments to processes should undergo evaluation to check whether revalidation is necessary all processes and procedures should undergo periodic re-validation to ensure they remain capable of achieving the intended results. Validation activities should be carefully recorded as this record is useful in examining the cause of problems and deviations that occur when the process is used repeatedly.
26.2.5.4 Starting Materials. Since starting materials are fundamental to the quality of the
nal product the manufacturer should ensure that procedures for selection and control of suppliers are sound. An approved suppliers list should be maintained by the quality unit. This should be accessible to all those who handle materials or who deal with supplies such as warehouse personnel, sampling and testing sta and purchasing. Additions or deletions to the list should be controlled by the company change control procedure. Materials received from unauthorised suppliers should be returned or quarantined pending formal approval. Materials receiving procedures should ensure that each container is checked for proper labelled identity and is of the material ordered. If several batches of the same material are received together they must be separated and controlled by internal company batch numbers. Each container should be formally sampled and tested to ensure the identity of the contents, unless an evaluation of the suppliers quality system has shown this to be unnecessary. It is expected that materials will be properly stored, free from the possibility of mix-up and contamination and in a suitable storage area which is temperature and if needed, humidity controlled. A system of re-evaluation should be in place with an assigned retest or expiry date to each batch of material. Only materials which have been released by QC should be used. They should be dispensed in designated areas by properly trained operators (see example 4 above), and an independent check of the identity and weight or volume must be made. They must be labelled properly. Controversy exists with respect to the definition of an independent check. Whilst a rst interpretation might be that a second person is required most European authorities would probably accept a separate check by bar code reading equipment backed up by a printout from the weighing equipment. The CFRs clearly require a second person.12
26.2.5.5 Processing Operations: Intermediate and Bulk Products (Chapter 28). Basic
principles of production not included elsewhere are: the work area must be free from materials, products, residues or documents that are not related to the current operation
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environmental conditions should be suitable and should be monitored. If intermediate or bulk products are to be stored, even for a short time, they should be kept under appropriate conditions significant deviations from expected yield should be recorded and investigated. It is up to the manufacturer to dene what is significant but this is often apparent by examining trends after several batches have been made. An area not well covered by GMP guidelines is the requirement for a procedure to control and investigate any deviations from the standard procedure (Chapter 27). This is an important topic for the manufacturer to cover because deviations often require urgent evaluation and decision-making, unlike controlled changes, which more often than not can be evaluated in a less frenetic atmosphere. The starting point for a deviation procedure must of course be the assumption that operator training clearly instructs that no deviation from the laid-down process can be allowed. However, mistakes do occur. In addition equipment breaks down, power cuts happen which are outside anyones control. All of these potential events need some thought on how they will be evaluated. A sound deviations procedure is most important in this respect.
Because packaging problems are the most frequent cause of product recalls worldwide, it is not surprising that no less attention must be given to their source and control than to raw materials. Similar attention to selection and monitoring of suppliers is required. It should be remembered that suppliers of printed packaging and manufacturers of packaging items such as bottles, closures and blister foils more often than not supply many other non-medicine industries. The consequences of label mix-ups, or poor closure/bottle tting may not be so exciting to those outside the pharmaceutical industry.
26.2.5.7 Packaging Operations. It is at the packaging stage that the opportunity for major
errors really presents itself. All those involved within packaging operations should be vigilant to the possibilities of mix-ups of product, labels and leaflets and other printed matter. Packaging areas are usually very busy with several lines operating side by side, albeit suitably separated. Packaging operators and in particular engineering tters move from line to line as production requirements dictate. These movements carry the potential for small items such as tablets, capsules, ampoules and vials to be carried accidentally from one line to another. Most packaging lines nowadays use self-adhesive labels supplied on rolls, which minimise the likelihood of an odd label drifting about. Nevertheless, those who still use individually cut labels must be especially vigilant. Thus procedures in the packaging area should control product and materials coming to the area from the stores. Operators must be trained to recognise subtle differences between similar products and packaging. Line clean-down and start-up procedures must ensure that residues of previous product and packaging are removed and checks made to ensure the line is clear. During the packaging operations routine checks should be carried out to ensure that the integrity of the pack remains in control. Such checks include conrmation that overprinted information remains correct and legible, that labels, leaflets and cartons are of the correct identity and that closure and seal integrity is within the expected limits. Example 8: During a long packaging operation more labels were required. Labels for the product with the correct name but different strength were issued by the store. Because they arrived on the line at a shift change over they went unnoticed and part of the batch was distributed with incorrect labels. An important aspect of packaging is the reconciliation procedure after a batch is completed. Reconciliation must take into account both the product and packaging which was: sent to the line used in the pack
Chapter 26
Procedures should also be clear on what to do with the leftover product and packaging. Owing to the danger of mix-ups some companies do not return opened cartons of leaflets or printed items to the store. Any product left over may also be uneconomic to keep when the dangers of mix-ups are considered.
Storage procedures should ensure that any nished product cannot be released for distribution until it has been released. At all times it should be stored under suitable conditions. Sometimes it is necessary to pack products at room temperature, which must then be cold stored to maintain shelf life. If that is the case, the maximum time allowed at room temperature should be stated.
26.2.5.9 Rejected, Recovered and Returned Materials. The careful control of rejected
materials is paramount, especially if they are products from within the manufacturing site itself. They must be labelled properly and stored in a separated and designated area. Access to this area should be restricted. Any reprocessing of a rejected product should be exceptional and requires full evaluation to ensure that the nal quality of the product will not be affected. Recovery of products from batches which did conform to the required quality, requires prior approval within the marketing authorisation. Recovered material may require additional testing to conrm the quality.
26.2.6.2 Good Quality Control Laboratory Practice (GCLP) (Chapter 30). Good quality
control laboratory practice is a subdivision of GMP related to proper organisation and management of the laboratory operations related to testing medicinal products. GCLP should be distinguished from good laboratory practice (GLP), which is a term formally reserved for the regulation of animal testing laboratories (Part 2). A laboratory must have an appropriate documentation system. Since the activities should be governed by the operation of the quality system it follows that the documentation system should be
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designed as part of the overall company system. This is often found not to be the case, leading to confusion of definitions and different levels of quality in documents between the GCLP system and the main GMP system. Whatever the system, the QC department has a responsibility to store documents related to the quality of each batch produced. The minimum storage periods are set out as 1 year after the expiry date or, within the EU, 5 years after the certication by a QP. Such records should include all original data such as that found in laboratory notebooks. Special attention should be drawn to the requirements for sampling. It is recognised that any sample, at best, can only give a snapshot of the quality of the whole batch. Thus samples should be taken with care using trained operators following clear procedures. Any ad hoc samples should be treated carefully, unless they have been taken using a preordained plan. Samples must be labelled with, as a minimum, the contents, batch number, date of sampling and some indication of the containers from which the samples have been drawn. Reference samples of materials and nished product must be retained. In the case of nished product the minimum period is 1 year after the expiry date. Raw materials should be retained for 2 years after release of the last batch of product containing them. There are exemptions for raw materials which would be hazardous to keep or which are volatile. The size of all samples should permit at least one full set of tests to be carried out. In the case of nished products the manufacturer should ensure that the sample is not lost to retesting early on in the shelf life by retaining sufcient for several retests. Analytical methods should be validated (Chapter 30) and in any case all tests should be carried out in accordance to the marketing authorisation. Subtle changes, which improve the methods, must be avoided unless properly authorised by the appropriate authorities. Example 9: An analyst adjusted the wavelength at which an HPLC method was carried out to obtain a sharper peak of the active ingredient. A related substance, not normally found in the product but which was quoted in the active ingredient specication, was missed because it did not absorb well at the new wavelength. This related substance was subsequently found during stability studies and the batch had to be recalled. The Guide to GMP lists the requirements for the test records13 and species the minimum standards for laboratory reagents and glassware.
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It should be noted that contract facilities must be approved and included on the appropriate manufacturing and marketing authorisations. Contract laboratories are subject to regulatory inspection, whether they are part of an organisation which holds a manufacturing authorisation or not.
26.2.8 Complaints and Product Recall 26.2.8.1 Complaints. Manufacturers must have a written procedure for dealing with complaints and a responsible person should be designated to handle all complaints. This ensures that if a series of complaints is received related to the same product or a particular batch it is recognised as requiring serious attention immediately. If applicable, the QP must be made aware of all complaints since he or she might have to take the initiative to recall a batch of product. The complaints procedure should ensure that a proper and timely investigation is carried out to determine the probable cause of any complaint and to decide if there is a serious defect. The consequences for other batches of the same product or for other products (e.g. in the case of a packaging defect or defect raw material) must be taken into account. The complaint procedure should also involve other departments and appropriate disciplines such as medical and regulatory affairs groups within the company, to provide an assessment of criticality.
26.2.8.2 Recalls. As in the case of complaints, there should be a written procedure that lays
down the action to be taken in the event that a decision to recall a batch or batches of product has to be taken. A designated person should be responsible for co-ordinating the companys actions and for communicating with regulatory authorities. Since any recall may require urgent and immediate action the procedure should be capable of operating at any time, including weekends and holidays. It is especially important that those who are in charge of the distribution records can be contacted and are capable of providing them at a moments notice. Most regulatory agencies have a specic department that must be notied in the event of a defective product which might be recalled or which is being recalled. The contact address and telephone and fax numbers should be included within the procedure and regularly checked to ensure it remains current. Any products which are returned due to being recalled must be held in a separated and controlled location within the storage facility. They should be properly labelled as their status and destroyed as soon as possible after the recall is judged to be complete. The person responsible for the recall should issue a written report to include reconciliation, as far as possible. The recall procedure should be evaluated on a regular basis for its effectiveness. This is often done by carrying out a dummy recall by choosing a batch and determining how rapidly information on its distribution can be gathered. The dummy run should also test the availability of key contacts and whether contacts are up-to-date. It is not sufcient to treat a real recall as this dummy test, since all the elements of the procedure might not have been tested.
26.2.9 Self-Inspection
The effectiveness and currency of the Quality System must be regularly evaluated by means of a self-inspection programme. Elements of a successful and effective programme are: a procedure for conducting self-inspections naming those who should carry them out. Preferably they should be carried out by an independent individual, accompanied by those responsible for the area under inspection a matrix of areas, systems, and facilities to be inspected against a planned schedule
Introduction: Good Manufacturing Practice written reports with recommendations for improvement senior-management review of planned and completed corrections.
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26.3 CONCLUSION
This chapter has summarised the requirements of GMP, mainly according to the expectations of the European Guide to GMP. The examples provided indicate the major defects that can occur due to apparently minor or simple actions by untrained or unthinking individuals. Detailed requirements for manufacturing controls on specic areas of production or specic types of products are found in the Annexes of the Guide to GMP, which should be consulted if applicable. The requirements for the GMP manufacture of IMP for clinical trials are detailed in Chapter 29. GMP is an evolving and dynamic requirement. The community expects continuously improved assurance of safety and quality from its medicines. Practices which were acceptable even a few years ago are no longer satisfactory. The manufacturer and especially those responsible for the implementation and maintenance of GMP should constantly be aware of that.
REFERENCES
1. Code of Federal Regulations Parts 210 and 211. Ofce of the Federal Register, National Archives and Records Administration, USA. 2. Pharmaceutical cGMPs for the 21st century A risk based approach. Department of Health and Human Services, US Food and Drug Administration, September 2004. 3. Directive 2001/83/EC of the European Parliament and of the Council of 6 November 2001 on the Community code relating to medicinal products for human use, Article 46 (f ). 4. Directive 2001/82/EC of the European Parliament and of the Council of 6 November 2001 on the Community code relating to veterinary medicinal products, Article 50 (f ). 5. Commission Directive 2003/94/EC of 8 October 2003 laying down the principles and guidelines of good manufacturing practice in respect of medicinal products for human use and investigational medicinal products for human use. 6. Commission Directive 91/412/EEC of 23 July 1991 laying down the principles and guidelines of good manufacturing practice for veterinary medicinal products. 7. Directive 2001/20/EC of the European parliament and of the Council of 4 April 2001 on the approximation of the laws, regulations and administrative provisions of the Member States relating to the implementation of good clinical practice in the conduct of clinical trials on medicinal products for human use, Article 13. 3 (a). 8. Eudralex. The Rules governing medical products in the European Community Volume IV. Good Manufacturing Practices. Ofce for Ofcial Publications of the European Communities. 9. See ref. 1 at 210.1 (b). 10. Pharmaceutical Inspection Co-operation Scheme, PIC/S Secretariat, 911, rue de Varembe, CH 1211 Geneva 20. 11. See ref. 8 at Annex 4. Para. 5,6. 12. See ref. 1 at 211.101 c. 13. See ref. 8 at 6.17.
CHAPTER 27
27.1 INTRODUCTION
Standard operating procedures (SOPs) are occasionally seen as a burdensome requirement, a bureaucratic nuisance that must be complied with because of the good manufacturing practices (GMPs). Certainly, the creation and maintenance of an SOP system does require resources, but if written properly, and with an understanding of their purpose, then SOPs are vital documents in the effective and efcient running of a quality management system, as well as a key tool in ensuring GMP compliance. This chapter rst considers general aspects of an SOP system, and then suggests the areas and subjects for which SOPs might be required in a facility operating to GMP. Elements of the former have also been discussed in Chapter 3 but are worthy of emphasis in a GMP context.
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each SOP is its instructional or descriptive content. Each SOP should describe a connected set of activities. It should be stated who is responsible for carrying out each action described. SOPs should describe the activities to be followed in a clear stepwise fashion, and it is often easier for operators to follow if the SOP should be written in the active, rather than the passive, voice (Do this rather than This should be done).
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available at every potential point where an SOP might be used. This is not always easy to achieve. One way around this is to set up the electronic system so that copies of SOPs can be printed on demand. It would be extremely labour intensive to attempt to control the distribution of copies printed in this way, to record the names of everyone who printed any copy of an SOP, and to recall and reissue them all when the document is revised. Instead, it is more appropriate to congure the system to watermark or otherwise add to each copy printed the date of printing, and some limitation on the duration over which such a copy can be used. For example, the text could be Valid on Date of Printing only or Only Valid until (Date). The system used by one of the authors allowed any SOP printed from the electronic distribution system to be used up to and including the following Sunday. New issues of SOPs were only made on Mondays. One other problem with the distribution of paper copies, whether they are issued as controlled copies or printed electronically, is the use of paper in cleanrooms. Paper creates quite a lot of dust, and is also difcult to sanitise in a way that maintains the legibility of the text. One simple solution is to laminate the SOPs in clear plastic, which seals in the dust and also gives a surface that can be easily wiped with a wide range of disinfectants without physical damage. Finally, in the spirit of making SOPs available at point of use, it is common to see parts of SOPs mounted on walls in the production area. Perhaps the most common instance is an extract of the SOP on cleanroom clothing, describing the changing into and out of cleanroom clothing, mounted on a changing room wall. This is very valuable, but it is important that this extract is part of the controlled SOP distribution system. It sometimes occurs that someone decides it would be useful to mount part of an SOP on a wall in this way. A partial copy is made and mounted. Because it is not part of the controlled distribution system, it does not get recalled when the SOP is updated (particularly if the section mounted on the wall is not changed). Because all the operators see this extract every day, it effectively becomes invisible, and its only when an inspector or an auditor comes around that the out-of-date document is noticed. By all means attach whole or part SOPs to the walls where it is of use, but ensure that they are logged as part of the controlled distribution system, so that they are kept current.
27.8 TRAINING
Training is a vital part of GMP, and this includes training in the relevant SOPs. It is therefore necessary to make SOPs available, for training purposes, a few days before the effective date so that sta can use the new document immediately after it becomes effective. The extent of training depends on the complexity of the task described, and on the experience level of the sta. A full training course, with prociency test at the end, might be appropriate for certain SOPs, while for others, it might be necessary only to read them before they are effective, and a complete range of intermediate situations is possible. Part of the process of preparing and approving a new SOP might be deciding how much training is required; alternatively this can be left to the departmental supervisors, who probably best understand the capabilities and knowledge of their sta. However this is decided, it should be recorded for each SOP. Then, after the training, the trainer (if necessary) should sign a training record to indicate that she or he has given the training, and that the person trained is judged competent to carry out the task. The trainees must then sign to indicate that they have received and understood the training, and that they feel that they are competent to carry out the specied task. It is common practice, and not unjustied, to argue that the author of an SOP is automatically considered trained in the task described, and is also qualied to train others. Where an organisation takes this view, this policy must be included in the SOP(s) that cover training in the use of SOPs. The task described in the SOP cannot be carried out by sta who have not been appropriately trained, and for existing sta who are to carry out the task, the period before the SOPs effective date is required. It is very important to ensure that new sta, or sta who
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missed the initial training for some reason, do not carry out the task until they too have received the appropriate training.
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must be recorded, investigated, and acted upon. It goes without saying that the operation of the deviation system must be described in an SOP.
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Qualication and Validation, and in the PIC/S publication Recommendations on Validation Master Plan, Installation and Operational Qualication, Non-sterile Process Validation, Cleaning Validation, (PI 0062). Supplier selection and evaluation: There needs to be a policy on how suppliers are selected and evaluated, and whether initial or periodic audits are undertaken. Dealing with regulatory inspections and customer audits: After 1 May 2004, inspections of development manufacturing facilities by national regulatory authorities will become routine throughout the European Union. While it is not essential to have a document describing how these are handled, who is responsible, etc. it certainly will make for a smoother inspection if everyone who is involved knows what is expected of them. Similarly, contract manufacturers and analytical facilities are subject to many audits by clients, again a well-thought-out process for dealing with these makes the audit go more smoothly, which benets both the client and the contractor. These documents are also the place to put statements of company policy such as whether auditors are allowed to use cameras or video equipment on site. Such statements will not, at the absolute end, deter a government inspector who is collecting evidence, but if matters get to that stage, no SOP will protect you.
27.11.2
Personnel
Training of new personnel: This document describes the induction and general GMP training given to every new employee, and how their task-specic training is decided. There should also be written descriptions of how all training is documented. Finally, the requirement for periodic refresher training in relevant parts of GMP ought to be specied. Job descriptions and curricula vitae (CV): A job description, so that sta are clear on what they are expected to do, and a CV, so that the prior experience of each sta member is clear, are important documents to show, together with the training record, that each member of sta has the experience, education and training (or any combination of these) to carry out his or her specied duties. The system should be specied in an SOP. Curricula vitae for consultants: Consultants can be used for the whole range of GMP activities, if an organisation so wishes. However, like regular sta, it is important to be able to show they were appropriate for the job they carried out, so an SOP should specify that a detailed CV will be obtained from each consultant, preferably before they carry out the work, and should specify who is responsible for storing these. Factory clothing and personal safety equipment: There need to be one or more SOPs detailing the appropriate clothing to be worn in particular manufacturing or laboratory areas, and, if appropriate, how this is to be put on and removed. Similarly, if personal safety equipment (e.g. safety glasses, face shields, gloves, etc.) are required in certain areas, or for certain processes, this should be set out in the appropriate SOP.
27.11.3
Cleaning of facilities: There need to be SOPs describing how the various areas of the facility are cleaned, at what frequency, using what cleaning agents and processes, and how appropriate cleanliness is monitored. For less critical areas this might be simple visual inspection by the area supervisor, whilst for the most critical area there might be a sophisticated environmental monitoring programme. All of this needs to be described in SOPs, which should also describe how cleaning is recorded, and what happens if the cleanliness monitoring shows an area to be insufciently clean.
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Operation of all items of equipment (including cleaning): For each item of equipment used in the manufacture or testing of products, there need to be one or more SOPs detailing how the equipment is to be used, and how it is to be cleaned. This may also include how cleanliness is evaluated before the next use. This should include specication as to how equipment is to be labelled to indicate its status (e.g. Clean, awaiting cleaning, in use, etc.). The routine maintenance and calibration programmes for the item also need to be specied in writing. Routine monitoring of temperatures, humidity, etc. in controlled areas: In any manufacturing or testing area where the temperature, humidity or other environmental parameter is critical, there must be a system to monitor that parameter. This might be as simple as routine temperature monitoring of a warehouse, with fairly wide limits, or it could be the sophisticated monitoring programme for an aseptic lling room, where temperature, humidity, relative air pressurisation, and non-viable airborne particulate matter all need to be monitored and controlled with tight limits. In addition, the SOPs on such monitoring should describe what actions are to be taken, by whom, in case the monitored parameters go out of the specied limits. Maintenance of utilities and equipment: As appropriate, these can either be included in the SOPs for operating the item or service, or separate SOPs can be set up. The choice should be made on the basis of convenience for the users of the documents. Calibration: Without calibration, measurements are of very little value. There must, therefore, be SOPs setting out the calibration programme for all critical measuring equipment, including how the frequency of calibration is established, setting out the tolerances on calibration, and nally detailing what is done, by calibration engineers, equipment users and QA, when a calibration exercise nds that an instrument is out of its tolerance limits. Equipment and facility qualication and re-qualication: There need to be policies on qualication (see Chapter 34), to describe the responsibilities of the sta involved, how protocols and reports are written and approved, and what is done when a validation exercise does not meet the acceptance criteria. Re-qualication may be appropriate after major maintenance, after significant change, after unexplained failure, and for certain critical equipment, periodic re-qualication may be appropriate. The SOP needs to describe how the decision on re-qualication is made, and how the set of tests that consider re-qualication are decided. If not set in the Validation Master Plan, this SOP also ought to set recalibration periods for critical equipment.
27.11.4 Documentation
The SOP system: This is the rst SOP needed, describing, SOP format, preparation and approval, distribution, amendment and periodic review and SOP training. Other documents: There are several other types of documents needed, such as specications, master formulae, process instructions, batch manufacturing records and other general records. The systems by which these are prepared, approved, issued and amended need to be specied in one or more SOPs. Obviously, these systems will be easier to run if they share as much as possible with the SOP system. Completion of records: There need to be one or more SOPs that set out how records are to be written (in permanent ink, of course), how corrections are made to erroneous entries in records, and how numbers are rounded. If the organisation is large, or if the policy is to use initials in place of full signatures, then there also needs to be a signature log, like everything else, which needs to be described in an SOP. Record retention: The requirements for retention of records which are set in the GMPs, but there should be an SOP setting out the organisations minimum retention periods, and how the decision whether to destroy a document when its retention period is up is made.
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27.11.5
Production
Receipt of raw materials: How raw materials are received, inspected and where they are stored, both when in quarantine and after release for use (see Chapter 28). Manufacturing processes: Much of the detail in a manufacturing process can appropriately be included in the batch manufacturing record (see Chapter 29), which becomes both an instructional document as well as the raw data concerning manufacturing. Additionally, there should be SOPs detailing how to operate the process equipment. However, it could be that certain manufacturing activities could be usefully described in SOPs. In-process sampling and testing: Detailed sampling instructions can be included in batch manufacturing records, but it may be appropriate to have these activities set out in SOPs instead. Packing and labelling processes: Just as for manufacturing processes, these may be described in batch packing and labelling records (see Chapter 28), or in SOPs, as is convenient for the organisation. One topic that is perhaps better dealt within an SOP is the matter of reconciliation of product and packaging materials, including the acceptable range for reconciliations and the actions taken if these limits are exceeded. Label printing, etc: If labels are printed in-house, then detailed SOPs are required covering how the text is generated and how the labels are printed. Whatever the source of the labels, SOPs are needed to cover how labels approved by QA or quality control (QC) are stored and issued, how label reconciliations are performed, the tolerance on reconciliation and what is done when these tolerances are breached, and how additional labels can be prepared and how excess labels are destroyed. Material labelling: As materials move around the facility, there needs to be clarity on their identity and status. There must therefore be SOPs describing how materials are to be labelled, both as to identity and status.
27.11.6
Quality Control
Receipt and labelling of samples: An analytical result is of no value if the sample is not representative (dealt with in sampling SOPs), and if it is not certain what it represents, and if the sample has been stored under incorrect conditions. There must, therefore, be an SOP describing how samples are logged into the analytical laboratory, how they are labelled, how they are to be stored, and how they are issued to analysts for study. Analytical methods: These are often considered as a separate class of documents to SOPs. However, whatever they are called, they still need to be reviewed, approved, issued, and in general, controlled in a similar way to SOPs. Out-of-specication results handling: A critical SOP, this should spell out in detail the steps taken when an out-of-specication result is obtained. Preparation of certificates of analysis: The certificate of analysis is both a summary of the analytical data, and, in some situations, the document that shows that a batch of product has been released for use or distribution. Label inspection: This SOP or SOPs should cover how label text is veried prior to printing, how printed labels are sampled and inspected, and how any variable information overprinted on labels (most typically batch number and expiration date) is veried. Sampling (including retention samples where appropriate): Without samples that are representative of the batch of material sampled, analytical work is of little value. There, therefore, need to be SOPs describing how samples are taken from raw materials, intermediates and nished products, what sample containers are used, how these are to be labelled and stored before analysis. The sampling tools, and how these are cleaned, also must be described. Additionally, there is a requirement that
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samples of starting materials and nished products are retained, so there needs to be an SOP on how these are taken, labelled and stored. Labelling of raw materials: It is important that raw materials are traceable, that is it is possible to unequivocally identify the batches of raw material that were used in a batch of nished product; furthermore it is an important part of GMP compliance that raw materials that have not been approved by QA or QC are not inadvertently used in manufacture (see Chapter 28). The mechanism by which traceability and status are controlled can be via labelling alone, or it might be achieved by a computerised inventory management system that only allows allocation of released batches for manufacturing. However it is achieved, there will be a requirement for labelling of raw materials on receipt, and possibly when released for use. All of this needs to be specied in SOPs. Examination of retention samples: It is a requirement of US GMP that retention samples are examined visually every so often. Although it is not a specied EU GMP requirement, it might be appropriate to adopt this as it requires little effort, and can reassure that major problems have not arisen. If it is to be done, then of course the process needs to be described in an SOP. Stability testing: For a product in development, stability studies following ICH guidelines are necessary to establish a shelf-life (see Chapter 29). Once a product has been approved for marketing, regular stability testing, perhaps on one batch per year, is necessary to demonstrate that the shelf-life claim is actually met in real production conditions. Lastly, if a process, equipment or material change might have an impact on product stability, again a stability programme is required. Therefore, there must be an SOP describing how stability studies are designed, executed and reported.
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cars. You hope that it will never be needed; but in event of an emergency, it is vital that it works rst time. So it is with the recall procedure. Therefore, it may be worthwhile including a provision for periodic mock recalls, where the systems are tested without actually recalling the product.
27.11.9
Self-Inspection
Internal audit procedure: This SOP sets out what is covered by the internal audit programme, who carries out the audits, at what frequency, how the audits are reported, and how any negative observations are dealt with (see Chapter 31). One important point is that reports, or summaries of the most significant ndings, must be given to senior management, both so that they understand the situation within their own organisation, and so that appropriate resources can be devoted to dealing with problems.
27.12 CONCLUSION
Although SOPs are not the sole requirement for achieving well-controlled and efcient manufacturing and testing of pharmaceuticals, and are not the sole criterion of GMP compliance, there can be no doubt that a well-designed SOP system is a major tool in achieving both goals.