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Quality Inspection: Making the Most of Your Processes

Quality inspection results should be included as part of the batch release documentation, says Susan J. Schniepp, distinguished fellow at Regulatory Compliance Associates.

 

Q: My company is a contract manufacturer. Our final product inspection process consistently delays timely release of the manufactured products to our clients. Is there a best process/practice for performing a quality inspection?

 

A: This is not a new problem for the industry. To me, some of the issue is the fact that we call the specific activity of the overall physical product evaluation the “final product inspection.” In my opinion, the physical product evaluation should start at the beginning: the receipt of the individual components (stoppers, vials, labels, etc.) that are used in manufacturing.

 

Quality Inspection

 

Each component should pass an incoming quality inspection with defined acceptable quality limits (AQL) and clear directions for rejection of the component should it exceed the AQL. The specific elements to be looked at on incoming inspection will vary depending on the component.

 

Let’s assume your company manufactures sterile injectable products and the major component you will use in manufacturing is a glass vial. The first step in the process is to perform an incoming inspection of the glass vials. The number of vials to inspect from the shipment will depend on the number of vials contained in the shipment. The sample size to be inspected should be recorded in the appropriate standard operating procedure (SOP). The specific defects to be inspected should also be included in the SOP.

 

Quality Control Inspection

 

When evaluating quality control defects, most companies employ definitions of critical, major, and minor to the reject/accept criteria. In the case of vials, critical might be defined as likely to cause harm to the patient; major might be defined as leading to impairment to the patient; and minor would be defined as cosmetic defect causing no threat to the patient. Defining the acceptance criteria upfront may save you a lot of time at the end of the process.

 

Once the vial is accepted, it will be used in the manufacturing process. Defects that exist in the vial after initial acceptance may be detected during this step of the process. Many manufacturing lines have automatic sensors that detect vial imperfections and eliminate the vial from the batch before it is sent for labeling. The line operators need to be trained to recognize when there is an increase in rejected vials because this could mean that the incoming inspection did not pick up the vial defect. Again, if the defect can be detected and categorized at this process stage, it will save time at the product release stage.

 

Quality Assurance Inspection

 

The last quality assurance stage before labeling would be visual inspection of the stoppered vial. Some companies perform this step manually with trained visual inspectors while others utilize visual inspection equipment to perform the final inspection of the vial before labeling. Companies using vial inspectors typically focus those inspectors on looking for particulates in the vial, but they should also be trained to recognize vial defects. Regardless of which inspection format is used, there should be SOPs and AQLs governing the inspection process.

 

Final product inspection results should be included as part of your , so it is important to have repeatable, defined process/processes in place at all stages of the manufacturing process that is/are suitable for the product being inspected. The more time you spend upfront in the component inspection process, the more efficient your quality checks in manufacturing and batch release process will be.

 

Article details

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Pharmaceutical Technology
Vol. 47, No. 12
Page: 34

 

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Biologics Investigation

biologicsContract manufacturing organizations that manufacture traditional and biotech pharmaceutical products are responsible for performing investigations and reporting the results to their clients. But how do biologics consultants recognize the differences between performing an investigation of a biologic product versus pharmaceutical products?

 

Biologics Manufacturing

 

The short answer is there is no process difference when performing deviation investigations for traditional pharmaceutical products vs. biologic products. The differences lie in the complexity of the manufacturing processes. Further, these are the variables that should be considered regarding what could impacted the deviation.

 

Biotechnology Process

 

Chemical processes, although sometimes quite complex, often have fewer variables even though many of the categories are the same. For instance, when investigating an unknown impurity in a biological process from an oligopeptide fermentation process, the considerations are many. This often includes understanding the fermentation conditions, such as time, temperature, oxygen uptake and byproduct production.

 

Contamination

 

Moreover, potential contamination of reactants can include master cell banks and fermentation reagents, equipment integrity, and overall performance. Further considerations for the downstream purification process variables and the effect of a final configuration (e.g., folding) also need to be considered.

 

The purpose of a deviation investigation is to determine why the deviation happened and what its impact was on the product quality. To determine the impact of the deviation on biotechnology engineering in general, it is critically important to find the deviation root cause.

 

Root Cause Analysis

 

Conducting a root cause analysis is especially important when considering the COVID-19 pandemic and global impact on biological matrix supply chain. Small cap or start up biologics companies have virtually no room for production errors in this type of environment. For example, patients may be waiting for biologic medications and any production interruption can impact more than just the manufacturer. 

 

The process used in the industry to determine root cause is, of course, the investigation procedure. This procedure, regardless of whether the product is biotech or traditional, should require the investigator to review various production systems. Equally important, the system review during the investigation should help determine whether they were the cause of the deviation under investigation.

 

Engineering Validation

 

Every biologics consultant understands it is important to remember when performing an investigation to keep in mind a few general rules. Naturally, one size does not fit all. Simple errors require simple corrections while serious deviations require broader investigations. Validating the investigation is related not only to the seriousness of the deviation but also to the complexity of the factors that could influence the outcome.

 

Fishbone Diagram

 

The best tool to have during any investigation is inquisitiveness. Continuing to ask questions and avoid assumptions will lead to a better outcome. Using other tools, such and fishbone diagrams and determination of most probable number (MPN), are always encouraged. Undeniably, they do not take the place of a biologics consultant asking questions.

 

Biologic Performance

 

In performing an investigation, it is important for the biologic investigator to widen their performance perspective and look for ways to relate similar issues. The best way to ensure events are not related is to try and relate them, not the other way around. Keep in mind that human error is rarely a true root cause. There is usually something in the process that causes that human error.

 
And finally, always verify the facts of the investigation. It is also important to include a historical review. This review should determine if the deviation occurred with this or other products, with the specific manufacturing line or other manufacturing lines, and/or with the operators.

 

Biopharma Tools

 

The historical review can help to prioritize the resources and detailed system review. In addition, many biopharma companies make use of tools (fishbone diagram, MPN) to help prioritize resources. These tools, if used correctly, can be helpful in determining root cause. However, keep in mind they are just tools and do not take the place of thinking.

 

The detailed investigation should include a review of various systems. The systems most often reviewed are equipment and machinery, the manufacturing process, the raw materials used in manufacturing, the specifications, the environment, and finally, the operators.

 

Finally, this is not to imply that these systems are the only areas you should look at during the investigation. These are simply the most probable areas where you will uncover the root cause of the deviation.

 

CAPA & Corrective Action

 

Each investigation must address the following elements: root cause, impact to the material or product, the immediate correction taken, the corrective action to prevent re-occurrence for specific product/operation, and the preventive action taken to prevent re-occurrence for all products/operations.

 

Once these elements have been investigated, results from the investigation must be documented. The written narrative should clearly explain what happened, when it happened, and who was involved or observed what happened. The narrative documents the solution and rationale for the root cause that was determined through the investigation process.
 

Quality Assurance

 
The key to any successful investigation is not assuming you have the solution prior to completing the investigation. Increase your quality assurance and compliance by asking questions until you can think of no more questions to ask. Be sure to document the answers to your questions.
 
 
If you follow your investigation procedure and thoroughly document your results, you should have an acceptable investigation regardless of whether you are manufacturing a traditional product or a biotech product. 

 

 

BioPharm International
Vol. 28, No. 11
Page: 46–47

 

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Compendial Methods & Pharmacopoeias

Experts Susan J. Schniepp, distinguished fellow for Regulatory Compliance Associates® (RCA), and Steven J. Lynn, executive vice-president of Pharmaceuticals for RCA, discuss the verification of compendial methods.

 

Q. Are compendial methods considered validated?

 

A. According to the pharmacopoeias, compendial methods are validated—that’s about as simple as it gets. The United States of Pharmacopeia National Formulary (USP–NF) states,

 

“…users of analytical methods described in USP–NF are not required to validate the accuracy and reliability of these methods but merely verify their suitability under actual conditions of use”

 

European Pharmacopoeia

 

The European Pharmacopoeia (Ph.Eur.) and the (JP) also consider their methods validated. Ph.Eur. states:

 

“The analytical procedures given in an individual monograph have been validated in accordance with accepted scientific practice and recommendations on analytical validation. Unless otherwise stated in individual monograph or in the corresponding general chapter, validation of these procedures by the user is not required”

 

Japanese Pharmacopoeia

 

The Japanese Pharmacopoeia says:

 

“when an analytical procedure is to be newly carried in the Japanese Pharmacopoeia, when a test carried in the Japanese Pharmacopoeia is to be revised, and when the test carried in the Japanese Pharmacopoeia is to be replaced with a new test according to regulations in General Notices, analytical procedures employed for these tests should be validated according to this document”.

 

Validation

 

Supporting validation information for pharmacopeia methods is retained by the compendial authorities and not by the users of the methods. However, this does not change the fact that the official methods in these publications are supported by validation information.

 

Verification

 

regulatory compliance

The methods need to be verified as suitable for use in the user’s laboratory. The USP–NF and the Ph.Eur. both describe the requirements for verification in their respective compendia.

 

Compendial Procedures

 

The USP–NF and Ph.Eur. explicitly require that compendial procedures demonstrate suitability under actual conditions of use. This information can be found in General Chapter, Verification of Compendial Procedures <1226> in the USP–NF, and General Notices in the Ph.Eur. (1,2).

 

On the other hand, the European Directorate for the Quality of Medicines (EDQM) stipulates on their website:

 

“When implementing a Ph.Eur. analytical procedure, the user must assess whether and to what extent its suitability under the actual conditions of use needs to be demonstrated according to relevant monographs, general chapters, and quality systems.”

 

In other words, it is the user’s responsibility to transfer the procedure correctly” 

 

Monograph 

 

Once a monograph has been established and it is accepted that the published method is validated, users of the monograph need to verify that the method is suitable for determining the product quality. Moreover, the purpose of verification is to establish that the official method is reproducible when used by others.

 

Lab Equipment

 

The monograph sponsor proves the method works for its product with the manufacturer’s analysts using the firm’s laboratory equipment. They have already met the basic International Council for Harmonisation (ICH) requirements for reproducibility, repeatability, and intermediate precision. 

 

The task for the user of the USP monograph is to prove the published method is reproducible. Additionally, any analyst for their company’s product should be capable of testing using the lab equipment.

 

Test Methodology

 

There is no absolute guidance for verification requirements. Companies must decide for themselves how they will establish the method is verified and suitable for their product. Lastly, the test methodology verification will depend and fluctuate based on complexity of the test method.

 

Chromatographic

 

Chromatographic methods should, at a minimum, meet the system suitability requirements defined in the official method. Conversely, other method parameters, such as accuracy and precision, may be considered.

 

Microbiology

 

Method performance can be accomplished by using performance characteristics such as blanks in chemistry or un-inoculated media in microbiology. Finally, laboratory control samples and spiked samples for chemistry, or positive culture controls for microbiology to assess accuracy.

 

Training Records

 

Technique-dependent methodologies should not require verification. These methods include but are not limited to loss on drying, pH, residue on ignition, etc. Technicians should be trained, and their training records maintained, demonstrating their ability to perform the method regardless of the material being tested.

 

Lab Procedures

 

To simplify activities for their analysts, many companies translate monograph instructions into laboratory procedures. Although this practice has its benefits, it can also lead to compliance concerns.

 

Nevertheless, the author recommends that a baseline comparison be made between the standards and the internal testing documents to minimize this risk. Further, the comparison does not need to elaborate, but should focus on critical parameters for test methods.

 

System Requirements

 

Equally important, the reader may also want to consider reference standard usage, system suitability requirements, or other parameters that may help establish equivalency to the compendial methods.

 

Critical to Quality (CTQ)

 

Finally, the criteria listed above should not be considered all-inclusive. Establishing an internal method that complies with the official pharmacopeial method is critical to quality (CTQ). After all, many different users may have other requirements to consider for their specific laboratory usage.

 

 

regulatory compliance

 

Article details

Pharmaceutical Technology
Volume 46, Number 4
Page: 58

 

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GMP Training

Q: I am in charge of GMP training for a contract-manufacturing site with approximately 350 employees. The budget for my department was recently cut, and now I am struggling to get my employees to training. I know that this will become a potential item when my clients inspect me. Do you have any suggestions on what I can do to remedy this situation?

 

A:  This is a great question. It seems cutting the gmp training and travel budgets are the first austerity measure companies take when they are facing some budgetary difficulties. In my opinion, training should probably be one of the last areas that should have its budget cut because training is one of the key elements management can use to assure their commitment to consistently producing a high-quality product. It is also a GMP requirement.

 

The US regulations, 21 Code of Federal Regulations (CFR) 211.25, define personnel qualifications and state:

 

“Each person engaged in the manufacture, processing, packing, or holding of a drug product shall have education, training, and experience, or any combination thereof, to enable that person to perform the assigned functions. Training shall be in the particular operations that the employee performs and in current good manufacturing practice (including the current good manufacturing practice regulations in this chapter and written procedures required by these regulations) as they relate to the employee’s functions. Training in current good manufacturing practice shall be conducted by qualified individuals on a continuing basis and with sufficient frequency to assure that employees remain familiar with CGMP requirements applicable to them”.

 

cGMP Training

 

Just because your budget is cut, however, doesn’t mean you can’t make sure employees receive meaningful training. There are many organizations and companies that offer cGMP training on many webinar topics. These can range from “How to Write Effective SOPs” to “How to Perform an Effective Technology Transfer” to “Risk Management Strategies for Quality Management in the Pharmaceutical Industry.”

 

Some of these webinars are free and some require a registration fee. They are usually 90 minutes in length, and many offer an opportunity to ask the speakers questions through a chatroom feature. If you are unable to listen to the webinar live, you may have the option to purchase a recording of it and listen to it at your convenience. The recorded option offered with these webinars can be valuable for training employees who work on the second and third shifts that can often be challenging.

 

GMP Training Certification

 

In some cases, the webinar may offer continuing education credits for GMP training certification for attending. The companies offering these webinars advertise them well in advance of the event and often send out multiple reminders. The advertising for the webinars highlight who will be speaking, their qualifications, what they will cover in the training, and what you will learn as a participant.

 

In addition, they will also make recommendations on who should attend so you can determine if this is appropriate training for your employees.  This information should be printed out and used to demonstrate the appropriateness of the training during an audit.

 

FDA Training

 

FDA also offers training through the FDA Learning Portal for Students, Academia and Industry at www.fda.gov/Training/learningportal. This training, FDA reports:

 

“… provides educational resources related to FDA’s regulatory, product quality, and safety responsibilities. In each section you’ll find educational materials such as lectures and courses as well as web pages related to the particular topic.”

 

Some of the topics available include courses titled FDA 101, FDA’s Regulatory Framework, Current Initiatives, Human Drug Approval and Post-marketing. The modules also provide a course objective so you and your employees will understand what they should know after completing the training.

 

For example, there is also a module called A Tour of FDA, which, FDA states, will provide an understanding of FDA’s public health mission and how the agency is organized to carry out its mission (2). FDA also broadcasts some of its public meetings depending on the topic.

 

The agency’s public meeting regarding its Request for Quality Metrics Guidance for Industry was a great way to learn about the new guidance and what industry colleagues were thinking. This is another way employees can keep up-to-date on the current issues facing the industry.

 

GMP Training for Employees

 

Finally, for some personnel groups, GMP training for employees consists of discussions of current topics. This can include industry warning letters, 483s, or new guidance documents may be a low-cost alternative to a formal training experience. These discussions can be led by qualified company personnel and can cover not only the specifics of the issues but the rationale behind them. As with all other training, these discussions should be documented in your training system.

 

The bottom line is even though your budget has been cut there are still opportunities to get your employees the required needed training that will satisfy your customers in audits. You should sign up to receive emails from companies and organizations that offer online training, review them to determine if they are applicable to your operations, determine who should attend from your company, and make sure you document their attendance for their training record.

 

In addition, you should also monitor the FDA website for potential upcoming webcasts, past webcasts, and other public offerings that will help you and your employees receive the necessary training even with a limited budget.

 

Article Details

 

RCA

 

Pharmaceutical Technology
Vol. 40, No. 12
Pages: 66, 65

 

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CAPA Preventative Action: Getting Drug Quality Right

A well-functioning Corrective and Preventive Action (CAPA) program can make the difference between a deviation being corrected and prevented the first time. The consequence is reoccurring deviations that require reopened investigations — wasting limited resources and potentially causing product quality issues.

 

CAPA

It’s important to remember that a well-functioning CAPA program starts with a well-functioning investigations program. After you recognize you have a problem, the first step is investigating the deviation and determining the root cause. The root cause(s) will direct how, what and where the company will take corrective and preventive action.

 

Preventive Action

CAPAAs regulators note in ICH Q10, “CAPA methodology should result in product and process improvement and enhanced product development.”

 

In his book, quality consultant Phillip Crosby states, “Quality is free. It’s not a gift, but it’s free. What costs money are the ‘unquality’ things — all the actions that involve not doing jobs right the first time.”

 

QMS CAPA

To that end, setting up a CAPA quality system (QMS) must be surrounded by adequate standard operating procedure (SOP). Each SOP should monitor and include metrics to ensure nonconformances do not occur in the future. Especially when considering CAPA in pharma; this is the least costly way to deal with regulatory issues or product defect problems.

 

While the two terms in the CAPA acronym may sound similar, there are crucial differences between ‘corrective action’ and ‘preventive action’. If an FDA investigation and corresponding CAPAs are initiated, then both the corrective and preventive actions would be addressed to determine the root cause.

 

CAPA Quality Assurance

Further, impact on material or product and the direct correction to the issue (i.e., immediate correction) should be well documented. Corrective actions are taken to prevent the reoccurrence for a specific product or operation, while preventive actions prevent any occurrence for all products or operations.

 

One of the most useful strategies during a CAPA audit is to ask questions and avoid assumptions. A fishbone diagram, fault tree analysis or the ‘5 Whys Method’ are robust tools that often help determine adequate root cause.

 

CAPA Records

When conducting the investigation, companies must review multiple systems including manufacturing processes, machinery, equipment, environment, specifications, raw materials and people.

 

Deviations are not limited to these systems. Other systems should also be evaluated as necessary, but many deviations do reside within one of the listed systems.

 

CAPA Effectiveness

Another way to look at CAPA effectiveness is the metaphorical horse with blinders. Imagine the blinders are used to keep the horse focused and moving forward. This same metaphor can be used to think about the investigation and CAPA process.

 

If you go in with blinders on, just looking at the issue without reviewing other interconnected systems, important details can be missed and more costly problems may result.

 

CAPA Systems

Once all the elements of the deviation have been investigated, the narrative and its linked CAPAs should explain when and what happened. Documentation should also be included in your CAPA system for who was involved.

 

The narrative should also document the solution that was implemented to correct and prevent the reoccurrence of the issue. This includes a rationale for the root cause identified during the investigation. All these items should be well-documented within your quality system.

 

CAPA for Quality

A robust CAPA program designed to improve quality should include a well-documented system that identifies the root causes of a deviation. This includes the nonconformance, system failures, or process problems.

 

In addition, the CAPAs must address each of the root causes and identify the corrective action for remediation. Only after careful consideration about the deviation can the appropriate correction prevent the deviation from happening again.

 

CAPA Manufacturing

Qualified staff (with proper training, education, and experience) should run the CAPA program. Incorporating meaningful metrics to track the performance of overall systems can help provide early warning signals for deviations/nonconformances.

 

An appropriate Subject Matter Expert (SME) should be included in the process. Management should review potentially adverse information, oversee the overall adequacy of the CAPA program, and remediate identified deficient areas, including those that may need capital investment.

 

CAPA Quality

Once the appropriate solution for improving quality has been implemented, evaluating the solution’s effectiveness should be ongoing. There should be a process for monitoring the recurrence of the deviation and the closing out of the CAPA once the solution has been confirmed effective. All these items must be documented within the quality system.

 

The same level of depth and rigor of a CAPA for one issue may not be required for every deviation. For example, a small documentation error will likely only require a simple correction. More serious deviations, like a confirmed Out of Specification (OOS), will demand a much more robust investigation and CAPA. 

 

Deviation Meaning

The complexity of the deviation and its concomitant CAPAs not only determine the approach taken for the investigation but also inform the timeline. For example, while some standard operating procedures may call for a 30-day timeline for investigations and CAPAs, that timeline may need to be extended. Identifying the priority of the deviation helps the entire team to recognize meaning. 

 

In this case, you’d need to document the rationale for the extension and get the quality department’s approval. A critical caveat here is everything in the investigation leading to a CAPA does not need a time extension. If your company is extending a lot of investigations, then it may indicate another entirely different problem.

 

Pharmaceutical Manufacturing

The key to establishing a successful CAPA is a complete and thorough investigation focused on finding the reason the deviation occurred. This is essential in pharmaceutical manufacturing as well as many other regulated industries. 

 

Failure to identify the correct root cause will result in possible failed effectiveness checks and the dreaded reopening of the CAPA. Everything plays a part in the investigation: people, machines, materials, processes, etc.

 

CAPA Audit

Management of these players is key to identifying the deviation’s root cause. The audit process behind the investigations is crucial in addressing the issue at hand. The aim shouldn’t be to find a single root cause that management believes to be the reason for the failure but to analyze all possible root causes across all systems.

 

If an identified root cause isn’t the true reason for the failure, then the root cause can be eliminated. Each root cause eliminated narrows down the investigation. Any potential root cause that cannot be eliminated must be remediated, even if that root cause is not THE root cause of the failure.

 

Root Cause Analysis

A mistake companies make is identifying a root cause that needs remediation and stopping there. Companies should always identify all possible root causes and address them accordingly. When executed correctly, CAPAs help organizations remediate deviations/issues before they cause more technical problems and escalated costs.

 

A practical example of an investigation and CAPA process is as follows: Company X had an investigation related to the detection of nonconforming vials, which were discovered prior to packaging. The inspectors on the line found the nonconforming vials, informed the quality team, and an initial investigation ensued.

 

Quality Assurance

The quality assurance team correctly put the lot on hold while the investigation was being conducted. During the early phase of the investigation, the nonconforming vials were sent away to be analyzed by a third-party qualified laboratory. The results came back stating the discoloration was due to chemical contamination.

 

The chemical in question was not part of the formulation or the container closure system and was not on any product contact surfaces within the equipment. Company X eventually decided the contamination happened at the vial manufacturer and closed the investigation. One week after the initial observation of the discolored vials was opened and closed, the same issue arose with another product and the original investigation was reopened.

 

Forensic Investigation

The company subsequently audited the vial manufacturer, but the results were inconclusive, with no identified source of the chemical responsible for the nonconforming vials. The company continued manufacturing while the investigation was ongoing and began a 100% incoming material inspection.

 

A week later, a line operator noticed a vial exiting the depyrogenation tunnel that had a discolored blob in it. Manufacturing was stopped and the vial was sent to the contract lab for analysis. Once again, the chemical in question was the culprit.

 

Supplier Audit

The company sent a consultant to do a supplier audit of the vial manufacturer while they continued manufacturing the product. Similar to the initial for-cause audit, the external consultant could not find the source of the chemical leading to the nonconforming vials.

 

Finally, after opening the line for inspection, the company discovered that the contaminating chemical was associated with the HEPA filters. Manufacturing was finally halted on the line.

 

Corrective Action and Preventive Action

After completing a more thorough investigation, the root cause was determined to be faulty cooling valves in the depyrogenation tunnel. This was previously identified by the company as a potential root cause in the initial investigation, but was not pursued because it was classified as ‘possible but highly unlikely’ and ranked lowest on the priority list.

 

There was no alarm associated with the cooling valve which explains why the issue was not caught under routine maintenance checks. Once the problem was correctly identified, the proper and effective corrective action could be taken, including the potential costly endeavor of evaluating all products made on the line and looking at other lines with the same depyrogenation oven.

 

Cost of Poor Quality

Hypothetically, let’s say the cost of a critical deviation for Company X is a million dollars. We start by looking at the cost of poor quality (COPQ) of a defect.

 

The cost is eliminated only if the pharma company’s quality management system (QMS) is organized. This includes the QMS system being designed to detect, investigate, correct and prevent issues/deviations.

 

QMS System

If the company can prevent defects with their robust QMS, they will save money because they allocated sufficient qualified resources toward an efficient QMS — which in turn meant they didn’t have to address many defects/deviations and CAPAs. Hence the quality system pays for itself.

 

If the issue is detected within the company before anything is shipped out, the cost rises tenfold to ten million dollars. This is due to the company needing to address the now-detected issue and implement corrections (corrective action) to rectify the issue. Additionally, the team would put measures in place to ensure issues do not occur in the future (preventive action).

 

Forensic Analysis

Finally, if the company detects an issue in a drug product after it has been released by the quality department and delivered to the customer, the cost raises tenfold again. The forensic analysis must now include the cost of recalls, as well as corrective and preventive actions. The cost of quality is important to understand — for Company X, they caused themselves a $100 million mistake.

 

Company X initially thought the issue seemed small and negligible, which led to an unfortunate quick closure of the investigation. Ultimately the deviation affected twenty-eight lots of manufactured products. These lots, produced over a two-month period for several clients, were rejected due to the nonconforming vials.

 

Root Cause Strategy

Company X should have utilized a more thorough investigation and root cause strategy to follow every possible root cause. Instead, the company chose what seemed like the easiest root cause and jumped to the wrong conclusion. Then the company quickly closed this initial investigation without a complete and thorough investigation. In conclusion, this mistake created a bigger issue and a compliance and business risk.

 

It takes diligence, thoroughness and a healthy number of questions to ensure you investigate, correct, and prevent problems. But without this, the quality and efficacy of the drug product being manufactured could be jeopardized. 

 

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GMP Pharmaceutical Standards

Good Manufacturing Practice (GMP)

 

Maintaining good quality control practices throughout the entire manufacturing process requires robust GMP development, a drive toward product and process understanding, and pre-established, comprehensive written procedures that are consistently reviewed and updated.

 

Good manufacturing practice (GMP) is established by regulators to ensure that pharmaceuticals are safe and effective for the patients that rely on them.

 

21 CFR Parts 210 and 211

 

In the United States, requirements governing finished pharmaceutical quality are described in the Current Good Manufacturing Practices (CGMPs) regulations established by FDA and published in the Code of Federal Regulations (Title 21 of the CFR, parts 210–211 for most finished pharmaceuticals).

 

FDA also publishes guidance to further describe recommended practices for complying with the CGMP regulations. The agency states that “CGMPs provide for systems that assure proper design, monitoring, and control of manufacturing processes and facilities. Adherence to the CGMP regulations assures the identity, strength, quality, and purity of drug products by requiring that manufacturers of medications adequately control manufacturing operations” (1).

 

Quality Management

 

In Europe, GMPs are defined by the European Commission in EudraLex–Volume 4–Good Manufacturing Practice (GMP) guidelines (2), which were first published in 1989.

 

EudraLex states that quality management is “a system of marketing authorizations [that] ensures that all medicinal products are assessed by a competent authority to ensure compliance with contemporary requirements of safety, quality, and efficacy” (2).

 

GMP Certified 

 

To harmonize GMPs and other quality requirements worldwide, the International Council for Harmonization (ICH) works with international regulators and industry to develop common guidelines across the industry to ensure consistent quality expectations worldwide.

 

“At its core, CGMP is a science- and risk-based focus on assuring drug quality. As described in ICH Q10, Pharmaceutical Quality System, an overall attitude to drive meaningful and continuous improvements from the quality unit and other manufacturing employees is essential” (3), FDA told Pharmaceutical Technology.

 

GMP Manufacturing

 

The global nature of the pharmaceutical supply chain requires regulatory agencies to inspect and govern GMPs at manufacturing facilities. These inspections sometimes result in actions by regulators (e.g., FDA 483s, warning letters, import bans, and court actions) against companies that fail to follow GMPs.

 

Common CGMP deficiencies cited by FDA in warning letters sent to pharmaceutical companies inspected during the past year include failures to ensure product sterility, ensure data integrity, create quality control units, and develop and follow written procedures (4–7).

 

GMP Practices

 

“Companies should vigilantly encourage GMP practices that reflect the most current and robust methods of processing and control, and with a focus on providing a quality product to US consumers,” says FDA.

 

“The approach to successful CGMP is not merely a check-box approach where a single obstacle can be identified, nor is it meant to be unchanged throughout the life of a product or a CGMP facility. Using a holistic and quality risk management approach, a manufacturer can select and study specific products and processes with the goal of continual improvement of product quality and quality systems and widespread optimization.”

 

Quality Culture

 

So how do companies ensure they are “vigilantly” following GMPs and avoid the wrath of regulators? The answer appears to be found in a company’s “quality culture” and in the development, writing, and following of written procedures. Performing pharmaceutical manufacturing according to GMPs involves a dedication to quality throughout development and manufacturing processes.

 

“Corporate management plays a vital role in this endeavor by establishing a commitment to quality, which includes providing sufficient resources and oversight for manufacturing operations. There are many elements to successful implementation of CGMPs but measuring and monitoring quality indicators and managing change are key among them,” says FDA.

 

GMP Certified

 

According to Susan Schniepp, distinguished fellow at Regulatory Compliance Associates, becoming GMP certified throughout all processes and procedures involves a combination of personnel training, keeping tools and equipment updated, having a strong quality unit, and developing a quality culture at all levels of the company.

 

“How the company goes about achieving this objective is what is critical. Traditional training may not be enough. There should be constant on-the-job training and oversight on a continual basis. Upgrading tools and equipment, especially computer-driven programs, needs to involve IT departments and adhere to the current data integrity concepts,” says Schniepp.

 

“No one element will be able to sustain GMPs. All the elements work together to establish a culture where sustaining GMPs is a priority.”

 

GMP Facility

 

Chris Moreton of FinnBrit Consulting agrees. “Too often, in my experience, certain factions in an organization think that quality is someone else’s responsibility. There may be an organizational chart that shows where the quality unit sits in an organization, but ‘quality’ (including GMP) is everyone’s responsibility within an organization; from the most senior to the most junior and vice versa.”

 

Management is key in creating a quality culture, says Moreton. “If the staff see the managers taking an interest and checking on things on a daily basis, the staff will respond, and they will try harder to get things right.”

 

Regulatory

 

A commitment to staying current with regulatory expectations is a must, according to Schniepp, and she warns that complacency is the biggest obstacle to maintaining GMPs.

 

“Once a process or procedure is established and functional, there does not seem to be the impetus to update and revise it as regulatory interpretation and understanding changes. This leaves the process or procedure compliant to outdated standards,” Schnieep says.

 

GMP Audit

 

Companies must also learn from prior mistakes, according to Mark Lynch, vice-president of Strategic Compliance. “It’s best to take the lessons learned from product experience and apply them to the culture overall so those lessons only need to be learned once. Those experiences should be continuously applied on the product level, and also used to make improvements to standard operating procedures (SOPs), policies, personnel, and technology.”

 

Problem solving is another technique that must be honed, according to Lynch. “Companies must also pay continuous attention to problem identification, solution, and improvement. Refinement of problem-solving techniques contributes to organizational learning.”

 

FDA cGMP

 

Enforcing quality procedures through a policy that ties failure to follow procedures with grounds for dismissal and using internal audits to detect improper performance are options to ensuring a quality culture, according to Lynch. “It is also important that tools are a regular topic of discussion with operators to capture improvements and assure consistency.

 

Additionally, sufficient supervisory presence and oversight are key both for monitoring purposes, and to be sure operators can raise questions and get the support they need. Finally, it’s best practice to put a GMP standard reporting mechanism in place that does not require identification, so employees feel comfortable flagging an issue without fear of blame,” he says.

 

GMP Quality

 

Companies who do not consistently maintain GMPs may find themselves under additional scrutiny by regulators for repeat offenses. A variety of FDA warning letters have pointed out repeat CGMP violations at companies and/or a particular facility (8, 9).

 

FDA reports that the agency, “… strives to provide clear guidance to companies proactively and in its enforcement actions. Where repeated violations have been found at the same facility or among different facilities of the same firm, we highlight those violations so that they may be addressed adequately.

 

Corrective Action

 

A focus on a commitment to quality is essential to correcting repeated violations, as are adequate corrective actions and procedures. While we generally encourage a focus on overall quality, there are times when we encourage firms to take specific actions, which are included in our warning letters as well as in applicable guidance documents and regulations.”

 

Repeated offenses may be a failure to look at the big picture and apply solutions across all systems and/or products, according to Schniepp. “Companies think in terms of solving the individual citation but fail to take that answer for change to a global look at fixing other processes and procedures that might be susceptible to the same observation. Tunnel vision when responding to warning letters has a great potential to result in repeat observations,” says Schniepp.

 

FDA Warning Letter

 

“Some of these ‘repeat mistakes’ are found to be FDA violations of the same section of the regulations but stem from a different problem. Investigators tend to use repeat findings as a way to point to simplified trends that make one issue appear to be really bad, rather than the complex combination of issues that it truly is,” Lynch says.

 

“Some companies lack the staff, procedures, capability, and time to fully investigate and solve problems, so they pick something (e.g., a personnel error), close the investigation, and move on to release product, and the same issue reappears because it wasn’t solved.”

 

Risk Management

 

Risk management and general cost increases can be another factor to repeated offenses, according to Moreton. “Often cost and/or short-term shareholder interests are used as an excuse to avoid some measures [to long-term change] … People complain that quality costs money, but if they really want to see how expensive things can be, they should try a consent decree.”

 

SOP Procedures

 

The lack of written procedures and/or a quality unit is another frequent infraction identified in warning letters. From October 2016 through September 2017, FDA issued more than 400 FDA 483 observations for a lack of written procedures or written procedures that were not fully followed (10).

 

Quality Program

 

Written procedures are key to a robust quality program, according to FDA and industry experts. FDA believes that the “most effective quality assurance (and compliance) strategies begin with robust internal procedures to adequately design and maintain a robust operation, and that can quickly identify and correct manufacturing problems when they occur.”

 

GMP Best Practices

 

What are best practices for developing written procedures for GMPs? While the agency does not endorse one particular approach to developing written quality procedures, FDA notes that these procedures should “be written to effectively communicate to the users of the procedure.

 

FDA recommends that the style and format of procedures be accessible to users, as well as ensuring adequate coverage of its purpose. We recommend that the effectiveness of a procedural training program be evaluated to ensure that personnel learn and can follow the procedures as intended.”

 

GMP Compliance

 

The trend in a GMP compliance failure to have written procedures is disturbing, according to Schniepp. She suggests that outsourcing quality, especially for start-up companies, may add to this problem. She questions whether outsourcing companies have the processes and procedures in place to handle new products.

 

Manufacturing Operations

 

A robust sharing of information between client and contract manufacturing organization is also key, including product and process understanding. “We need to also remember that new products, particularly in the biotech segment of the industry are novel in nature so the old way of doing business may not be applicable. Whatever the reason the industry must focus effort on making sure there are GMP lab processes, procedures, and written instructions in place that support the release of product,” Schniepp stresses.

 

Having all parties involved in the GMP labeling development of written quality procedures is necessary. “Including everyone affected by the procedure and writing the procedure with their input will result in streamlined and efficient procedures, which will be easier to maintain in the long run,” says Schniepp.

 

Standard Operating Procedure

 

Standard operating procedures (SOPs) written by people not familiar with the specific operation can cause disconnects, according to Lynch. “The best way to assure adequate SOPs is to sit down with people most familiar with operations and map out the process steps and handoffs. This can be incorporated graphically using [swim lane diagrams] and similar tools like Visio (Microsoft) and include them as part of the document.”

 

“In my opinion, in order to ensure that quality procedures are effective, it is necessary to involve those who know the process or operation being documented,” Moreton agrees. “This may mean sitting down with the operator and finding out exactly what is being done and how, not what management thinks should be done and how they think the operation(s) should be carried out.”

 

Operating Process

 

According to Schniepp, procedures should be mapped out, committed to paper, reviewed periodically, and updated as necessary. “Companies need to remember that their processes and procedures are not carved in stone and need to be changed to stay compliant with the operations being performed and the current interpretation of regulations,” says Schniepp. New technologies and new product types may necessitate an update to procedures.

 

Companies should be careful to not try and fit technology or product advances into current procedures but should instead take the time to review their processes and procedures and update them appropriately in responses to these advancements, she says.

 

FDA Process Validation

 

Consistent review of GMP procedures is important, especially if a change in equipment, facility, or regulatory requirements has occurred, experts note. “Written procedures should be reviewed and updated as often as needed. However, if a process and procedure is being updated frequently then it probably wasn’t very well written in the first place,” says Schniepp.

 

“This being said, procedures that are fairly stable should be validated at least every two years to make sure they are still current and reflective of FDA regulatory expectations.” When developing written procedures, says Lynch, “each process and procedure should be tailored to its specific purpose, so they don’t include unnecessary steps that add time to the process without applicable value to the procedure at hand.”

 

SOP Documents

 

Companies often lack the documentation that will help operators understand the entire GMP process, says Lynch. “The most important concept to remember when writing procedures is to include the detailed instructions for the operation or processes being defined by that procedure and not include extra explanatory or extraneous information that has no bearing on the operation or process being defined,” agrees Schniepp.

 

cGMP Consulting

 

In warning letters, FDA commonly suggests the hiring of a third-party GMP consultant to help companies address their GMP deficiencies. Schniepp says these consultants can provide a “fresh perspective” when resolving GMP issues. “A new and fresh approach is valuable because the consulting firm has no preconceived ideas and can offer new insight to what may seem to be an old and uncorrectable problem,” says Schniepp.

 

These consultants can be helpful even when not suggested by regulators “because they are looking at the quality with eyes not steeped in the corporate culture,” according to Moreton. Consultants also have knowledge and GMP expertise the company does not have.

 

“[Consultants] can offer a variety of approaches and suggestions for remediating current problems as well as offering solutions to maintain and improving systems moving forward. One of the most important aspects to consider when hiring a consulting firm is to make sure they not only have the expertise, but they also have the time to devote to fixing the problem,” says Schniepp.

 

Manufacturing & Industrial Consultant

 

When hiring a GMP consultant, Moreton suggests companies look at the experience of the contractor as a whole as well as the qualifications of the individual consultants “to ensure there is a good fit with the contractee’s needs.”

 

Lynch warns, however, that pharmaceutical companies should not rely too much on outside help. “Consultants can help companies get back on track if companies lack the resources internally. However, eventually companies have to sustain compliance themselves. Third-parties should provide expertise in the needed area and technology and have demonstrated success.

 

Then, they should be able to teach and mentor personnel for improved behaviors and provide flexible models to fit company operations and culture. Usually, this is more than one-time training, but a program of measurement and support over time.”

 

Article Details

 

gmp pharmaceutical

 

Pharmaceutical Technology
Vol. 42, No. 7
Pages:18–23, 60

 

About RCA’s Pharmaceutical Consulting Services 

 

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gmp pharmaceuticalRegulatory Compliance Associates® (RCA) provides pharmaceutical consulting to the following industries for resolution of life science challenges:

 

 

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