Quality Agreements and Out-of-Specification Investigations

A. The best place to start is to take a critical look at existing guidance documents and regulations that govern quality agreement and out-of-specification (OOS) investigations.

“The Food and Drug Administration is aware that many manufacturers of pharmaceutical products utilize extramural independent contract facilities, such as testing laboratories, contract packers or labelers, and custom grinders, and regards extramural facilities as an extension of the manufacturer’s own facility”. 

“Designation of responsibility for investigating deviations, discrepancies, failures, out-of-specification results, and out-of-trend results in the laboratory, and for sharing reports of such investigations”.

“The Contract should describe clearly who undertakes each step of the outsourced activity, e.g. knowledge management, technology transfer, supply chain, subcontracting, quality and purchasing of materials, testing and releasing materials, undertaking production and quality controls (including in-process controls, sampling and analysis)”.

The above regulations establish the need for quality agreements that cover laboratory activities but doesn’t define what needs to be in an OOS procedure. The EU addresses the need to investigate OOSs in their good manufacturing practices. EudraLex Part 1, Section 6.35 states,

“Out-of-specification or significant atypical trends should be investigated. Any confirmed out of specification result, or significant negative trend, affecting product batches released on the market should be reported to the relevant competent authorities. The possible impact on batches on the market should be considered in accordance with Chapter 8 of the GMP Guide and in consultation with the relevant competent authorities”.

Part 2 of the EU GMP guide for APIs states in section 11.15 that:

“Any out-of-specification result obtained should be investigated and documented according to a procedure. This procedure should require analysis of the data, assessment of whether a significant problem exists, allocation of the tasks for corrective actions, and conclusions. Any re-sampling and/or retesting after OOS results should be performed according to a documented procedure”.

GMP Regulations

Often, the procedure will contain a GMP regulations checklist that assists in identifying obvious laboratory errors. The checklist assesses the suitability of analyst qualification and training, use of correct procedure and specification, the calibration and performance of the equipment, correct preparation of test solutions and dilutions, use of proper reagents and standards, calculations, etc.

A thorough checklist and analyst documentation are critical in identifying true laboratory errors. The SOP should also discuss the sample retesting requirements when a true laboratory error is determined to be the cause of the OOS.

GMP Guidelines

The most important and critical element for OOS investigations is specifying the timeliness. These guidelines should be stipulated in the SOP and, in most cases, the investigation into the OOS, from the laboratory perspective, should be concluded in 24 hours or less.

The expectation of when the contract lab will inform you of any OOS obtained should be clearly defined in your quality agreement. The sooner a laboratory error can be ruled out as the cause of the OOS result, the sooner the full-blown manufacturing investigation can be started.

Taking the time to establish a quality agreement and investigate the details of their OOS procedure is the first step in establishing a good working relationship with your contract test laboratory. This working relationship will become invaluable when an OOS occurs.

The final product testing procedure for OOSs isn’t the only one you need to review, however. You should also look at the quality agreement and OOS procedure being used by your manufacturer for in-process test results, assuming they are different entities. The same information required in the final product OOS procedure should be the same for in-process testing.

Article Details

Pharmaceutical Technology
Vol. 43, No. 6
Pages 50, 49