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Role of QC/Production/QA in Relation To Batch Release: Beijing University 20-22 September 2006
Role of QC/Production/QA in Relation To Batch Release: Beijing University 20-22 September 2006
Role of QC/Production/QA in Relation To Batch Release: Beijing University 20-22 September 2006
Lionel Viornery Inspector, head of the starting materials for pharmaceutical use inspection unit
Introduction
From the finished product point of view From the API point of view
Introduction
legislation applicable to finished products Article 51 of directive 2001/83/EC and article 11 of directive 2003/94/EC
They are fit for their intended use They comply with the requirements of the MA They do not place the patients at risk due to inadequate safety, quality or efficacy
Introduction
Introduction
to ensure that the batch has been manufactured and checked in accordance with the requirements of the MA, the principles and guidelines of EU GMP and any other legal requirement before it is placed on the market In the event that a defect needs to be investigated or a batch recalled, to ensure that the QP who certified the batch and the relevant records are readily identifiable
Introduction
Introduction
Manufacture : All operations of receipt of materials, production, (re)packaging, (re)labelling, quality control, release, storage and distribution of APIs and related controls Release : ?
Introduction
Release
Reaction
Crude API
Crystallisation
Release ?
Pure API (wet) Drying Isolation
Packaging/ labelling
Drug Manufacturers
Release
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Introduction
Materials meet established specifications (case of raw materials and Intermediates) APIs meet the requirements for quality and purity that they purport or are represented to possess APIs meet the commitments made in registered files (MA, CEP, ASMF)
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Release in relation to
Raw materials (sections 7.20 and 7.21) Packaging and labelling materials Intermediates (section 2.22-1) API (section 2.22-1)
(section 9.10)
Principles : What
Section 2.17 : No materials should be released
or used before the satisfactory completion of evaluation by the quality unit(s) unless there are appropriate systems in place to allow for such use (e.g. release under quarantine as described in section 10.20 or the use of raw materials or intermediates pending completion of evaluation)
QA unit is responsible for the release of all materials Use or distribution of raw materials and intermediates under quarantine is possible under conditions
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Principles : What
Section 10.20 : APIs and intermediates should
only be released for distribution to third parties after they have been released by the Quality Unit(s). APIs and intermediates can be transferred under quarantine to another unit under the companys control when authorised by the Quality Unit(s) and if appropriate controls and documentation are in place
QA unit is fully responsible for the release of APIs and Intermediates to third parties Distribution or use under quarantine is possible in the case of a unit of the same company for example
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Principles : How
Section 6.70 : Written procedures should be
established and followed for the review and approval of batch production and laboratory controls records, including packaging and labelling, to determine compliance of the intermediate or API with established specifications before a batch is released or distributed
The release process should be described in a procedure detailing the different steps to be followed, documentation to be reviewed (including deviations), who will release
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Principles : Who
Section 2.14 : The persons authorised to release
intermediates and APIs should be specified
The responsibility for releasing APIs, materials, intermediates specified in writing for all the persons in charge (including deputies); Responsibility usually included in individual job descriptions
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Release Raw materials Non isolated intermediates for internal use Isolated intermediates for internal use Intermediates for distribution APIs for distribution
QC Yes No Yes No No
QA No No No Yes Yes
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Releasing or rejecting all APIs and Intermediates for use outside the control of the manufacturing company; Establishing a system to release or reject raw materials, intermediates, packaging and labelling materials
QA unit is fully responsible for API and intermediates release QA unit can delegate the release of all the other materials to other departments (QC and/or production) except intermediates for third parties
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release process Sections 2.22-3 et 6.71 : QA unit(s) should review and approve batch production and laboratory control records of critical process steps
approve procedures in case of delegation to other unit(s) of the review of the production and laboratory control records of non-critical process steps
Critical meaning something that must be controlled within predetermined criteria to ensure that the API meets its specification
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release process Section 6.72 : All deviation, investigation, and OOS reports should be reviewed as part of the batch record review before the batch is released
Quality Unit(s) should date and signe Certificates of analysis been reworked, appropriate evaluation demonstrating the equivalence in quality of the reworked batch should be performed
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testing have been validated (unless if included in the relevant Pharmacopoeia) properly monitored
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the authorised persons of the QA should ensure that : (continued) All production and QC documentation has been completed, reviewed and signed
investigated and the impact on the quality of the API assessed can impact the quality of the API have been notified and authorised by the dosage form manufacturer
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that raw materials, intermediates, packaging and labelling materials, and APIs are compliant with established specifications and standards records including data derived from all tests carried out and conclusions recorded
CONCLUSION
factual evidence (BPR, results from testing) and should be backed by a living Quality System an increase in the requirements for the release of RM versus APIs unit to the user, the drug manufacturer