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• Introduction
• Scope
• Responsibilities
• The Requirements
 General Considerations
 Prevention of Cross-Contamination
 Batch Manufacturing Records
 And the others (13 items)
• Manufacture of active pharmaceutical ingredients
(APIs) and intermediates as finished product, must
follow well-defined operating principles

System and Principles must be well-defined

• Manufacture must comply with current Good

Manufacturing Practices (GMPs) and with the
corresponding registration dossiers

GMP Compliance & Regulatory Compliance

2. Scope

This presentation applies to all

manufacturing sites and subcontractors,
who manufacture active pharmaceutical
ingredients and intermediates

Based on ICH Q7 (EU GMP part II)

3. Responsibilities

• Site Management is responsible for ensuring that

adequate resources are in place to comply with the
regulatory requirements
Adequate Resources to be provided

• Site Quality Management is responsible for ensuring that

there are systems and procedures in place for the
manufacturing of APIs and Intermediates
Systems and Procedures must be in place.
4. Requirements (1)
 General Considerations
 Prevention of Cross-Contamination
 Computerised Systems
 Documentation
 Batch Manufacturing Records
 Review of Batch Manufacturing Records
 Manufacturing Process
 In-process Sampling and Testing
 Change Control
4. Requirements (2)
• Analytical, Biological and Microbiological
• Tests
• Water
• Recycling of Recovered Materials and
• Solvents
• Reprocessing
• Reworking
• Wastewater and Materials
• Storage
4. 1. General Considerations (1)

• Manufacturing operations must be performed

and supervised by trained and qualified

• Personnel must wear garments and protective

clothing suited to the operation performed and
taking into Account any specific Health, Safety
and Environment (HSE) requirements.
4. 1. General Considerations (2)
• Product handling operations such as receipt,
quarantining, sampling, storage, labelling,
packaging and transfer must be conducted in
a way to prevent any risk of cross-
contamination and must be described in
appropriate procedures

Specific requirements for Highly Active

Substances. Dedicated and self-contained
facilities must be used for these materials,
e.g. beta-lactams, hormones, cytotoxics.
4. 1. General Considerations (3)

• All equipment, products, and containers must be

clearly labelled and identified. Labels must be
designed to be securely affixed, legible, and
must not fade or deteriorate with time

• Connections between piping (lines, flexible

tubing, etc) and other manufacturing equipment
used to transfer products must be controlled.
4. 1. General Considerations (4)
• Only authorised personnel must be allowed to enter in the
manufacturing areas. Site personnel must accompany visitors within
manufacturing areas

• All company personnel and visitors to the site must be under

controlled access and exit at all times

• Visitors access and exit must be authorised and documented

• Visitors must be accompanied by site personnel at all times unless

training in GMPs specific to the area is provided and documented.
4. 1. General Considerations (5)

• Equipment used to manufacture intermediates and APIs

must be qualified and uniquely identified and be part of
a preventive maintenance program

• Equipment, instrumentation, computerised and/or

control systems, facilities and utilities used in
conjunction with the above must be qualified, and
systems (e.g. water systems and computerised systems)
and processes must be validated and maintained in a
documented state of control
4. 1. General Considerations (6)
• Critical measuring equipment must be in calibration and be
part of a calibration program

• All equipment and instruments that could have an impact on

product quality, safety or efficacy must be tracked and
maintained under a calibration and maintenance program

• All calibrations and maintenance must be documented and the

records of those activities must be archived

• Calibration is essential to maintain product quality, personnel

and environmental safety during operation. It is an important
step for qualification.
4. 1. General Considerations (7)
• Starting materials, raw materials and packaging materials
used to manufacture intermediates and APIs must meet
predetermined specifications as defined in the registration
dossiers and be released by the Quality Unit according to site

• All specifications developed for APIs and intermediates must

contain at a minimum the following attributes: Appearance
and/or Description, Identity, Assay, Impurities

• Quality Unit must establish a system to release or reject raw

materials, intermediates, packaging and labelling materials
(ICH Q7A, under 2.2)
4. 2. Prevention of Cross-
Contamination (1)
• Measures must be taken during manufacture to
prevent/minimise any contamination risk specifically when
manufacturing areas are not dedicated to a single product

• Air filtration equipment and environmental zones of the finishing

rooms must be subject to the requirements of the Directive
“Environmental Zoning & Air Handling Systems”

• Prevention of contamination. Cleaning of non-dedicated

equipment used for the final steps must be validated

• Environmental Zoning & Air Handling System requirements for

the final steps: drying, milling, filling.
4. 2. Prevention of Cross-
Contamination (2)
• Different batches of product or product in different
phases must not be loaded or unloaded
simultaneously in the same area/room

• Rooms in which packaging and labelling operations

are performed must be inspected immediately before
use in order to ensure that all non-relevant packaging
components have been removed. This operation must
be reported in the batch record. (ICH Q7A, 9.44)

• If operations on different products are carried out

simultaneously or consecutively in the same room, the
operations must be segregated and controlled.
4. 3. Computerised Systems
• Any computerised system which may have an impact of
product quality or which deals with any GMP related data
must be validated

• Good Practices for Computerised Systems

• Computerised Systems Validation

• The scope and extend of the validation activities must be

commensurate with the GxP risk and complexity of the

• Validation must be based on a documented User

Requirement Specification.
4. 4. Documentation
• All documents related to the manufacture
of intermediates and APIs (e.g. process
description, batch manufacturing records),
must be prepared, checked, approved and
issued following written procedures.

ICH Q7, Chapter 6: Documentation and Records

4. 5. Batch Manufacturing Records
• For each batch of intermediate or API, batch
manufacturing record(s) with its associated batch
number must be compiled, checked for
appropriateness with the Master Batch
Manufacturing record, and signed before use

• Batch Manufacturing Records must include but not

limited to:
 Dates and when appropriate, times
 Reference to each major equipment used (e.g. reactor,
drier, mills, etc.)
 Description of packaging and labelling materials used
4. 5. Batch Manufacturing Records
• Batch number of the manufactured product, raw materials,
starting materials, intermediates, any reprocessed, or re-
worked material, and packaging materials
• Any physical and chemical parameters
• Critical process data
• Analytical data on the finished product, if available
• Sampling operations
• Signature or initials of each operator who has performed a
critical step and of each operator who has checked it
• In-process control test results
4. 5. Batch Manufacturing Records

 Representative(s) label(s) used to identify the finished product batch

 Yields obtained at defined stages
 Any deviation reported during manufacture with all relevant

Individual manufacturing steps must be signed

(or initialled) and dated.

• A similar list is provided in ICH Q7, under 6.52

• A list for Master Batch Records: under 6.41
4. 6. Review of Batch
Manufacturing Records
• Batch manufacturing records must be reviewed
and approved by Manufacturing and Quality
departments according to site procedures

• Any deviation, investigation, comment and any

report of an Out-of-Specification (OOS) result
must be an integral part of the batch record and
must be reviewed before a decision is taken on
the release/reject of the batch.

• ICH Q7, Chapter 6.7

4. 7. Manufacturing Process (1)
• Critical steps and methods must be defined for each
manufacturing process through a scientific rationale

• Critical manufacturing steps and critical cleaning methods

must be validated according to site procedures

• What is the definition of “critical”?

“Critical” in this context describes a process step, process

condition, test requirement or other relevant parameter or
item that must be controlled within pre-determined criteria to
ensure that the API meets its specification. (ICH Q7)
4. 7. Manufacturing Process (2)
• Critical process parameters must be identified,
monitored and/or recorded/reported. They must be
checked and signed (initialled) by a second person

• Any deviation to critical processing and process

parameters or any discrepancy in the yield range for
critical steps must be documented and investigated in
order to assess its potential impact on product quality.

• Control all steps and parameters!

• Validate the critical ones!
4. 8. In-process Sampling and
• Sampling during manufacture and in-process control tests with
defined limits when applicable, must be described in

• Blending batches of finished products intermediate or API is allowed

providing this is a condition of the registration dossiers and complies
with specifications. Under this condition expiry or retest date should
be based on the date of the oldest batch

 Blending Batches in ICH Q7, Chapter 8.4

 “Out-of-Specification batches should not be blended with other batches

for the purpose of meeting specifications.”
4. 9. Change Control
• Any change associated with the manufacture of
active pharmaceutical ingredients or
intermediates must be in compliance with the
site change control procedure

ICH Q7, Chapter 13

4. 10. Analytical, Biological &
Microbiological Testing
• Laboratory tests must be conducted on
each batch of active pharmaceutical
ingredient and where applicable on each
batch of intermediate as described in the
registration dossiers in order to confirm
compliance with the approved

ICH Q7, Chapter 11 (Laboratory Controls)

4. 11. Water
• *Water used in the manufacturing process
must be suitable for its intended use and
meet pre-defined specifications

ICH Q7, Chapter 4.3 (Water)

*We have a separate guidance document which goes into detail on Water: Type, Production, Distribution,
Use & Storage and Operations and Control of Water Systems.
4. 12. Recovery of Materials &
• Recovered materials and solvents must be recycled
and tested to pre-defined specifications according to
site procedures and in compliance with registration

• Where appropriate, the number of re-cycles allowed

must be defined and the recovery process should be

ICH Q7, Chapter 14 (Rejection and Re-use of

4. 13. Reprocessing; 4.14
• For further information refer to the
guidance document entitled
“Reprocessing, Reworking and Re-

• ICH Q7, Chapter 14 (Rejection and Re-use

of Materials)
4. 15. Wastewater and
• Wastewater and materials (solids, fluids or
secondary products derived from manufacture)
must be discarded in a way that satisfies Health,
Safety and Environmental (HSE) requirements.

• ICH Q7, Chapter 4.6 (Sewage and Refuse):

“Sewage, refuse, and other waste… should be
disposed of in a safe, timely, and sanitary
manner. Containers and/or pipes for waste
material should be clearly identified”
4. 16. Storage

• Finished products must be handled and stored in

controlled/monitored areas under conditions to
prevent degradation and/or contamination.

• Refer to our guidance document on Warehousing and

Good Distribution Practices

• ICH Q7, Chapter 7.4 (Storage)

• Guide to Good Storage Practices for Pharmaceuticals

Annex 9, WHO Technical Report Series 908, 2003
• It is important that you have all operations
involved in the preparation of an API under
appropriate control, by:

 Having defined the critical process steps

 Having established a robust process (PAT, QbD)
 Having performed a process validation with
continuing verification
 Using an effective Change Control System
 Investigating discrepancies, deviations; and
 Learning from problems, errors and mistakes.
Thank You

Any Questions