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GOOD MANUFACTURING PRACTICE [GMP]
Manufacture of Investigational
Medicinal Products (IMPs)
Tajuddin Akasah
B.Pharm.Hons.(USM)., M.Phil., Ph.D. (UK)
Head of Centre for GMP
National Pharmaceutical Control Bureau
WHO Collaborating Centre
For Regulatory Control of
Pharmaceuticals
Member of Pharmaceutical
Inspection Cooperation Scheme
MS ISO 9001:2000 Certified
National Pharmaceutical Control Bureau
Ministry of Health Malaysia
2
SCOPE TO COVERSCOPE TO COVER
Quality
Background
GMP and QA
Elements of GMP
3
QUALITY?
4
How and Why? some assumptions
I like the brand!
I trust the brand!
I like the box!
My mother uses it!
My friend uses it!
My doctor says so!
The pharmacist sells it!
5
THALIDOMIDE AND HEAVY
METAL POISONING
6
Regulator’s concern ….
Quality, Safety and EfficacyQuality, Safety and Efficacy
[pharmaceuticals]
Quality and SafetyQuality and Safety
[health supplements and traditionals]
2
7
How do we ensure ?
Quality (meet specs, intended
use) and
Safety (Heavy metals and
microbial limits, no prohibited
ingredients, ADR monitored)
Efficacy (proven clinically)
8
DO YOU KNOW THAT THE MEDICINE
USED IS NOT ‘TESTED’?
9
?
10
Quality
QC test is destructive
Unable to do on every tablet
Require sampling
Compliance to GMP is crucial
Quality being ‘built-in’ from the start to
finish
11
WHAT IS GMP?
Good Manufacturing Practice
GMP is that part of QA which ensures that
products are consistently produced and
controlled to the quality standards appropriate
to their intended use and as required by the
marketing authorisation or product
specifications
12
WHAT IS QA?
Quality Assurance
It is the sum total of the organised
arrangements made with the objective of
ensuring that medicinal product are
of quality required for their intended
use. QA therefore incorporates GMP plus
Quality Control (QC).
3
13
GMP IMPLEMENTATION IN MALAYSIA
GMP for pharmaceuticals in
Malaysia since 1984
WHO and ASEAN
Guidelines
MALAYSIAN Guidelines
PIC/S since 1st Jan 2002,
Malaysia became the 26th
member state
14
Background
A short history of GMP
First introduced by the
Canadian Authorities – mid
1960s
Since then GMP acceptance
– as a ‘way of life’ in the
pharmaceutical industry
15
Background
It might be assumed that
40 years of experience of GMP
84 countries
Would have eliminated many dangers to
the patients due to quality failure in
manufacturing but….
16
MistakesMistakes
109 infants have died in Nigeria
due to failure to follow GMP
Supplier mislabelled ethylene
glycol (anti freeze) as propylene
glycol and the manufacturer
failed to perform adequate
QC – identification and potency
test
17
OTHER EXAMPLES
Slimming pills in Singapore 2002
Slimming pills in Malaysia 2004
Tablet with hairs in Brunei 2004
Adulterated Trad Med in Yemen 2004
Nepal 2004
Wrong labelling in Malaysia 2005
18
GMP COMPLIANCE IS CRUCIAL
WHAT ARE THE ELEMENTS OF GMP?
4
19
Ch. 1. Quality Management System
Ch. 2. Personnel
Ch. 3. Premises and Equipment
Ch. 4. Documentation
Ch. 5. Production
Ch. 6. Quality Control
Ch. 7. Contract Manufacture and Analysis
Ch. 8. Complaint and Product Recall
Ch. 9. Self Inspection
Annexes 1-18 (specific)
20
QUALITY MANAGEMENT SYSTEM
Developed, established, implemented
Policies and objectives
Organisational structure, functions
Responsibilities, procedures
QC and specifications
21
PERSONNEL
~ separate people responsible
for production and quality
control (independent of
each other)
~ appropriately trained in
quality system, GMP and
regulatory requirements
22
PREMISES* & EQUIPMENT*
Suitably located, designed,
constructed and maintained
The need to
avoid any risks of
contamination from
environment
cross-contamination
product mix-up
23
Premises & Equipment…
Campaign working is
acceptable but…
Separate or dedicated
facilities for
Penicillin, steroids,
hormones etc.
24
Hormone Production
5
25
DOCUMENTATION
Complete history of each
batch from starting
material to finished
products,traceability
BMR, SOPs, Formulas
26
WHEN
ATTEMPTING A
TASK WE NEED
SOME SORT OF
DOCUMENTATION
27
If the documentation is wrong!
28
PRODUCTION – Starting materials
Consistency of
production is
influenced by quality
of starting materials
Specifications
29
Manufacturing Operations
Standard Operating Procedures (SOPs)
Cleaning Procedures and Validations
30
Principles applicable to Comparator Product
If significant changes were made
to the quality of the
comparator product (dosage
form, packaging materials,
Storage, etc.)
Stability, comparative
dissolution, bioavailability
data should be made available
to prove the original quality
characteristics
6
31
Expiry Date
The expiry date on the original package
may NOT be applicable when repacked
The sponsor is responsible to determine a
suitable use-by date (product nature,
characteristics of container, storage
conditions)
32
Randomisation Code
Procedures should describe the
generation, distribution, handling &
retention of randomisation code
used for packaging investigational
products
33
Blinding Operations
A system should be implemented to allow
for a proper identification of the blinded
product
System + randomisation code - must allow
proper identification & traceability
Sample of blinded IMPs should be retained
34
Milo + Nescafe
Ikan kering + Telor Goreng
1/1000th
35
ValidationValidation
The documented act of
proving that any
procedure, process,
equipment, material,
activity, or system
actually leads to the
expected results.
36
Qualify a system and/or equipment
ValidateValidate a process
Qualify an autoclave, whereas you
validate a sterilisation processvalidate a sterilisation process
Qualification or ValidationValidation ?
7
37
Production
actual & theoretical yield
abnormal discrepancy
should be investigated
38
Packaging & Labelling
Line clearance
Label reconciliation
Independent
checking by QC staff
39
Thai labels
40
QUALITY CONTROL
Concerned with
sampling, specifications,
testing, documentation,
release procedures.
41
Quality Control…
Accuracy of therapeutic dose (content
uniformity)
Release of active substance (solubility,
dissolution)
Estimation of stability (accelerated &
stress conditions, shelf life, storage
conditions)
42
CONTRACT MANUFACTURE &
CONTRACT ANALYSIS
Must be correctly defined
agreed and controlled in
order to avoid
misunderstandings
Must clearly defines the
duties of the giver and
receiver
8
43
COMPLAINTS AND
PRODUCT RECALL
Complaints must be
reviewed according to
SOPs
For all contigencies there
should be aproduct recall
procedures
44
SELF INSPECTION
Conducted in order to monitor the
implementation and compliance
with GMP principles
To propose necessary corrective
measures
45
GMP FLOW CONCEPTGMP FLOW CONCEPT
Black Grey White
46
Contaminations
Microbiological
Pyrogen
Particulate
Sources
Personnel
Environment/surface
Equipment
47 48
And finally…
GMP
9
49
GMP – GOOD MANUFACTURING
PRACTICE and not
Good Massage Practice
50
IS IT TOUGH?
51
Some useful websites
http://www.bpfk.gov.my
http://www.picscheme.org
http://www.tga.health.gov.au
http://www.who.org
http://www.fda.gov
52
QUESTIONS & ANSWERS
53
HOW DO WE MONITOR MANUFACTURERS?
WE AUDIT
[ROUTINE, VERIFICATION,
INVESTIGATIVE & ETC.]!
54
Grading of GMP Compliance and
Frequency of Audits
12 MTHS6 MTHS6 MTHSPOOR
18 MTHS12 MTHS12 MTHSS’FACTORY
24 MTHS24 MTHS18 MTHS
STATUS
GOOD
LOWMEDIUMHIGHRISK
10
55
AUDIT FINDINGS
EXAMPLESWHY?WHAT?
BAJU KOYAK,
TEMPERATURE
RECORD NOT SIGNED
COMMENTS FOR
IMPROVEMENT
MINOR
PROCEDURE NOT
COMPLETE, NO
TRAINING, BAJU
KOYAK
QUALITY DEFECTS
NOT EFFECTING
HUMAN LIFE
MAJOR
WATER SYSTEM,
HVACS, X- CONT’N,
BAJU KOYAK
EFFECT HUMAN
LIFE
CRITICAL

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F gmp imp kl dr tajuddin

  • 1. 1 1 GOOD MANUFACTURING PRACTICE [GMP] Manufacture of Investigational Medicinal Products (IMPs) Tajuddin Akasah B.Pharm.Hons.(USM)., M.Phil., Ph.D. (UK) Head of Centre for GMP National Pharmaceutical Control Bureau WHO Collaborating Centre For Regulatory Control of Pharmaceuticals Member of Pharmaceutical Inspection Cooperation Scheme MS ISO 9001:2000 Certified National Pharmaceutical Control Bureau Ministry of Health Malaysia 2 SCOPE TO COVERSCOPE TO COVER Quality Background GMP and QA Elements of GMP 3 QUALITY? 4 How and Why? some assumptions I like the brand! I trust the brand! I like the box! My mother uses it! My friend uses it! My doctor says so! The pharmacist sells it! 5 THALIDOMIDE AND HEAVY METAL POISONING 6 Regulator’s concern …. Quality, Safety and EfficacyQuality, Safety and Efficacy [pharmaceuticals] Quality and SafetyQuality and Safety [health supplements and traditionals]
  • 2. 2 7 How do we ensure ? Quality (meet specs, intended use) and Safety (Heavy metals and microbial limits, no prohibited ingredients, ADR monitored) Efficacy (proven clinically) 8 DO YOU KNOW THAT THE MEDICINE USED IS NOT ‘TESTED’? 9 ? 10 Quality QC test is destructive Unable to do on every tablet Require sampling Compliance to GMP is crucial Quality being ‘built-in’ from the start to finish 11 WHAT IS GMP? Good Manufacturing Practice GMP is that part of QA which ensures that products are consistently produced and controlled to the quality standards appropriate to their intended use and as required by the marketing authorisation or product specifications 12 WHAT IS QA? Quality Assurance It is the sum total of the organised arrangements made with the objective of ensuring that medicinal product are of quality required for their intended use. QA therefore incorporates GMP plus Quality Control (QC).
  • 3. 3 13 GMP IMPLEMENTATION IN MALAYSIA GMP for pharmaceuticals in Malaysia since 1984 WHO and ASEAN Guidelines MALAYSIAN Guidelines PIC/S since 1st Jan 2002, Malaysia became the 26th member state 14 Background A short history of GMP First introduced by the Canadian Authorities – mid 1960s Since then GMP acceptance – as a ‘way of life’ in the pharmaceutical industry 15 Background It might be assumed that 40 years of experience of GMP 84 countries Would have eliminated many dangers to the patients due to quality failure in manufacturing but…. 16 MistakesMistakes 109 infants have died in Nigeria due to failure to follow GMP Supplier mislabelled ethylene glycol (anti freeze) as propylene glycol and the manufacturer failed to perform adequate QC – identification and potency test 17 OTHER EXAMPLES Slimming pills in Singapore 2002 Slimming pills in Malaysia 2004 Tablet with hairs in Brunei 2004 Adulterated Trad Med in Yemen 2004 Nepal 2004 Wrong labelling in Malaysia 2005 18 GMP COMPLIANCE IS CRUCIAL WHAT ARE THE ELEMENTS OF GMP?
  • 4. 4 19 Ch. 1. Quality Management System Ch. 2. Personnel Ch. 3. Premises and Equipment Ch. 4. Documentation Ch. 5. Production Ch. 6. Quality Control Ch. 7. Contract Manufacture and Analysis Ch. 8. Complaint and Product Recall Ch. 9. Self Inspection Annexes 1-18 (specific) 20 QUALITY MANAGEMENT SYSTEM Developed, established, implemented Policies and objectives Organisational structure, functions Responsibilities, procedures QC and specifications 21 PERSONNEL ~ separate people responsible for production and quality control (independent of each other) ~ appropriately trained in quality system, GMP and regulatory requirements 22 PREMISES* & EQUIPMENT* Suitably located, designed, constructed and maintained The need to avoid any risks of contamination from environment cross-contamination product mix-up 23 Premises & Equipment… Campaign working is acceptable but… Separate or dedicated facilities for Penicillin, steroids, hormones etc. 24 Hormone Production
  • 5. 5 25 DOCUMENTATION Complete history of each batch from starting material to finished products,traceability BMR, SOPs, Formulas 26 WHEN ATTEMPTING A TASK WE NEED SOME SORT OF DOCUMENTATION 27 If the documentation is wrong! 28 PRODUCTION – Starting materials Consistency of production is influenced by quality of starting materials Specifications 29 Manufacturing Operations Standard Operating Procedures (SOPs) Cleaning Procedures and Validations 30 Principles applicable to Comparator Product If significant changes were made to the quality of the comparator product (dosage form, packaging materials, Storage, etc.) Stability, comparative dissolution, bioavailability data should be made available to prove the original quality characteristics
  • 6. 6 31 Expiry Date The expiry date on the original package may NOT be applicable when repacked The sponsor is responsible to determine a suitable use-by date (product nature, characteristics of container, storage conditions) 32 Randomisation Code Procedures should describe the generation, distribution, handling & retention of randomisation code used for packaging investigational products 33 Blinding Operations A system should be implemented to allow for a proper identification of the blinded product System + randomisation code - must allow proper identification & traceability Sample of blinded IMPs should be retained 34 Milo + Nescafe Ikan kering + Telor Goreng 1/1000th 35 ValidationValidation The documented act of proving that any procedure, process, equipment, material, activity, or system actually leads to the expected results. 36 Qualify a system and/or equipment ValidateValidate a process Qualify an autoclave, whereas you validate a sterilisation processvalidate a sterilisation process Qualification or ValidationValidation ?
  • 7. 7 37 Production actual & theoretical yield abnormal discrepancy should be investigated 38 Packaging & Labelling Line clearance Label reconciliation Independent checking by QC staff 39 Thai labels 40 QUALITY CONTROL Concerned with sampling, specifications, testing, documentation, release procedures. 41 Quality Control… Accuracy of therapeutic dose (content uniformity) Release of active substance (solubility, dissolution) Estimation of stability (accelerated & stress conditions, shelf life, storage conditions) 42 CONTRACT MANUFACTURE & CONTRACT ANALYSIS Must be correctly defined agreed and controlled in order to avoid misunderstandings Must clearly defines the duties of the giver and receiver
  • 8. 8 43 COMPLAINTS AND PRODUCT RECALL Complaints must be reviewed according to SOPs For all contigencies there should be aproduct recall procedures 44 SELF INSPECTION Conducted in order to monitor the implementation and compliance with GMP principles To propose necessary corrective measures 45 GMP FLOW CONCEPTGMP FLOW CONCEPT Black Grey White 46 Contaminations Microbiological Pyrogen Particulate Sources Personnel Environment/surface Equipment 47 48 And finally… GMP
  • 9. 9 49 GMP – GOOD MANUFACTURING PRACTICE and not Good Massage Practice 50 IS IT TOUGH? 51 Some useful websites http://www.bpfk.gov.my http://www.picscheme.org http://www.tga.health.gov.au http://www.who.org http://www.fda.gov 52 QUESTIONS & ANSWERS 53 HOW DO WE MONITOR MANUFACTURERS? WE AUDIT [ROUTINE, VERIFICATION, INVESTIGATIVE & ETC.]! 54 Grading of GMP Compliance and Frequency of Audits 12 MTHS6 MTHS6 MTHSPOOR 18 MTHS12 MTHS12 MTHSS’FACTORY 24 MTHS24 MTHS18 MTHS STATUS GOOD LOWMEDIUMHIGHRISK
  • 10. 10 55 AUDIT FINDINGS EXAMPLESWHY?WHAT? BAJU KOYAK, TEMPERATURE RECORD NOT SIGNED COMMENTS FOR IMPROVEMENT MINOR PROCEDURE NOT COMPLETE, NO TRAINING, BAJU KOYAK QUALITY DEFECTS NOT EFFECTING HUMAN LIFE MAJOR WATER SYSTEM, HVACS, X- CONT’N, BAJU KOYAK EFFECT HUMAN LIFE CRITICAL