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Tuesday, May 2, 2017

PIC/S reaffirms its stance on proposed EU ATMP GMP Guidelines and highlights gaps relating to patient safety


PIC/S sent a letter in response to a reply received from the European Commission on 5 April 2017 in connection with PIC/S' stance on the proposed EU Advanced Therapy Medicinal Products (ATMP) GMP Guidelines, which will not only lower GMP standards for ATMP at the risk of patients but also lead to an internationally non-harmonised approach to the implementation of GMP for ATMP.
In its latest letter, PIC/S reaffirms its position and highlights gaps relating to patient safety, while welcoming the Commission's proposal for engagement with PIC/S on its initiative and seeking clarification on the scope of cooperation proposed.
For reasons of transparency and rights of patients, this letter has been published via the link below:

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GMP News, GMP guidelines, GMP Violations, GMP warnings, GMP Trends. A Public Health Global News Portal. (This story has not been edited by GMP Violations staff and is auto-generated from a syndicated feed/ experts experiences sharing.) Disclaimer: The Logos/Images & content posted here are belongs to respective to Authority/owners of the firm. The Article posted under public health importance news. Please ensure the guideline as per Regulatory agencies.
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Monday, March 13, 2017

What are the APS PROCESS SIMULATION TEST CONDITIONS ?



















PROCESS SIMULATION TEST CONDITIONS

1.     Test Performance
1.1 The process simulation test should follow as closely as possible the routine aseptic manufacturing process and include all critical subsequent manufacturing steps. All equipment should remain the same wherever practicable as for the routine process. Appropriate combinations of container size and opening as well as speed of the processing line should be used (preferably at the extremes).
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Sunday, March 12, 2017

What are the requirement s for PROCESS SIMULATION & TEST PROCEDURES ?


















PROCESS SIMULATION TEST PROCEDURES
General Comments:

The media fill should emulate the regular product fill situation in terms of equipment, processes, personnel involved and time taken for filling as well as for holding.

Where filling takes place over extended periods, i.e. longer than 24 hours, the process simulation test should extend over the whole of the standard filling period. In order to prevent excessively high numbers of units being filled it is usually acceptable to just run the machine for a reasonable time, if the validity of the simulation is not diminished by this procedure.
It should be considered that inert gases will prevent the growth of aerobic microorganisms. Therefore for process simulations sterile filtered air should be used instead of inert gases, also for breaking a vacuum. Where anaerobes are detected in the environmental monitoring or sterility testing, the use of an inert gas should be considered for a process simulation, as inert gas is supporting the growth of anaerobes.

Before enumerating the different process simulation test procedures some preliminary explanations are necessary for the preparation of liquid media as it is used for the majority of the process simulation tests. Where a liquid nutrient medium is used it should be prepared in a similar manner to the product. The medium should be dissolved in Water for Injection in a standard manufacturing vessel. If heat is required to dissolve it then only minimal heat should be used. The pH of the medium should be measured and, if necessary, adjusted to bring it into the required range. The medium should be aseptically filtered into an aseptic holding vessel using the normal production filter and processing procedure. In justified cases it may be also acceptable to sterilise the media. All aseptic holding vessels should be covered by a process simulation test on a regular basis unless a validated, pressure hold or vacuum hold test is routinely performed.

The following chapter illustrates the test procedures for the various simulation tests for aseptically produced solutions, lyophiles, suspensions, ointments and powders and summarises the considerations to be made.

Liquid Products

Vial Products

The liquid growth medium for the simulation test is prepared as above and kept in a sterile holding vessel for the maximum permitted holding time before starting the simulation test. If the bulk solution is stored under refrigerated conditions during the holding time then this should also be performed for the medium. Vials and closures should be prepared as in regular production.

Sterile Products in Plastic Containers

Ear and eye drops are typically marketed in plastic containers. Containers, inserts, closures and where applicable over seals are washed and sterilized as in regular production. Instead of sterilization with heat, irradiation or ethylene oxide are used.

Whilst clear plastic containers are frequently used for process simulation trials, the plastic is usually slightly opaque and thus hinders identification of contaminated units that show only a slight haze. In such case examination under natural or room lighting would not suffice. Where opaque containers are used for process simulation trials the whole contents should be removed for examination.

Ampoule Products

Open or closed ampoule types may be used. They should be sterilized by dry heat and afterwards used in the simulation test as per the regular production run.

Ampoules should be prepared as in regular production.

Injectable Powder Products

There are two possibilities for simulation of this process. Either by filling a sterilised liquid growth medium into the sterile container or adding a powder (inert or growth medium) before or after a sterile diluent (WFI or growth medium). Inert materials commonly used include: polyethylene glycol 8000 and carboxymethyl cellulose. These materials are usually sterilised by irradiation.

Suspension Products

This procedure is comparable to the filling of liquid products, except for the process step of maintaining suspension of the ingredients. The stirring or recirculation should be part of the simulation. If aseptic additions are made to the bulk solution these should be simulated by the use of inert sterile liquids/powders.

Freeze Dried (Lyophilised) Products

Crystallisation of the medium should be prevented because it may reduce the likelihood of recovery of organisms.

Two simulation methods are commonly used. In the first one a dilute medium is subject to a cycle that removes water until a determined medium strength is obtained, but is not subject to freezing. The second method uses full strength medium and requires only a partial vacuum be drawn whilst the chamber should be kept at ambient temperature. There is a risk that the medium may boil over and contaminate the chamber unless conditions are tightly controlled. The absence of boiling under the defined cycle conditions should be confirmed.

Semi-Solid Products (e.g. sterile ointments)

For this simulation test the liquid growth medium is thickened to the appropriate viscosity, used as in the routine production procedure. Suitable thickening agents are agar and carboxymethyl cellulose. Other agents would need to be validated with regard to lack of their bacteriostatic and fungi static properties. Metal and plastic ointment tubes prevent the examination of the medium in-situ. Usually the whole content of the tube should be examined and this is usually achieved by squeezing the contents into a plate (petri dish), and after whirling it is examined for turbidity and fungal colonies under defined light conditions or by performing a sterility test. If properly validated, an alternative method for detection of contamination of semi-solid products could be the use of media which changes color in the presence of contamination.

Clinical Trials Materials and Small Batch Size Products

As processes for smaller quantities (less than 3000 units) do not allow an interpretation according to chapter 5 of these Recommendations, any presence of microbial contamination should be regarded as an alert limit. Monitoring and test conditions, like incubation or media selection remain the same as for commercial production runs.

The size of media fills for small batch size products should at least equal the number of containers filled for the commercial product.

Biological and Biotechnology Products

The manufacture of these products varies, such that there is not one single process. It may be more practical to validate the various segments of the process individually. The frequency of the revalidation should relate to the one of regular, commercial production.

Sterile Bulk Pharmaceuticals 

Whenever possible a growth medium should be used and the process should be simulated as closely as possible to the normal route of manufacturing the sterile bulk drug substance.

The aseptic manufacture of sterile bulk drug substances is a difficult process, which may have numerous individual segments that need to be validated. The possibility of microbial ingress into the system has to be considered after each step of the routine production.


The validation may include segments, where the use of growth media is not feasible.

Author: Mahender Nagaraju
Source: PIC/S Guidelines

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Wednesday, February 1, 2017

European Medicines Agencies and PIC/S agree on Audit Cooperation


 PIC/S & EMA


















PIC/S has published a "Letter of Agreement between the EEA Heads of Medicines Agencies and the Pharmaceutical Inspection Co-operation Scheme" on their website. The objective of the agreement is the exchange of information after audits among authorities and joint trainings for GxP inspectors.
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Friday, December 30, 2016

GOOD PRACTICES FOR DATA MANAGEMENT AND INTEGRITY IN REGULATED GMP/GDP ENVIRONMENTS



GOOD PRACTICES FOR DATA MANAGEMENT AND INTEGRITY IN REGULATED GMP/GDP ENVIRONMENTS

This document was written with the aim of:
Providing guidance for inspectorates in the interpretation of GMP/GDP requirements in relation to data integrity and the conduct of inspections.
Providing consolidated, illustrative guidance on risk-based control strategies which enable the existing requirements for data integrity and reliability as described in PIC/S Guides for GMP2 and GDP3 to be implemented in the context of modern industry practices and globalised supply chains.


Facilitating the effective implementation of data integrity elements into the routine planning and conduct of GMP/GDP inspections; to provide a tool to harmonise GMP/GDP inspections and to ensure the quality of inspections with regards to data integrity expectations.
This guidance, together with inspectorate resources such as aide memoire (for future development) should enable the inspector to make an optimal use of the inspection time and an optimal evaluation of data integrity elements during an inspection.
Guidance herein should assist the inspectorate in planning a risk-based inspection relating to data integrity.

This guide is not intended to impose additional regulatory burden upon regulated entities, rather it is intended to provide guidance on the interpretation of existing PIC/S GMP/GDP requirements relating to current industry practice.

 The principles of data integrity apply equally to both manual and computerized systems and should not place any restraint upon the development or adoption of new concepts or technologies. In accordance with ICH Q10 principles, this guide should facilitate the adoption of innovative technologies through continual improvement. 3.6 This version of the guidance is intended to provide a basic overview of key principles regarding data management and integrity. The PIC/S Data Integrity Working Group will periodically update, amend and review this guidance in light of inspectorate feedback, experience in using the guide and any other developments

  


DATA GOVERNANCE SYSTEM

 What is data governance?

Data governance is the sum total of arrangements which provide assurance of data integrity. These arrangements ensure that data, irrespective of the process, format or technology in which it is generated, recorded, processed, retained, retrieved and used will ensure a complete, consistent and accurate record throughout the data lifecycle.
The data lifecycle refers to how data is generated, processed, reported, checked, used for decision-making, stored and finally discarded at the end of the retention period. Data relating to a product or process may cross various boundaries within the lifecycle. This may include data transfer between manual and IT systems, or between different organizational boundaries; both internal (e.g. between production, QC and QA) and external (e.g. between service providers or contract givers and acceptors).

Data governance systems

Data governance systems should be integral to the pharmaceutical quality system described in PIC/S GMP/GDP. It should address data ownership throughout the lifecycle, and consider the design, operation and monitoring of processes / systems in order to comply with the principles of data integrity, including control over intentional and unintentional changes to, and deletion of information.

The data governance system should ensure controls over data lifecycle which are commensurate with the principles of quality risk management. These controls may be:

· Organizational
o procedures, e.g. instructions for completion of records and retention of completed paper records;
o training of staff and documented authorization for data generation and approval;
o data governance system design, considering how data is generated recorded, processed retained and used, and risks or vulnerabilities are controlled effectively;
o routine data verification;
o periodic surveillance, e.g. self-inspection processes seek to verify the effectiveness of the data governance policy.

· Technical
o computerized system control,

o automation


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Revision of PIC/S GMP Guide PE 009-13 GUIDE TO GOOD MANUFACTURING PRACTICE

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Geneva, 22 December 2016: the following Chapters of the PIC/S GMP Guide have been revised:
  • Chapter 1 on “Quality Management” (which has become “Pharmaceutical Quality Systems”); 
  • Chapter 2 on “Personnel”;
  • Chapter 6 on “Quality Control”; 
  • Chapter 7 on “Contract Manufacture and Analysis” (which has become “Outsources Activities”).
The revised Chapters 1, 2, 6 & 7 of the PIC/S GMP Guide are based on the equivalent Chapters of the EU GMP Guide with some minor differences in terms of language. Chapters 1, 2 & 7 have been aligned to ICH Q10 and the principles of “Pharmaceutical Quality System” have been integrated. A section on consultants has been added in Chapter 2. The scope of Chapter 7 has been expanded beyond the scope of “contract manufacture and analysis”. Both Chapters 1 and 7 have been renamed to reflect the changes. In Chapter 6, all sections have been reviewed and amended and a new section on “Technical transfer of testing methods” has been added.
The revision has been successfully completed by the PIC/S Sub-Committee on the Harmonisation of GM(D)P, led by Paul Gustafson (Canada/RORB). The revised GMP Guide (PE 009-13) will enter into force on 1st January 2017. All non-EEA Participating Authorities of PIC/S (and Applicants) have been invited to transpose the revised Chapters of the PIC/S GMP Guide into their own GMP Guides.
1.GUIDE TO GOOD MANUFACTURING PRACTICE FOR MEDICINAL PRODUCTS
     Download Link
2.GUIDE TO GOOD MANUFACTURING PRACTICE FOR MEDICINAL PRODUCTS
  PART II  Download Link
3.GUIDE TO GOOD MANUFACTURING PRACTICE FOR MEDICINAL PRODUCTS       
   ANNEXES
1.    Annex 1 (Manufacture of sterile medicinal products)
2.    Annex 2 (Manufacture of biological medicinal substances and products for human use)
3.    Annex 3 (Manufacture of radiopharmaceuticals)
4.    Annex 4 (Manufacture of veterinary medicinal products other than immunologicals)
5.    Annex 5 (Manufacture of immunological veterinary medical products)
6.    Annex 6 (Manufacture of medicinal gases)
7.    Annex 7 (Manufacture of herbal medicinal products)
8.    Annex 8 (Sampling of starting and packaging materials)
9.    Annex 9 (Manufacture of liquids, creams and ointments)
10. Annex 10 (Manufacture of pressurised metered dose aerosol preparations for inhalation)
11. Annex 11 (Computerised systems)
12. Annex 12 (Use of ionising radiation in the manufacture of medicinal products)
13. Annex 13 (Manufacture of investigational medicinal products)
14. Annex 14 (Manufacture of medicinal products derived from human blood or plasma)
15. Annex 15 (Qualification and validation)
16. Annex 16 [Qualified person and batch release]*
17. Annex 17 (Parametric release)
18. Annex 18 [GMP Guide for active pharmaceutical ingredients]**
19. Annex 19 (Reference and retention samples)
20. Annex 20 (Quality risk management)***
·         Appendix I: Risk Management Methods and Tools Basic Risk Management Facilitation Methods
·         Appendix II: Potential Applications For Quality Risk Management


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