Lecture 2 Assessing Manufacturers Compliance Flashcards
limitations of conventional product testing
- can only test on a ‘representative’ sample size
- can only test if the analyte and test method is known
- can only test if test method is specific, accurate and reliable (aka validated)
types of QA of product moved upstreams
- product design/formulation of dosage form
- control of starting materials (APIs, excipients, and containers)
- GMP compliance by manufacturers of API and finished dosage forms
- contamination control, process validation and stability testing
- use of innovative technologies and approaches (process analytical tech PAT, parametric release)
limitations of sterility testing
- high stat probability of passing sterility test even when contamination level is relatively high
- sterility test is by no means cheap (both pos and neg test)
- two weeks of incubation period is needed for sterility test
- sterilised products cannot be released in real-time
parametric release of terminal sterilised LVPs
parametric release are release based on key parameters of a validated sterilisation process, instead of results of batch sterility test:
- temp
- pressure
- sterilisation time/cycle
- bioburden of pre-sterilised parental product
what is quality risk management
a systematic framework to manage quality risk in stepwise approach comprising risk identification, analysis, reduction and communication
objective of QRM
assess risk to product quality/patient, and then manage these risk to an acceptable level
steps in QRM
- risk idenfication
- risk analysis
- risk reduction
- risk communication
risk identification
- quality of starting materials
- production and packaging processess
- premises and equipment
- personnel (human) errors
- warehouse and pest control
- cleaning procedures and contamination
risk analysis
- failure mode and effects analysis (FMEA)
- fault tree analysis (FTA)
- hazard analysis and critical control points (HACCP)
risk reduction
- reliable suppliers
- amend cleaning procedures
- revalidate processes
- training/ retraining
- tighten pest control program
risk communication
communicate to internal staff and external stakeholders
who should be concern and business of quality of medicines
- manufacturer:
- product and manufacturer licence holder
- distributor and advertiser
- research and development scientist
- production/ QC experts - regulator HSA
- product quality reviewers
- GMP inspectors
- analytical scientists
hard skills and knowledge required by manufacturers and regulators
- pharmacology and pharmacotherapy
- medicinal chem
- pharmaceutics
- pharmaceutical microbiology
- pharmaceutical law
- GMP and quality standards
- statistics
soft skills required of regulator and manufacturer
- confidence
- assertiveness
- integrity and impartiality
- perseverance
- tact and diplomacy
- oral communication and negotiation skills
- report writing and written communication skills
- willing to travel overseas regularly for business
what is quality
- fitness for use for treating patients
what does the quality of medicinal products includes
- identity of starting material
- potency of starting materials API
- purity (absence of contaminants)
- pharmaceutical quality attributes (of finished dosage form)
- hardness, friability, size, dissolution profile
- pH, clarity, color indexes, microbial limits, sedimentation
- viscosity, sterility, endotoxin level
- stability and homogeneity
what is a contaminated medicinal product
- contains undesirable foreign matters of chemical or microbiological nature
- may be present in starting, intermediate or bulk product
- introduced during manufacturing: procurement, sampling, processing, packaging, repackaging, storage, transportation
classification of contaminants
- intrinsic:
- present inherently in API, excipients, packaging materials used in formulating product
- not removed completely from starting andpackaging material during manufacture
- aka impurities often specific in nature - extrinsic:
- originate externally from production personnel, process equipment, packaging equipment, manufacturing premises
- usually non-specific in nature
why is there a need to control impurities
- overall therapeutic effect of medicinal product is dependent not only on its pharmacological properties of API but also on toxicity of impurities present
- need control of impurities in starting materials and finished products are an important part of drug development, manufacturing and GMP compliance, and regulatory assessment for marketing approval
types of impurities in API
- process related:
- un-reacted API starting material/ intermediates
- residual reagents and catalyst
- residual solvents
- residual heavy/other metals
- by-products - drug-related impurities
- degradation products (after API formed) - polymorphs
- eg. cimetidine, carbamazepine, ampicillin - stereoisomers:
- eg. dopamine, propranolol - container-closure system and labels
- primary containers: residual polymers.monomers, plasticisers, antioxidants, coating materials
labels: adhesive, printing ink
types of controls on intrinsic contaminants
- QC testing of materials and finished product (manufacturer)
- assessments of impurity profile (HSA product reviewer)
- GMP compliance (manufacturer)
- periodic GMP audits (HSA inspectors)
types of control of extrinsic contaminants
- GMP compliance
2. periodic audits by GMP inspectors to verify compliance
relation of operations to potential risk of contamination
increased operations within a given facility piece of equipment, increase risk for contamination
factor influencing stability of medicinal product
- product-related factors:
- formulation of the product
- physico chemical properties of drug subs/ excipients
- types of primary container and packaging material used - environmental factors:
- temp
- moisture
- light
- oxygen
- physical stress during transportation
- in-use contamination during consumption