NSF packaging Flashcards

1
Q

2011/62/EU Falsified Medicines Directive

A
  • Safety features – a unique identifier and an anti‐tampering device on the outer packaging of medicines
  • A common, EU‐wide logo to identify legal online pharmacies
  • Tougher rules on import of active pharmaceutical ingredients
  • Strengthened record‐keeping requirements for wholesale Distributors
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2
Q

Anti counterfeiting goals

A

 Add at least one overt and one covert feature to all primary packaging
 Add overt and covert features to secondary packages where applicable
 Upgrade covert technologies to invisible encrypted graphics for all printed components
 Develop and Implement “track and trace” technology on all priority packs

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3
Q

Overt features

A

Holograms
 Ink colour changes when viewed at different angles
 Component corner radius
 Varnish pattern with intentional errors
 Dot varnish void
 Temperature sensitive ink
 Aphrodite

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4
Q

Covert features

A

Micro dots/text
 Coin reactive – reveals hidden code
 Scrambled Ink – opens web link when scanned
 Hidden ink – text changes through viewing lens
 Luminescent inks
 Use of taggants
 DNA Presence

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5
Q

Indicators of instability

A

Loss of drug substance
Loss of efficacy
 Loss of content uniformity
Inappropriate dosing
Reduction in safety profile
 Increase in concentration
Evaporation / drying out
Safety concerns
Microbial contamination
Safety questionable
Loss of efficacy
 Production of toxic impurities
Reduction in safety profile
NITROSAMINES!..
 Loss of pharmaceutical elegance
Loss of acceptability in use

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6
Q

Types of stability test

A
  1. Stress testing
     Establish the degradation pathways
     and the intrinsic stability of the molecule
     and validate the stability indicating power of the analytical procedures used.
     Studies include:
     Temperature
     Humidity
     Oxidation
     Hydrolysis
     Photostability
    1. Accelerated testing
       Increase the rate of degradation or physical change
       Can also be used for extrapolation
    2. Long term (real time) testing
       Evaluation of real time physical, chemical, biological and microbiological characteristics
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7
Q

Types of stability study

A

 Long term (Real time) studies
 Required for all products
 Requires a single label for all markets
 Accelerated studies
 To support shelf-life
 To demonstrate effects of
 High/low temperatures, humidity, light

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8
Q

Analytical methods for stability testing need to be:

A

 Specific
 Sensitive
 Validated
 Capable of detecting degradation

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9
Q

Certain variations may require supporting stability data

A

 Change in formulation
 Change in packaging material (less protective)
6 months, pilot x3
 There is Specific Guidance on this!
EU guideline
ICH Q12 Section 9

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10
Q

Glass key facts

A

 Super cooled liquid
 Primary constituent silica (silicon dioxide SiO2)
 Pure silica forms a glass when heated
 SiO2 molecules polymerise with strong covalent Si-O bonds
 Great strength (approx. 2.5 x tensile strength of steel)
 Thermal resistance
 Transparent to visible and some UV light
 Resistant to acid
 High softening point
 Difficult material to work
 Attacked by alkali
Addition of soda (Na2CO3) dramatically reduces softening point but high
sodium content produces low chemical resistance – susceptible to degradation
 Addition of lime greatly improves chemical resistance, by replacing
some Na+ by Ca++ and closing up the matrix
 Borosilicate glass has improved thermal resistance

Pharmacopeia tests
If a type II glass container is tested and is intact, it will pass the
Pharmacopoeial hydrolytic test
* The test then requires glass to be crushed and repeated
* Type II glass fails the test when untreated surfaces are exposed
* Type I glass continues to pass the test, even when crushed

 Advantages
* Clear/strong/stable
* Impermeable
* Acid resistant
* Surface treatable
* Hygienic
* Sterilisable by heat
* Economical

Disadvantages
* Not malleable/ductile
* Breakable
* Difficult to work
* Attacked by alkalis
* Sensitive to handling
* Heavy
* Limited colours
* Transparent to visible light and some UV

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11
Q

Plastic Key Facts

A

 Many applications – flexible
 PE and PP included in pharmacopoeias
 Adhesives and inks can migrate through plastics… labels!
 Additives – sorption and leaching

Sorption
 General term used to cover drug binding to a container when the
mechanism (i.e. adsorption or absorption) is unclear
 Overall, glass is not a threat (cf Insulin)
 Rubber closure – problem with Lipophilics
 PVC is particularly bad (pH dependent for some drugs)

Leaching
 Problems with both plastic and glass
 Polyethylene and polypropylene do not pose a hazard
 PVC is a problem due to additives in formulation

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12
Q

Rubber key facts

A

 Synthetic Rubber widely used in pharmaceuticals
* Butyl rubber
* Halobutyl rubbers
* Silicone rubber
 Complex formulations – high development costs
 Drug master files can be used to protect commercially sensitive information

Finishing and pre-treatment
 Washing
* Surface contamination
* Lubricants
* Rubber
 Atmospheric contaminants
 Sterilisation
* Autoclaving
* Irradiation

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13
Q

Aluminium, film, tubes

A

 Strong, rigid
 Impermeable at thicknesses greater than 25μ approximately
 Lightweight
 May need coating/lacquer to prevent reaction with products

General term covering the steps from plain foil to the finished material
(e.g. foil with heat seal lacquer and printing)
* Application of Adhesive Layer – Laquer/Melt
* Laminate
* Printing

Adhesive process
 Lacquer
* Solvent solutions of plastic(s) sprayed onto surface
* Solvent dried off resulting in thin film of plastic, which acts as heat seal
* Typical 4-10gsm coating
* Lacquer coating may be needed to act as ‘key’ for printing
 Melt
* Extrusion and rolling method
* Roller coating
* Higher film thickness
* E.g. polythene 30gs

Lamination
 Produces multiple layer laminate
 Paper/foil/poly – often 9μ used
 Cold forming laminates
* E.g. nylon/foil/poly
 ‘Cocktail’ of adhesives used
* E.g. PVA, Urethane

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14
Q

Container closure information is a critical component of the eCTD.

A

Within 3.2.S.6 (drug substance) and 3.2.P.7 (drug product):
* Description
* Details on the primary components
 Identity of materials of construction of each packaging component
 Component specifications
 Description
 Critical dimensions
 Drawings
 Non-compendial methods, where appropriate
* Secondary packaging components
 Brief details of non-functional components
 Additional information for functional components
.. and ALSO within 3.2.P.2 (Pharmaceutical Development): Information on the
suitability of the container-closure for its intended purpose.

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15
Q

PACKAGING SUITABILITY FOR INTENDED USE:

A
  • PROTECTION from factors that can cause degradation in the quality of the dosage form
  • COMPATIBILITY – that the container closure will not cause unacceptable changes in
    the quality of either the dosage form or the packaging component
  • SAFETY from leaching harmful or undesirable amounts of substance to which a
    patient might become exposed during treatment with the dosage form
  • Do not forget the ink printing and label adhesives (on plastic and other permeable
    components)!!
  • PERFORMANCE – where the container meets the functionality for which it was
    designed. Providing appropriate levels of:
     System functionality (where a delivery system is designed to help patient
    compliance – such as calendar packs, packs with counters etc.)
     Drug delivery (where the container-closure system is designed to deliver
    specific dosages – such as transdermal patches, dry powder inhalers,
    metered dose inhalers etc.)
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16
Q

CONTROL OF PACKAGING COMPONENTS

A

PHYSICAL CHARACTERISTICS
* Dimensional criteria (shape, wall thickness, design tolerances)
* Physical parameters (unit weight)
* Performance characteristics (metering valve delivery volume, ease of movement of
syringe plungers)
CHEMICAL COMPOSITION
* Extractables (extraction profiles for polymeric and elastomeric components of
inhalation products)
* Leachables
* Change in formulation of a packaging component

Secondary components are packaging items that are not intended to come into contact with
the dosage form. They include cartons, aluminium over-pouches, paper or plastic
overwraps etc. These must provide one or more of the following functions:
* Protection from moisture ingress or egress
* Protection from gaseous ingress or egress
* Protection from light
* Protection from rough handling
* Protection from microbiological spoilage (e.g., maintaining sterility)

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17
Q

WHAT SHOULD I PUT IN MY REGULATORY SUBMISSION?

A
  • Description
  • General description of the container-closure system
  • Specific information for each component:
     Product name and code
     Name and address of the manufacturer
     Physical description of the component (type, size, shape, colour)
  • Materials of construction:
     Plastics, paper, metal glass etc
     Identified by code and source
     Alternative materials
  • Operations of preparations prepared on the packaging components (washing,
    coating, sterilisation etc.)

Information about the suitability
* Complete chemical composition for every material used in the manufacture of a
packaging component
* Test results from qualification and characterisation studies:
 Protection: USP tests
 Safety and compatibility: extraction / toxicological evaluations (e.g.,
USP Biological Reactivity Test)
 Performance: USP and Non-USP functionality tests
 Tests on the assembled container-closure system

Information about the quality control
* Information on the quality controls applied by the component suppliers
* Certificates of Conformity or Analysis
* Tests and methods applied to components on receipt, including:
 Acceptance criteria for extractables
 Dimensional and performance criteria

Appropriate diagrams must always accompany information on container-closure
components. The extent of detail required depends upon the type of component, but
these typically include diagrams of:
* Bottles
* Tamper-evident and child-resistant closures
* Multiple-layered materials (e.g., transdermal patches)
* Metered dose valves
* Actuators
* Component manufacturers
* Materials manufacturers
* Stability data

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18
Q

CONTAINER-CLOSURE SYSTEMS FOR “HIGH-RISK” DRUG PRODUCTS

A

Inhalation drug products
These include inhalation aerosols (MDIs), inhalation solutions, suspensions and sprays
(administered via nebulisers), inhalation powders (DPIs) and nasal sprays.
These are considered “high risk” because they are intended for patients with compromised
respiratory function, and specific additional requirements are applied to the packaging
components used for these types of products.
There are three important US guidances on these types of products which we will look at
below (note that US guidances can be draft for many years):
* Metered dose inhaler (MDI) and Dry Powder Inhaler (DPI) Drug Products; CMC
Documentation (updated 2018) – draft
* Nasal Spray and Inhalation Solution, Suspension and Spray Drug Products; CMC
Documentation (2002) – final
* Inhalation Drug Products Packaged in Semi-permeable Container-Closure Systems
(2002) – draft

Nasal spray and inhalation solution products
Here the administered dose is directly dependent on the design, reproducibility, and
performance characteristics of the container-closure system. The selection of the suitable
pump for a given set of formulation characteristics (viscosity, density, surface tension,
rheological properties etc) is of considerable importance.
Information is needed on:
* Fabricators of the container, closure and the assembled pump
* Fabricators for each part of the pump
* Unique identifiers for different parts of the pump
* Unique identifiers of the container, closure and the assembled pump
* Engineering drawings of the container, closure and pump components
* Precise dimensional measurements of the container, closure and pump components
* Composition and quality of materials of the container, closure, pump, and pump
components
* Composition and quality of materials of the container, closure, and pump
components
* Control extraction methods and data for elastomeric and plastic components.
* Toxicological evaluation of extractables.
* Acceptance criteria, test procedures and analytical sampling plans:
 Physicochemical parameters and dimensional measurements of the
container, closure and pump components
 Qualitative and quantitative extractable profiles from the container,
closure, and pump components
 Performance characteristics of the pump

Inhalation products in semi-permeable containers
For these types of container-closure systems, the same basic information as for nasal
products is required. An additional concern for these containers is the integrity of the
container – and the need to include more detailed information on the SECONDARY
packaging components than would normally be required for other types of products.
The reason for this is that semi-permeable primary container-closure systems (such as LDPE
vials) need to be protected by secondary packaging to minimise and control the entry of
chemical contaminants from the local environment into the drug product. The secondary
packaging therefore plays a crucial role in assuring the reproducibility of batch-to-batch
quality.

Injectable and ophthalmic drug products
INJECTABLES
Considerations for injectable products include:
* The potential for haemolytic effects
* Protection from microbial contamination
* Protection from light and gases
* Protection from solvent loss
* Protection from exposure to water vapour

The type of materials chosen must be clearly justified:
* Elastomeric components:
 Ph Eur /USP Elastomeric Closures for Injections
* Plastic components:
 USP Biological Reactivity tests
* Glass components:
 USP Containers: Chemical Resistance – Glass Containers
 Ph Eur Glass Containers for Pharmaceutical Use

OPHTHALMICS
These are usually solutions in an LDPE bottle with a built-in dropper (often referred to as
“droptainers”), or ointments supplied in metal tubes with an ophthalmic tip.
Considerations for these products include:
* The potential for the container-closure to form substances that irritate the eye
* Potential for particulate contamination
* Reactivity of the dosage form with the metal container
* Maintenance of sterility
* Seal integrity
* Reactive gases

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19
Q

Standard labelling - outer

A

 Name, Strength, Pharmaceutical form
 Tradename – INN / avoid confusion
 Dosage form – EDQM standard terms
 Braille

Qualitative and Quantitative statement
 Per dosage unit or e.g. mg/ml
 Number of doses
 Excipients
 Those known to have a recognised effect - e.g. Sucrose
 Note that there is specific EU guidance on certain substances
 E.g. All products containing ethanol
 ALL EXCIPIENTS for injectable, topical, ocular preparations

Method / route of administration
 “Keep out of the reach and sight of children”
 Special warnings
 Expiry date

Storage precautions
 Precautions for disposal of unused product
 Basic information
 MA holder
 MA number
 Batch number
 Instructions for use (non-Rx)
 Authenticity and tamper evidence

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20
Q

Labelling Exemptions
Blister packs and small packs

A

Blister packs and small packs
 Name
 MAH
 Lot no.
 Expiry date
 Plus for small immediate packaging units
 Route of administration
 Contents by weight, volume or unit

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21
Q

Variations for labelling can come from

A

These can come from:
 Upgrades to the product / substance e.g. new stability data – longer shelf-life.
 New indications / further patient groups
 SAFETY MONITORING
 “PRAC variations”
 see example for ibuprofen in your notes.
 Sometimes as URGENT SAFETY RESTRICTION variations.

22
Q

PACK
Module 3.2.P, Drug Product

A

P.1 Description and Composition
Concise information on integral medicinal products, and brief information on any additional medical
device (part)/accessories provided and intended for use with the medicinal product, should be submitted,
and their identity (e.g. type/version), description and function should be stated.
P.2 Pharmaceutical Development
This section of the dossier should summarise the information relevant to development of the specific
medical device (part) integrated into the medicinal product, including the rationale for its selection in the
specific sections of 3.2.P.2. A risk assessment summary for the medicinal product, aligned with relevant
risk management principles in ICH Q9, should be presented.
P.2.2 Drug Product
P.2.3 Manufacturing Process Development
P.2.4 Container Closure System (CCS)
P.2.5 Microbiological Attributes
P.2.6 Compatibility
P.3 Manufacture
P.3.1 Manufacturers
P.3.3 Description of manufacturing process and process controls
P.3.4 Controls of critical steps and intermediates
P.3.5 Process validation and/or evaluation
P.5 Control of drug product
P.5.1 Specification(s)
P.7 Container closure system (CCS)
P.8 Stability
Module 3.2.A.2, Adventitious Agents Safety Evaluation
Module 3.2.R, Regional Information, Medical Device

23
Q

Artwork approval process

A

Artwork preparation
Transfer to supplier
Generate proof
Customer approval
Plate preparation and control
Printing
Supply of component

24
Q

Prepare artwork
Design Requirements

A
  • Regulatory
  • Mandatory Text
  • Marketing
  • Branding
  • Anti-counterfeit Measures
  • Overt
  • Covert
25
Q

Artwork Origination

A
  • Software
  • Secure Storage
  • Naming conventions
  • Folder structures
  • In-Process
  • Final Approved
  • Obsolete
  • Rejected
  • Revision Control
  • Archiving
     Outsourced?
  • Approved Supplier
26
Q

Artwork process controls

A
  • Converters Code
  • Item Number Allocation
  • Pharmacode Allocation
  • Version/Revision Control
  • Colours – Pantone ref
  • Translation
  • Who Checks…?
  • Pack Development
  • Packaging
  • Regulatory
  • QA
  • Secure Storage of Final Copy
27
Q

Artwork transfer

A

Electronic
* Email
* Secure Server
* Encryption
* Transfer Errors
 Manual Hard Copy
* Converted at Printers

28
Q

Artwork Proof generation and approval

A

Final Check
* Artwork Dept
* vs Original
* Colour match
* Layout
* Dimensions accurate

29
Q

Artwork Copy change and proof reading

A

Oral liquid
* Antihistamine
* Antiemetic
* Sedative
 Instruction for dosage changed
* From mls
* To xx 5ml spoonful’s

30
Q

Artwork - print plates

A

Preparation
* Unique Identification
* Version Control
* Traceable to Original Artwork
* Secure Storage
 Use
* Multi-Use
* Authorised Issue and Return
* Rotation of plates within set (wear)
 Destruction
* Secure

31
Q

Artwork printing

A

Specification
* Paper/card/labels
* Colours
* Dimensions
* Splices
* Artwork unique referenced
 Automated Devices
* Print presence/absence – camera systems
* Double sheets
* Bar codes/pharmacode readers
* Splices
 In Process Checks
* Device challenges
* Colour checks
* Dimensional checks
* Quality

32
Q

Artwork common challenges

A

Multiple markets supplied
* 1000 of artworks to manage and update
* Different regulatory requirements pack (even in EU… Blue Box information)
 Multi-language packs
* Space
* Proof reading
 Implementation date for regulatory approvals
* When should the new artwork be placed onto the market?
* Good link with regulatory required

33
Q

Artwork supplier considerations

A

Due Diligence – financially sound and ethical
 Facility capacity, location, supply chain and back up
 Standards for manufacture
* Technical capability
* Operating to recognised standards (PQS)
* Quality culture
* Facility design
* Hygiene and cleanliness
* Process controls and security

34
Q

Artwork standards for manufacture

A

Depend upon:
* Use of the component
* Criticality of component
* Further processing e.g. cleaning
 Aim should be GRADUAL IMPROVEMENT in standards to that of the
dosage form manufacturer

35
Q

Artwork - Key areas of interest for the QP

A

Change control systems
 Artwork management
* Control of printing plates
* Digital artwork management
 Line clearance
 Opportunities for mix-ups
 Contamination (primary materials)

36
Q

Artwork - Product security

A

Use, control and verification of security codes
 Unique controlled numbering systems
 Secure storage and documented issues/returns
 Avoidance of processing products with similar appearance in close proximity
 Controlled set up procedures
 Digital file control and access on-line

37
Q

No composite gang printing

A

 Verification of replacement print media during runs
 Verification and control of splices
 No replacement of missing labels
 Accurate counts
* Control of rejects, scrap and over run
* Labels may be sequentially numbered
 Running the web to plain print if possible

38
Q
A
39
Q

Packaging vision systems

A

Missing or wrong characters
 Missing parts of a character
 Filled in letters
 Missing accents or symbols
 Missing graphical elements
 Wrong barcodes
 Wrong colours
 Wrong font
 Braille

40
Q

Packing Supplier management

A

Audit
* Risk-based (determine need and frequency/duration)
* ‘Desk top’ vs physical audit
* Periodic re-evaluation
 Quality/technical agreement
 Material specifications
* Agreed quality standards
* Agreed sampling plans
 Ongoing performance monitoring/reviews

Specific guidance for the manufacture of these materials is provided however by the following
documents:
 ISO 15378 (2017): Primary packaging materials for medicinal products – particular
requirements for the application of ISO 9001:2015, with reference to Good Manufacturing
Practice (GMP)
 PS 9000 (2016): Chartered Quality Institute of Quality Assurance/Pharmaceutical Quality
Group in a Code of Practice Pharmaceutical Packaging Materials – the application of ISO
9001:2015 to pharmaceutical packaging materials

Goods receipts checks
Typical checks
* Condition and security of delivery vehicle
* Cleanliness
* Transit damage
* Identity
* Quantity
* Purchase order (authenticity of delivery)

The different items should be
* Separated – to avoid mix-up!
* Labelled
* Stored pending sampling
 Stock inventory records will also need to be updated

41
Q

Packing - Sampling

A

The Sampling Plan for packaging materials should take account of at least the following
* The agreed quality standard
* The nature of the material (e.g. primary and/or printed packaging material)
* The production method
* The knowledge of the QA system of the packaging material supplier based on audit
* The quantity received
The number of samples taken should be determined statistically and specified in a sampling plan
The typical plans adopted
* The well known n + 1 rule
* Statistical plans e.g. IS0 2859

42
Q

Packing component specs

A

Specifications for starting, primary or printed packaging materials should include, if applicable
* A description of the materials including
* The designated name and the internal code of reference
* The reference, if any, to a pharmacopoeial monograph
* The approved suppliers and, if possible, the original producer of the products
* A specimen of printed materials
* Directions for sampling and testing or reference to procedures
Qualitative and quantitative requirements with acceptance limits
 Storage conditions and precautions
 The maximum period of storage before re-examination

43
Q

Packing line validation

A

Feeder design
Tablet feed rate
Line dwell time
Forming temperature
Sealing temperature
Sealing pressure
Line speed
Product security certification - correct product, correct fill, blister sealed

44
Q

Packing line start up checks

A

Key to using the packing process is the start‐up checks:
* Line clearance
* Incoming bulk and components visual check for condition
* Critical processes validation
* Calibrations complete and in date
* The name and batch number of the product being handled should be displayed at
* each packing line or station.”
* All products and packing materials checked on delivery to the packing department
* for quantity, identity and conformity with the packing instructions.

45
Q

Packing line in process controls

A

Once the process is underway, it is necessary to confirm continued acceptable operation through a
series of controlled in‐process checks.
On‐line control of the product during packaging should include at least checking the
following:
(a) General appearance of the packages;
(b) Whether the packages are complete;
(c) Whether the correct products and packaging materials are used;
(d) Whether any over‐printing is correct;
(e) Correct functioning of line monitors.
Samples taken away from the packaging line should not be returned.
There may be other product or process specific checks introduced by the company for example
integrity test, torque tests, blister seal checks etc.

Products which have been involved in an unusual event should only be reintroduced
into the process after special inspection, investigation and approval by authorised
personnel. Detailed records should be kept of this operation.

46
Q

Packing line end of run checks

A

The final stage in the process is the end of run check, covering:
 Reconciliation
 Line clearance
 Retained samples
 Returns to warehouse

47
Q

Packing line IPCs

A

On-line control of the product during packaging should include at
least checking the following:
a. General appearance of the packages
b. Whether the packages are complete
c. Whether the correct products and packaging materials are used
d. Whether any over-printing is correct
e. Correct functioning of line monitors”

48
Q

Packing line visual IPCs

A

Routine visual checks to ensure the quality of the product during the
packaging process
 Visual verification that the correct materials are being used, printed,
information applied online is correct, the pack is assembled correctly
and there is no physical damage occurring
* Collations and shipper
* Tamper evident labels
* Carton and leaflets
* Blister

49
Q

Packing line challenge tests

A

Splice detection
Vision System
 Blister seal
 On-line verification
* Printed foil
* Leaflets
* Cartons
 Checkweigher

50
Q

Packing line test frequencies

A

How often must these checks be carried out?
* Challenge tests
* Start and end of batch
* After machine has been switched off
* After engineering activity
* Visual tests
* Start and end of batch
* Every 30mins – 2 hours
* After machine stoppages as above
 Record all tests in Packaging Batch Record

51
Q

Packing line rejects

A

Clearly labelled reject bins for empty blisters and partially filled blisters
 Reject bins for cartons
* Missing blisters
* Missing leaflets
* Incorrect code
 Reprocess, when… how?

Control
 Pack Breakdown
 Inspection
 Reintroduction before Verification system
 EOB or specific times during batch (recorded)
 Clear approved procedures

Rework
 Documented procedure
* How and when? During or at end of batch?
* How many times is allowable?
* Rework due to coding error?
* Rework into another market pack due to commercial need?
 Activity recorded – batch record or log book
 Appropriate and validated equipment used
 Authority requirements
* E.g. Russia expect a validated process