Do your standards require compliance with multiple compendia? You may be able to simplify your standards testing.
The latest addition of the MAPP (Manual of Policies and Procedures) 5310.7 – Acceptability of Standards from Alternative Compendia (BP/EP/JP) published in January 2017 states that it is reasonable to accept an applicant’s proposal to use a quality standard from the BP, EP, or JP as part of the specifications for an excipient, drug substance, or drug product in the drug application, if the standard in the BP, EP, or JP is equivalent to or better than the corresponding standard in the USP/NF.
This is useful information for those responsible for marketing authorization or incoming goods control in the pharmaceutical industry.
In the finalized guidance on GMP requirements for combination product manufacturers, the FDA clarified how to comply with certain device requirements with compliance examples for prefilled syringes, drug-coated mesh and drug-eluting stents. This final version reiterates that combination product manufacturers have two options for compliance: satisfy all drug and device GMPs, or implement a streamlined quality system that focuses primarily on one but incorporates elements of the other GMP systems. This guidance details which GMPs are applicable to a product, general methods for how to implement them, key definitions, and how to make post-market changes to a product’s quality system.
A recent case from Denmark demonstrated that senior management really is responsible for GMP compliance. The Danish Medicines Agency (DKMA) has now taken an action that reinforces senior management responsibility in a very significant way: they demanded the replacement of the CEO!
It’s important that senior management understand their critical role in implementing a compliant Pharmaceutical Quality System (PQS) and in creating a good quality culture.
Are you preparing submissions to the EMA for marketing authorization this year? This guideline goes into effect in July 2017 and describes the type of information required for the manufacture and control of active substances used in medicinal products for EMA marketing authorization. It replaces the “Note for guidance on chemistry of new active” (CPMP/QWP/130/96, Rev 1) and “Chemistry of active substances” (3AQ5a) and covers new and existing active substances in one guideline.
The FDA’s newly formed Office of Pharmaceutical Quality (OPQ) will update its GMP inspections process to add risk-based factors to give sites with higher risk more attention and reward sites that exceed basic compliance.
This New Inspection Protocol Project (NIPP) changes GMP inspections by standardizing data gathering during inspections, using a question-answer based reports with a semi-quantitative scoring to allow for comparisons within and between sites, and a common inspection report structure.
The NIPP program is expected to start in 2017 as a pilot program to collect feedback and experience from the inspectors before it is formally implemented. As FDA inspections become more transparent and semi-quantitative, it is bound to be mutually beneficial to both FDA and the industry. The program was one of the 5 areas of priority for OPQ.
ABSTRACT (from the document): An analytical procedure must be demonstrated to be fit for its intended purpose. It is useful to consider the entire lifecycle of an analytical procedure, i.e., its design and development, qualification, and continued verification. The current concepts of validation, verification, and transfer of procedures address portions of the lifecycle but do not consider it holistically. The purpose of this proposed new chapter is to more fully address the entire procedure lifecycle and define concepts that may be useful. This approach is consistent with the concept of quality by design (QbD) as described in International Council for Harmonisation (ICH) Q8-R2, Q9, Q10, and Q11. The lifecycle approach can potentially be applied to all procedures, although the level of effort should be consistent with the complexity and criticality of the procedure.
Quality agreements are critical to ensure you and your contract manufacturer define each other’s roles and responsibilities with respect to quality. On November 22, 2016, the FDA released the finalized guidelines that specify what should go into quality agreements between pharmaceutical companies and outsourced contract manufacturers.
This guidance applies to commercial manufacturing for human drugs, veterinary drugs, certain combination products, biological and biotechnology products, finished products, APIs, drug substances, in-process materials, and drug constituents of combination drug/device products.
It does not apply to Type A medicated articles and medicated feed, medical devices, dietary supplements, or human cells, tissues, or cellular or tissue-based products regulated solely under section 361 of the Public Health Service Act and 21 CFR part 1271.
Quality metrics are used throughout our industry to drive continuous improvement efforts in manufacturing. Collecting the right quality metrics is critical to ensure compliance. Quality metrics can also help the FDA in developing compliance and inspection policies and procedures by allowing the FDA to:
Use a risk-based inspection scheduling of drug manufacturers
Improve ability to predict and possibly mitigate future drug shortages
Encourage the pharmaceutical industry to implement state-of-the-art, innovative quality management systems for manufacturing.
The revised draft guidance includes an explanation of how the Center for Drug Evaluation and Research (CDER) and the Center for Biologics Evaluation and Research (CBER) intend to utilize submitted data and quality metrics to help ensure that their policies and practices continue to support continuous improvement and innovation.
FDA is initiating a voluntary reporting phase of the FDA quality metrics reporting program where they expect to learn more about a limited set of quality metrics, associated analytics, and improve the FDA quality metrics reporting program.
During the voluntary phase of the reporting program, FDA will accept voluntary submissions of data from drug manufacturing firms involved in the manufacture, preparation, propagation, compounding, or processing of finished dosage forms (FDF) or active pharmaceutical ingredients (API) used in the manufacture of “covered drug products.”
For more information and to download the guidance, click here.
Does your company handle investigational drug products (IDP) the same as your commercial products? If so, you may want to consider the proposed new USP chapter on storage and transport of IDP as an addition to the Good Storage and Distribution Practices for Drug Products chapters . This new subchapter should focus on investigational drug products (IDPs; investigational medicinal products in Europe, IMPs). Transport of small quantities of product to multiple sites, minimal stability data, temperature excursions of single containers along with different distribution requirements in various countries make this a challenge for most companies. To address these challenges, the new chapter proposes the following requirements:
Storage in a safe and secured area at labelled storage conditions
Segregation for IDPs not dispensed yet and for IDPs awaiting return to sponsor or contractor
Site qualification audits need to be performed
Anticipation and tracking of expiry or re-test extensions (according to different local regulatory requirements)
Packaging qualifications should be the same as for commercially available drug products
Consideration of important distribution risk factors (e.g. distance, time, temperature, handoffs, packaging)
Confirmation that proper steps are taken to ensure IDP supply chain integrity (including checklists for patients)
Unblinded IDPs should be quarantined
Comparators should be shipped and stored according their (new) IDP labeling
This new chapter also gives a detailed example for calculating a rating of shipment risk to help identify probability and impact of errors in the supply chain.