Label reconciliation
On product
On secondary packaging
Initials
Used
Printed
Used
Printed
Created labels
4,200
365
Labels on product/box
4,116
345
Labels on lab samples
10
1
Labels on quarantine forms
2
2
Labels on batch record
1
1
Labels rejected
2
Labels unused
69
16
Total
4,200
4,200
365
365
Yield reconciliation | Loss | Yield | Initials |
---|---|---|---|
Theoretical yield | 4,750 | ||
Yield after preparation | 4,165* | ||
Loss during inspection | 27 | ||
Loss during labelling | 2 | ||
Laboratory samples | 10 | ||
Final yield | 4,126 | ||
Total | 4,165 | 4,165 |
Table 34.1 shows that the ampoules are packed in boxes of 12 ampoules. At first glance the reconciliation seems to fit. On closer inspection, there are some deviations: it seems that 10 ampoules are not labeled and there are two boxes labeled too much (4,116 ampoules correspond to 343 boxes). There is nothing else than to check whether the line clearance has been performed, to inspect the produced batch (are all boxes filled?) and to count the ampoules and boxes again. A non-conclusive reconciliation can be based on counting and/or writing errors. The relatively low yield may be explained satisfactorily. However, verification of sufficient inspection of the ampoules (glass particles present?) is needed. Also additional particle counts can be considered because of the reported trouble in the sealing of the ampoules.
34.8 Quarantine Management
To prevent the delivery of unapproved products a watertight quarantine policy is very important. Materials with a quarantine status must be separated from released materials in a totally safe way.
The following items must have the quarantine status:
Unreleased starting materials
Intermediate and bulk products which are not directly further processed
Filled units that have not yet been labelled
Products not yet analysed or released or both
Starting materials or products where doubt about quality is raised after release of the batch in question
It is preferable that these items are placed in a lockable quarantine location. An alternative is storing in lockable cabinets or quarantine-carts. The access to the quarantine locations should be limited to a small number of people.
If storage in a closed quarantine location is not possible, for example a bulk product in a production vessel that is not directly filled and labelled, the quarantine status is stated with a striking and well attached plate or label.
The quarantine status is indicated and also recorded on the batch documentation, including the number of items placed in quarantine and the additional number of samples that may be taken.
34.9 Quality Control and Release
34.9.1 Batch Documentation Review
Final inspection is an essential element in controlling the quality of pharmaceutical preparations. In the first place, the final control comprises of the control of the batch documentation. In a larger organisation, such as a hospital, this is often the task of the production pharmacist.
The final inspection of the batch preparation record should comprise of the following checks:
Are all raw and packaging materials properly identified and is the correct amount of each substance processed?
Are all items of the preparation record completed correctly?
Are all initials put?
Are all IPC’s within limits and are any discrepancies handled correctly?
Is the necessary documentary evidence, such as print-out of pH meter, packaging of used filter, print-out of filter testing device, sterilisation indicator and sterilisation report, attached?
Are raw data for critical processes within specifications?
Are the correct labels used and are the printed data correct and complete?
Is the label and yield reconciliation, including line-clearance, performed correctly?
Are deviations, if any, adequately documented and concluded?
If there are deviations from the desired process that need extra attention during quality control, this is noted on the protocol. An example is a too long sterilisation process, in which case special attention must be paid during analysis to the presence of possibly formed degradation products.
34.9.2 Quality Control
The Quality Control (QC) department has to operate according to Good Quality Control Laboratory Practice (GQCLP) standards [2]. All QC methods have to be validated and verified before application. The instruments used for QC are qualified and calibrated before QC testing is performed. There is a procedure in place for the investigation of Out Of Specification (OOS) and Out Of Trend (OOT) results. The reference standards used should be certified, qualified and verified. Documentation and traceability are important such as in production. All raw data should be retained.
During quality control the laboratory checks whether the product meets all specifications. The control of the end product includes a number of non-destructive tests, such as checking the yield or the weight distribution or a visual control of packaging and labelling. Subsequently the required analytical and microbiological tests are carried out. The assessment of the finished product includes production conditions, the results of IPC testing, the documentation review and compliance of the final product with the specifications.
An important part of the quality control is the sampling policy (number of samples, method of sampling, select or random samples or both see Sect. 20.4). The selected samples must be taken in those places where the risk of deviations is greatest (worst case procedure, see for instance 11.5 for sampling suspension-type suppositories after serial filling). In addition, samples are taken for stability testing (reference and retention samples) and validation.
QC is not restricted to laboratory operations, but should be involved in all decisions related to product quality (see Sect. 35.6). As an example, QC participates in the investigation of complaints about product quality. QC is involved in the assessment and the monitoring of the stability of the products as well. The QC department has to approve the IPC methods used in production. In all situations, the independency of QC from the production department is fundamental.
When the pharmacy doesn´t have own facilities for conducting pharmaceutical analysis, these QC activities can be outsourced [4].
34.9.3 Release Policy
The final release of products comprises a major responsibility, which must be independent of production. In pharmaceutical industry release is performed by a qualified person (QP), in pharmacies often by a pharmacist. Investigational medicinal products (IMPs) always have to be released by a notified QP (Sect. 25.3.4).
The extent of the final inspection and release policy depends on the type of preparation. Thus, for extemporaneous preparations an independent control of the preparation record and a few non-destructive inspections of the product will suffice. If no abnormalities are observed, an authorised pharmacist can perform the product release. In some countries a delegated person may release the extemporaneous product conditionally; afterwards, within a defined time frame, the authorised pharmacist releases the product formally.
In some situations, for example with very short-lived radiopharmaceuticals, conditional release before all QC tests are performed is necessary. As a consequence, process validation is important. An immediate recall procedure must take place, when product quality is found to be insufficient.
Stock preparations usually undergo an extensive analytical control (see Sect. 34.9.2) and remain in quarantine until the QC is fully completed (see Sect. 34.9). The release is based on the assessment of the document control in combination with the analytical quality controls. During release, final reconciliation takes place. For certain preparations (e.g. aseptic preparations) also the results of monitoring of production conditions are included.
Parametric Release
Parametric release is a system of release that gives the assurance that the product is of the intended quality based on information collected during the preparation process and on the compliance with specific GMP requirements related to parametric release [7]. The principle is based on the recognition that a comprehensive set of in-process tests and controls may provide greater quality assurance that the finished product meets the specifications than finished product testing. Parametric release might be applicable for the routine release of finished products without carrying out a sterility test and can be authorised if the data demonstrating correct processing of the batch provides sufficient assurance, on its own, that the process designed and validated to ensure the sterility of the product has been performed. At present parametric release may only be applied for products terminally sterilised in their final container.
Parametric release of products with a market authorisation has to be authorised by the competent authorities. Authorisation is based on a strict set of requirements described in annex 17 of the EU GMP [7]. The principle of parametric release is also used in the release of terminally sterilised products in hospital pharmacy (see Sect. 30.9). The requirements mentioned in GMP annex 17 have to be described in a procedure. One of the requirements is a risk assessment of the process (see box in Sect. 34.14.1).
34.10 Validation: General Principles and Terminology
34.10.1 Validation and Qualification
The GMP (Annex 15) requires that the producer controls the critical properties of the product and of the critical steps in the process [3]. This means that the quality of the design of the product, the preparation or manufacturing process, the equipment and automated systems used have to be assured. The organisation must demonstrate that processes, equipment, systems, installations and analysis perform reliably and reproducibly under all possible conditions. This is usually called validation.
According to GMP, validation is the action of proving, in accordance with the principles of GMP, that any procedure, process, equipment, material, activity or system actually leads to the expected results. Qualification is the action of proving that any equipment works correctly and actually leads to the expected results. The word validation is sometimes widened to incorporate the concept of qualification.
Because of these somewhat vague and overlapping definitions, in this chapter the term qualification is used in the case of equipment and persons and the term validation when assessing processes or methods.
34.10.2 Prospective, Concurrent and Retrospective Validation
As a rule, qualification of equipment and building-related installations takes place before putting into operation (= prospective). Validation of preparation and manufacturing processes is done preferably prospective as well, when designing a new process. However, in some situations qualification or validation has to be performed simultaneously with the application of the equipment or process; this is called concurrent qualification or validation. Concurrent qualification or validation should only be applied to simple equipment or processes, where there is very little chance that the outcome would be negative and products would have to be destroyed.
It is also possible to perform a qualification of equipment or validation of a production process that is already operational, but has not been previously validated. This so-called retrospective validation consists of collecting, evaluating and assessing data from the past. Retrospective validation is only possible if no significant changes in the method of preparation or equipment have occurred during the measuring period, and if sufficient, reliable data are available. If that is not the case, additional prospective validations have to be performed.
When changes occur, it has to be ascertained that the product still meets the specifications and whether re-validation is necessary to prove this. Therefore, an effective change control procedure has to be in place.
34.10.3 Re-validation and Requalification
A one-time validation or qualification does not exist whether regarding equipment or process. The minimum requirement is that the status of validation and qualification has to be evaluated on a regularly basis. The evaluation frequency has to be pre-defined in accordance with a risk-based approach. The evaluation has to include a systematic going through any changes, deviations or trends in performance e.g. as indicated from test results. If the evaluation leads to the conclusion that the “validated state” is changed a targeted re-validation has to be done. If there is no indication or need for re-validation the evaluation is documented in a report, which has to be approved by the same functions as the initial validation or qualification. For sterilisation processes re-validation is mandatory every year. Beyond the regular re-validation an important reason for re-validation is an essential change in the equipment, the process or the product range.
All proposed changes must go through the change control procedure (see Sect. 35.6.10) to determine the impact of the proposed change on all related equipment, systems and processes. A standardised risk assessment procedure may be helpful to determine the extent of re-validation activities. It is usually not necessary to entirely repeat the initial validation. Guided by the quality requirements of the product and the nature of the changes a decision is made which parts of the initial validation have to be repeated.
34.10.4 Organisation
In general, the head of the production department and the head of the QC department have management responsibility for the validation program. Quality staff may play a significant supporting role in supporting validation activities. The final responsibility for validation is described in the validation master plan (see Sect. 34.11). Validation activities should only be performed by suitably trained personnel who follow approved validation procedures.
Despite its complexity, validation provides benefits. Besides the increased control of processes, validation provides more insight into the critical factors, which can result in increased patient safety, fewer errors and less rejections. The PIC/S has published a recommendation regarding validation, which may be used as reference material [5]. However, the latest version is from 2007 and recent developments are not included.
In the following sections the principles and different forms of validation and qualification are elaborated.
34.11 Validation Master Plan
Validation has to be planned, implemented and maintained in the total life cycle of products, premises, equipment and systems. A systematic approach targeted at local conditions is mandatory and it is recommended to document this approach in a so-called validation master plan (VMP) [3, 8]. According to Annex 15 of the GMP validation master plan contains the following subjects:
Validation policy
Organisational structure of validation activities
Summary of facilities, systems, equipment and processes to be validated
Documentation format: templates for protocols and reports
Planning and scheduling
Change control
Reference to existing documents
The validation policy indicates the necessity of the validation work and the responsibility of the management, so that the preconditions for implementation can be met.
In the VMP the organisation of the validation and the tasks of the members of the validation team (see below) are laid down. What to validate and to what extent is decided after the execution of a risk assessment. The most frequently used methods for risk assessment are described in ICH Q9 [9] (see also Chap. 21).
Through prioritisation, the sequence of the qualification and validation activities is formulated. For each device or process acceptance criteria have to be set based on a risk assessment including critical aspects for the total product range. Tests in relation to acceptance criteria are described in test plans. Tests have to be reported and the approved report might be the base for future change control. Ideally, protocols and reports with a fixed layout are used.
Qualification and validation can be outsourced. However, the responsibility remains in-house so the contract-taker has to be approved according to current GMP requirements for outsourced activities [10]. For example, the following qualification and validation items can be outsourced: LAF cabinets, safety cabinets, HVAC-systems, sterilisers, rinsing machines and devices for performing filter integrity testing. When tasks of qualification and validation are outsourced, internal approval of protocols, raw data and reports have to take place according to internal procedures.
Activities should be planned in a logical way for efficiently achieving a validated state. After listing and prioritising the activities a validation plan (including costs and need for resources) and a timetable are formulated and presented to the management. A logical planning begins with the validation of the analytical methods because they underpin the conclusions of the process validation. Also before initiation of process validation of production processes the qualification of the relevant equipment has to be finalised. For example, before validating aseptic processes, qualification of the HVAC-installation has to be finished.