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132
Manufacture and Supply, Science and Reg ulation Towards High-Qua lity Medicinal Products
look to the future”. This initiative was formed to address common challenges faced by the participating countries such as huge back­logs of product applications, high sta turnover, long registration times, inadequate financial resources, and limited capacity to assess certain types of products such as biologicals and biosimilars.
Acknowledging these common challenges, the heads of agencies of ZaZiBoNa agreed to develop a work-sharing arrangement to meet the objectives that included a reduced workload, reduction in time­line to registration, development of mutual trust and confidence in regulatory collaboration, and to provide a platform for training and collaboration in other regulatory fields. In establishing these objectives, the ZaZiBoNa initiative sought to make ecient use of limited resources to ensure timely access to quality-assured medi­cines by the public in the Southern African Development Commu­nity (SADC) region whilst at the same time building the regulatory capacity of the NRAs.
It has been reported that the collaborative initiative began with the first assessment session in October 2013. These assessments initially looked at applications common to the four founding countries that were pending in the backlog but expanded over time to review products submitted prospectively. In 2014, the ZaZiBoNa initia­tive was formally endorsed and adopted by the SADC Ministers of Health. Since then, the initiative has grown, and 14 of the 16 SADC member countries are now participating either as active or non­active participants, based on their internal capacity to conduct prod­uct assessments and manufacturing facility inspections. Currently, there are nine member countries participating actively, namely, Botswana, Democratic Republic of Congo, Malawi, Mozambique,
WHO Listed Authority and Other International Reliance and Harmonization Initiatives
Namibia, South Africa, Tanzania, Zambia and Zimbabwe. The remaining member countries do not participate actively in dossier assessment but are involved in training programs and information sharing on products approved by the collaborative procedure. The non-active member countries of ZaZiBoNa are Angola, Comoros Islands, Madagascar, Seychelles and Swaziland, whilst the observer countries are Lesotho and Mauritius. In the long term, all SADC countries are expected to participate actively, depending on their capacity. There is mutual agreement and consent is given by appli­cants for sharing information concerning the products being consid­ered. When a product has been approved by the ZaZiBoNa initiative, it means that the product has attained marketing authorization in all the participating countries. Applicants who wish to participate in the ZaZiBoNa initiative should have applied for registration of a medicinal product in at least two of the participating countries.
133
The ZaZiBoNa initiative was later absorbed by the SADC Medicines Registration Harmonization project that was launched in 2015, and funded by the World Bank for the period 2018–2020. In addition to strengthening and expanding areas of technical cooperation among member NRAs through initiatives such as ZaZiBoNa, this project has other objectives that include:
— ensuring that at least 80% of member states have national med-
icines regulatory authorities that meet minimum standards;
— ensuring regional harmonization of medicines regulatory sys-
tems and guidelines;
— facilitating capacity building of medicines regulatory authori-
ties in member states through the implementation of quality management systems; and
134
Manufacture and Supply, Science and Reg ulation Towards High-Qua lity Medicinal Products
— developing and implementing national and regional integrated
information management systems to facilitate decision-mak­ing and sharing of knowledge among member states and stake holders.
Various activities are ongoing currently to fulfil these objectives, for example, most SADC countries have conducted self-benchmarking of their regulatory systems using the WHO GBT. In addition to exist­ing SADC guidelines, regional guidelines for variations and biosimi­lars are under development. An audit of regulatory assessment skills and competencies in the region using the WHO global competence framework for regulators is also being conducted.

4.6. Conclusion

The increasing number of global harmonization initiatives such as ICH, ICMRA, Access Consortium, ASEAN, EAC, EMA and ZaZiB­oNa is clearly a positive development. Going forward, it is hoped that some of these harmonization initiatives will eventually evolve into mutual recognition and reliance schemes to avoid duplication of inspection and regulatory eorts. It is also hoped that greater inter-collaborations take place amongst some of these global har­monization initiatives leading to a “merger” of some of these initi­atives with similar and overlapping objectives, and their eventual transformation into international reliance schemes. These mutual recognition and reliance schemes will certainly help regulatory authorities expedite the product approval process. Manufacturers will also benefit from a reduction of on-site inspections which can be duplicative in nature. In a nutshell, eective implementation of reliance programs will benefit not only the regulatory authorities,
WHO Listed Authority and Other International Reliance and Harmonization Initiatives
but also the industry, the healthcare providers and, ultimately, the patients and consumers.
Singapore HSA strongly supports international reliance and global harmonization initiatives. The reliance programs that Singapore HSA engages to facilitate pharmaceutical inspections include the:
— Singapore-Australia MRA on GMP Inspection, eective 2001; — ASEAN Sectoral MRA on GMP Inspection, eective 2012; — PIC/S GMP Inspection Reliance, eective 2018; — Singapore-New Zealand MRA on GMP Inspection, eective
2020; and
— Korea-Singapore MRA on Pharmaceutical GMP Inspection,
eective 2024.
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Singapore HSA is also a member of the:
— ICMRA since 2012; — ICH since 2017; and — Access Consortium since 2021.
As a pioneer WLA eective 2023 which is accredited to the WHO GBT ML4, Singapore HSA hopes to lead by example, in interna­tional reliance, harmonization and convergence of inspection and regulatory functions.
Part II
GMP Compliance and Manufacture
of High-Quality Medicinal Products
Chapter 5
Compliance of Pharmaceutical
Manufacturers to Good Manufacturing
Practice Standards
139

5.1. Introduction to GMP

ere is a fun fact. The abbreviation GMP has been associated with Great Mountains of Papers as well as Guarantees Maximum Profit. These associations of
H
ral International Society for Pharmaceutical Engineering Singapore Conference in 2001. Both the founding CEO of the newly established Singapore Health Sciences Authority (HSA), Dr. Clarence Tan, and the co-author, Sia Chong Hock, who was the founding Director of
GMP were mentioned tongue-in-cheek at the inaugu-
140
Manufacture and Supply, Science and Reg ulation Towards High-Qua lity Medicinal Products
the GMP Audit Unit of HSA, were invited as keynote speakers to this conference. The Business Times of Singapore picked up the two associations for GMP which were highlighted during the conference and reported them the following day on 26 June 2001 (see report
Compliance of Pharmaceutical Manufacturers to Good Manufacturing Practice Standards
on previous page). In its report, the Business Times quoted: The new regulator, namely the Health Sciences Authority, will adopt high standards but will not impede industry growth. It will be a health inspector that is industry-friendly says its CEO, Dr. Clarence Tan. The Business Times also quoted: His colleague, Sia Chong Hock, whose job is to ensure that the industry adhere to GMP, was even more vivid in conveying HSA’s support for the industry. In Singapore GMP is also known as “guarantees maximum profit”, he said. This is in contrast to Europe where GMP is referred to as “great mountains of papers”.
Fortunately, or unfortunately, both associations for the abbrevia­tion (GMP) have not been forgotten, and have remained to this day. Ocially, GMP stands for Good Manufacturing Practice(s). GMP is a quality system standard implemented by manufacturers to assure that medicinal products are consistently manufactured and con­trolled to the quality appropriate for their intended uses. The small letter “c” is sometimes added as a prefix to GMP, i.e., cGMP. This is used to refer to current Good Manufacturing Practice(s) to empha­size that GMP standard is not cast in stone; it is a living standard and is dynamic. GMP standard will change in tandem with changes in pharmaceutical science and technology, pharmaceutical laws and regulations, the use of computerized systems and information tech­nology as well as other developments associated with Industry 4.0.
141

5.2. Overview of the PIC/S GMP Standard

Singapore has legally adopted the GMP standard of the Pharmaceu­tical Inspection Co-operation Scheme (PIC/S) when HSA became its first Asian Participating Authority with eect from 1 January
2000. The PIC/S GMP standard is ocially referred to as the PIC/S
Guide to Good Manufacturing Practice for Medicinal Products.