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142
Manufacture and Supply, Science and Reg ulation Towards High-Qua lity Medicinal Products
This PIC/S GMP standard is organized into nine Chapters and 20 Annexes. Chapter 1 deals with the Pharmaceutical Quality Sys­tem of the manufacturer, including the need to conduct Product Quality Review and Quality Risk Management. Chapter 2 deals with Personnel, Chapter 3 deals with Premises and Equipment, and their design, construction, maintenance and cleaning, while Chap­ter 4 on Documentation has provisions concerning Standard Oper­ating Procedures (SOPs) and records such as the Batch Production Records, Batch Packaging Records, Analytical Records, and Distri­bution Records, that are required to be kept by the manufacturer. Chapter 5 covers Production (including Packaging) and it deals with the control of production and packaging processes including the need to conduct process validation studies, whilst Chapter 6 is concerned with the Quality Control (QC) of starting materials, intermediate products, packaging materials and finished products and the need to use validated test methods. Chapters 7 covers out­sourced activities, including contract manufacture and contract testing (analysis) whilst Chapter 8 deals with the handling of com­plaints and product recalls. Chapter 9 is about self-inspection or internal quality audit. Each of these chapters will be elaborated for a better understanding of why they have been incorporated into the PIC/S GMP standard.
In addition to the nine chapters, the PIC/S GMP Standard also has 20 Annexes which stipulate additional requirements for vari­ous types of medicinal products and GMP-related matters. These Annexes are referred to by the inspectors when they inspect specific categories of manufacturers, e.g., facilities producing sterile prod­ucts, biologicals, radiopharmaceuticals, herbal products and other pharmaceutical dosage forms.
Compliance of Pharmaceutical Manufacturers to Good Manufacturing Practice Standards

5.3. How is an On-site GMP Inspection Conducted?

In the conduct of an on-site GMP inspection of a pharmaceutical facility, the inspector is often guided by the flow of the manufactur­ing processes, rather than by the 9 Chapters and 20 Annexes of the PIC/S GMP standard. Appended below is a typical manufacturing
143
Typical manufacturing flow
flow at a pharmaceutical production facility. At the manufacturing facility, the inputs are the starting materials, comprising the active pharmaceutical ingredients (APIs), excipients, and the packaging materials. During production and packaging of a pharmaceutical dosage form, such as tablets, the processes include weighing, mixing, granulation, drying, compression, coating, packaging, labeling, with
144
Manufacture and Supply, Science and Reg ulation Towards High-Qua lity Medicinal Products
QC testing carried out at the dierent manufacturing stages, as well as before batch release. The outputs of the entire manufacturing process are the finished pharmaceutical dosage forms such as tablets, capsules, creams, ointments, liquids, eye drops and injections. Thus, a pharmaceutical inspector often finds it convenient and practical to begin his on-site GMP inspection at the Warehouse, followed by the Weighing Room, Production Areas and Packaging Room, and the QC Laboratories such as the Chemistry Laboratory and Microbi­ology Laboratory. Last but not least, there is also a Document Audit covering the review of SOPs, Records, Reports and Specifications, before the conclusion of the on-site inspection. However, it must be emphasized that an experienced inspector can choose to commence an on-site GMP assessment of a pharmaceutical manufacturing facility at any point in the manufacturing flow. The inspector is not obliged to start his inspection from the warehouse.
However, as it is practical and convenient for the inspector to con­duct an on-site GMP inspection following the manufacturing flow, this chapter will start with the warehouse where the starting mate­rials are stored.
5.3.1. Why is the Warehouse Inspected?
The objective of inspecting the warehouse is to assess that:
— all starting materials such as the APIs, packaging materials and
pharmaceutical excipients have approved specifications, and these starting materials are purchased from pre-qualified suppliers;
— approved written procedures are in place for managing receipt,
quarantine and sampling of starting materials for quality
Compliance of Pharmaceutical Manufacturers to Good Manufacturing Practice Standards
assessments, release of these starting materials upon suc­cessful assessments, as well as for managing rejected materi­als and products; and
— the environment of the ware-
house has control programs (e.g., temperature and relative humidity monitoring and pest control programs) in place, which can preserve the quality of materials and prod­ucts stored at the warehouse(s).
The GMP requirements for the warehouse are covered under the PIC/S Guide to GMP for Medicinal Prod­ucts Chapter 3 (Premises: Storage Areas) and Chapter 5 (Production: Starting Materials). After inspecting the warehouse, the inspectors will audit the weighing (or dispensing) room.
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Temperature and relative humidity
5.3.2. Why is the Weighing (or Dispensing)
monitoring
Room Inspected?
The objective of inspecting the weighing room is to assess that:
— calibrated, accurate and reliable weighing balances are used; — the weighed materials are of correct identity, quantity and quality; — authorized personnel wear appropriate personal protective
equipment (PPE); and
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Manufacture and Supply, Science and Reg ulation Towards High-Qua lity Medicinal Products
— the weighing room is environmentally controlled to prevent
cross-contamination.
Thus, the items covered by the inspector when he audits the weigh­ing room will include calibration of the weighing balances, labe­ling of starting materials, wearing of proper PPE by the operators, installation of eective dust extraction system and maintenance of the weighing room. Inspection of the weighing or dispensing room is covered under the PIC/S Guide to GMP for Medicinal Products Chapter 5 (Production: Dispensing).
Weighing (dispensing) process
After inspecting the weighing room, the inspector will move on to audit the production processes. In the case of tablet manufacturing, the production processes will comprise mixing (or blending), gran­ulation, drying, tablet compression and coating. These processes are carried out at the production areas.
Compliance of Pharmaceutical Manufacturers to Good Manufacturing Practice Standards
5.3.3. Why are the Production Areas Inspected?
The objective of inspecting the production areas where the mixing/ blending, granulation, drying, tablet compression and coating pro­cesses are carried out, is to assess that the:
production premises are designed to prevent cross-contamination;
production equipment is eectively cleaned and regularly
maintained;
personnel control programs are in place, e.g.:
— access is restricted only to authorized personnel; — authorized personnel wear appropriate gowns and PPE;
starting materials of correct identity, quantity and quality are
used for production; and
147
Mixing (blending) process
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Manufacture and Supply, Science and Reg ulation Towards High-Qua lity Medicinal Products
process controls are in place, e.g.: — critical processes are validated (and re-validated periodically) — in-process QC programs are in place, and — comprehensive batch production records are kept.
The production areas are covered under the PIC/S Guide to GMP for Medicinal Products Chapter 5. The items covered during the inspec­tion of the production areas include the:
Production Rooms — Design and construction — Partition, segregation, air-handling and containment
measures
— Connecting pipe work are made of stainless steel and drain-
age has no backflow
— Change room is appropriately designed and fitted with air
shower
— Cleaning and maintenance are carried out regularly with
proper records kept
— Environmental and microbiological monitoring programs
Production Equipment — Design and construction — Cleaning, maintenance, calibration and usage records — Status labeling of equipment
Production Process Control — Labeling and control of weighed materials — Gowning of production personnel — Batch production records — Process deviation and investigation — Process validation, revalidation and change controls
Compliance of Pharmaceutical Manufacturers to Good Manufacturing Practice Standards
149
Granule drying process
Tablet compression
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Manufacture and Supply, Science and Reg ulation Towards High-Qua lity Medicinal Products
Tablet coating
Personnel — Wearing appropriate PPE and avoiding jewelry and applica-
tion of cosmetic products
After inspecting the production areas, the inspector will proceed to audit the packaging process taking place at the packaging room.
5.3.4. Why are the Packaging Areas Inspected?
The objective of inspecting the packaging areas is to assess that:
— there is proper design, construction, maintenance, cleaning and
environmental monitoring of the packaging rooms to prevent cross-contamination and mix-ups;
Compliance of Pharmaceutical Manufacturers to Good Manufacturing Practice Standards
— there is also regular maintenance, cleaning and status labeling
of the packaging equipment to prevent cross-contamination and mix-ups;
— the packaging process is validated, and line clearances are per-
formed and batch packaging records are kept; and
— there is eective control of labels to prevent mix-ups and appro-
priate temperature and relative humidity control to maintain quality of packaged products.
151
Packaging process
The items covered during the audit of the packaging areas include the:
Packaging Rooms — Design and construction — Cleaning, maintenance and calibration of weighing and
monitoring equipment
— Environmental and microbiological monitoring
Packaging Equipment — Cleaning, maintenance, calibration and usage records — Status labeling of equipment