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Manufacture and Supply, Science and Reg ulation Towards High-Qua lity Medicinal Products
APIs, excipients and container-closure system, the control strategies as illustrated in the diagram below include:
QC testing of APIs and other starting materials, as well as fin-
ished products by the manufacturer for impurities that are spe­cific in nature, and which are known to the manufacturer;
GMP compliance by the manufacturer;
Assessments of impurity profile by product reviewers of the
medicines regulatory authority (e.g., Singapore HSA, Australia TGA, US FDA, UK MHRA), and the rejection of starting materi­als and finished products with unacceptable levels of impurities before pre-market approval; and
Periodic GMP audits by inspectors from the medicines regula-
tory authority.
Control of intrinsic contaminants (impurities)
6.3.4. Control of Extrinsic Contaminants
On the other hand, extrinsic contaminants are non-specific in nature and may come from the manufacturing personnel, production
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equipment, packaging equipment and premises. From the person­nel, the extrinsic contaminants include bacteria, fungi, particles, fibers, hair, dirt, saliva, perspiration and body fluids. From the equip­ment, extrinsic contaminants may include rust, corroded materials, product residues, grease, lubricants and leached chemicals. From the manufacturing premises, extrinsic contaminants may potentially include flies, rats, cockroaches, other pests and rodents, and their body parts, feces and droppings, as well as cross-contaminants from adjacent or adjoining production premises, in addition to pollutants from the external environment, outside of the manufacturing com­pany. As extrinsic contaminants are non-specific in nature and often unknown, they cannot be picked up via QC testing. Hence, extrinsic contaminants have to be controlled and regulated through GMP compliance and various cross-contamination measures undertaken by the pharmaceutical manufacturer, as illustrated in the diagram below.
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Control of extrinsic contaminants (non-specific)
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Manufacture and Supply, Science and Reg ulation Towards High-Qua lity Medicinal Products
Some of these measures include sampling of starting materials for QC testing within a designated sampling room or under controlled environment with eective partitioning to prevent cross-contamina­tion. The sampling room in the warehouse has to be a closed sys­tem with positive air pressurization. Sampling of starting materials should also be performed by trained personnel who are properly gowned with observation of good personal hygiene. Clean stainless steel sampling tools are also needed to collect the samples. In addi­tion to the sampling of starting materials for QC testing or evalua­tion, all manufacturers of medicinal products must have an eective contamination control program. A proper contamination control strategy must be undertaken by all pharmaceutical manufacturers to keep out contaminants, cross-contaminants and extraneous mat­ters at all stages of manufacturing.
6.3.5. General Assessment of Cross-Contamination Risks
As a general assessment of the overall contamination risk of a man­ufacturing facility, a simple rule of thumb may be used by the GMP inspector. According to this rule, operations or activities within a given manufacturing facility is likely to increase risks for contamina­tion. For example, if only a single medicinal product or API is man­ufactured, the cross-contamination risk from another drug product or API is virtually absent, and risk is at its lowest. Current GMP reg­ulations require manufacturers of APIs which are highly sensitizing, such as penicillin and cephalosporin, to be manufactured in dedicated and self-contained facilities or buildings. Although the manufacture of hormones, steroids and other materials that are highly potent is allowed to be carried out in dedicated and self-contained areas or rooms within the same facility, it can still pose an intermediate
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level of cross-contamination risk. On the other extreme, there are generic drug manufacturers which produce multiple products in non-dedicated facilities, using multi-purpose production equipment, and often lacking a robust cross-contamination program. This group poses the greatest risk for cross-contamination.
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General assessment of contamination risk
Thus, it is prudent for GMP inspectors to pay most attention to generic drug manufacturing facilities producing large numbers of medicinal products using multi-purpose equipment. Such “over­crowded” pharmaceutical manufacturing facilities pose the great­est cross-contamination risks in the same way that over-crowded workers’ dormitories have resulted in very high transmission of the coronavirus during the COVID-19 pandemic in some countries.
Today, human resource managers, public health regulators, build­ing construction companies and government authorities have real­ized the need for proper dormitory design, eective segregation
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Manufacture and Supply, Science and Reg ulation Towards High-Qua lity Medicinal Products
Overcrowded workers’ dormitory
and ventilation to avoid or reduce the transmission and cross-trans­mission of viruses and other pathogenic microorganisms. The subject of purity and contamination control in the manufacture of medicinal products is further elaborated under Chapters 15 and 16 on Active Pharmaceutical Ingredients and Pharmaceutical Excipients respectively, Chapter 21 on Looks are Deceiving, and Chapter 22 on Nitrosamine Saga and Control of Impurities.

6.4. Stability and Shelf-Life Testing of a Medicinal Product

The stability of a medicinal product is determined through a sta­bility testing program. The factors influencing the stability of a
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medicinal product may be categorized into product-related fac­tors and environmental factors. Product-related factors include the formulation of the product, the physico-chemical properties of drug substance(s) as well as the primary containers and packaging materials used. On the other hand, environmental factors include temperature, moisture, relative humidity, light, oxygen, physical stress during transportation as well as potential in-use contamina­tion during consumption. Therefore, the stability testing program takes into consideration both product-related and environmental factors. The program includes real-time studies under appropriate controlled storage conditions, which are dependent on the intended market(s), as well as accelerated studies under stressed conditions, to estimate the shelf-life of the product. Stability testing studies are conducted with a view to establish the shelf-life of product when stored, distributed and used under recommended temperature, rel­ative humidity and other environmental conditions.
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6.4.1. Why is Proper Storage, Distribution and Handling of a Medicinal Product Important?
Elevated temperature during storage of a medicinal product can result in loss of potency (through degradation) and hence loss in ecacy, putting the life of the patient at stake. This is especially critical if the product has an API with a low therapeutic index, that is, the dierence between the eective concentration and toxic con­centration of the API is small. Such an API has a narrow safety mar­gin or band. Elevated temperature during storage can also result in loss of vehicle or solvent through evaporation, leading to increase in concentration of the API with potential for overdosage. Moreover, elevated temperature during storage can cause hardening of tablets
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Manufacture and Supply, Science and Reg ulation Towards High-Qua lity Medicinal Products
through loss of moisture content, leading to change in dissolution profile, alteration in bioavailability and associated change in rate and extent of systemic absorption, and ultimately a loss in ecacy and therapeutic failure of the product.
Elevated relative humidity or moisture content during storage can result in the formation of toxic degradation products through hydrolysis. For example, acetic acid can arise from the degradation of aspirin containing acetyl salicylic acid; epi-anhydrotetracycline from tetracycline, with potential to cause kidney damage; and penicillanic acid from beta-lactam antibiotics, with potential to cause anaphylaxis or anaphylactic shock. Elevated relative humidity or moisture content can also bring about a loss of package integ­rity and label clarity with resultant obliteration of essential label information. In the case of a transdermal patch, elevated relative humidity or moisture content can also result in a loss of adhesion of the patch to the skin and thus in non-delivery of the transdermal medication.
During transportation of a consignment of a medicinal product to its final destination, there may be increased agitation and vibration during the journey by air, sea or road. Increased agitation and vibra­tion may lead to ingress of micro-organisms into the product. The ingress may arise from poor container-closure integrity or hairline cracks, resulting in a drop in microbiological quality of the product and thus an unsafe, harmful product if it is intended to be sterile. Moreover, poor handling of a product such as eye drops or eye oint­ment during in-use can bring about inadvertent contamination of product with potential to cause eye infections and even blindness.
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The stability of a medicinal product and its impact on shelf-life and expiry date is further elaborated under Chapter 7 on Stability and Shelf-Life Testing of Medicinal Products.
6.5. Homogeneity of a Medicinal Product and
Process Validation Study
The homogeneity or consistency of a medicinal product is the extent of how uniform the active ingredients are dispersed throughout each individual dosage form or unit of the product. Homogeneity may be demonstrated through a process validation study.
Whether it is US FDA, UK MHRA, Australia TGA, PIC/S or WHO, process validation is defined as the means of ensuring and providing documentary evidence that the manufacturing processes are capa­ble of consistently producing a finished product of required quality. There are several major steps involved in a process validation study. Using the tablet dosage form as an example, the first step in a pro­cess validation study is to identify the critical quality attributes. For a tablet, the critical quality attributes include the blend homoge­neity, hardness, thickness, friability, particle size of the drug sub­stance and dissolution profile. Then, the critical process parameters, namely blending, milling and tablet compression, are identified, and this is followed by the design of the sampling plan. For blend­ing, 10 samples are taken from the top, middle and bottom of the blender. For milling, one representative sample (about 100 g) may be drawn from the mill; and for tablet compression, six samples of
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Manufacture and Supply, Science and Reg ulation Towards High-Qua lity Medicinal Products
20 tablets each may be collected at four equal time intervals from the tablet compression machines, covering three compression speeds (low, target and high speeds). You can see that pharmaceu­tical process validation is about extensive testing under worst-case scenarios. After the design of the sampling plan, the testing plan is developed. For blend uniformity, the content of blended samples is assayed, and for the compressed tablets, tests for hardness, friability, thickness, potency and dissolution profile are carried out. Then the acceptance criteria are set; typically, they are set at within 90% to 110% of the labeled amounts of the API content. Finally, statistical analysis (both intra-batch and inter-batch) are performed on three consecutive full-scale batches of the product. For intra-batch analy­sis, process capability studies are carried out and the process capa­bility indices are measured. For inter-batch analysis (of the three consecutive production batches), an analysis of variance is carried out. The objective of intra-batch analysis is to demonstrate the con­sistency of all the three validation batches. Intra-batch analysis is performed on blend content uniformity test results. The objective of inter-batch analysis is to demonstrate the equivalency amongst the three validation batches and the pilot batch (used for clinical trial and stability studies). Inter-batch analysis is performed on the dissolution test results.
In process validation study, there is a Rule of Three to explain why a conventional process validation study is often performed on three consecutive batches. The explanation or rationale is as follows:
One Successful Run – It’s a Fluke
Two Successful Runs – It’s a Coincidence
Three Successful Runs – It’s Scientific!
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Another perspective for the Rule of Three is:
One Successful Batch – It’s an Accident
Two Successful Batches – It’s Luck
Three Successful Batches – There Is Linearity and Correlation!
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There is now a newer approach to process validation. As described earlier, the conventional or traditional approach to process valida­tion applies the Rule of Three, that is, it must be demonstrated that three full-scale and consecutive production batches must have been validated during the study. Re-validation is conducted only when there are significant changes to critical quality attributes and crit­ical process parameters. With the new approach, also referred to as continuous process verification, there is extensive process design and process qualification, monitoring of critical process param­eters such as mixing time, duration of drying, temperature, and