Best dating europe manufacturing

best dating europe manufacturing

What are the 5 best dating sites in europe ? 1. 2. 3. Post Comment. #1. Aug 11, 2011 3:57 am cst what are the 5 best dating sites in europe ?. Aug 12, 2011 3:25 pm cst what are the 5 best dating sites in europe ? heinzketchupFort Mill, South Carolina USA11 Threads 1 Polls 2,277 Posts. heinzketchupFort Mill, South Carolina USA2,277 posts. Tulefel: You don’t have my photo. But why to bother with someone else’s photo? Upload your own instead! Or you’ve got doubts about your attractiveness?

best dating europe manufacturing

Eastern European dating aficionados are at an all-time high this time of the year. To help you ring in 2019 with a kiss (and more) from an Eastern European cutie, we are bringing you the complete and updated list of dating platforms to try.

No lies, though, most of them you have already heard of. Or maybe not, if you are new to this whole thing. My point is, the best Eastern European dating sites are the ones that already have years of experience behind their backs. They are the safest, they have the most members, and ultimately, they are the ones where your chances are the highest!

– Did You Say Eastern Europe? I know, I know, International Cupid is hardly a niche dating site. We will get to them later (and trust me, they do have a bunch of perks). But here is why International Cupid is worth your time and membership fee: Variety, Variety, Variety! From my experience, men who date foreign girls are not too picky about where they come from. Sure, you might have a thing for Eastern Europeans but would you really turn down an olive-skinned Greek lady with huge eyes and sensual curves?

Even if she is not Slavic, I bet she does check a lot of your wifey requirement boxes: • Gorgeous? Check! • Family-oriented? Check! • Smart? Check! • Will take care of me? Triple check! I would go as far as saying that International Cupid is the best place for a newbie to start his Eastern European wife hunt.

They are a Cupid Media website, meaning that they have the same profile quality standards and smart, multiple layer anti-scam policy.

International Cupid also comes with the huge perk of giving you tons of background verified, relationship-minded girls. They are the perfect way to ease into the international dating scene. Plus, most of their members are Eastern European girls so you will still be dating in your niche with the option to look outside as well (without any extra fees or the need to fill out a new profile on a different site).

Tinder – Everyone Wants To Hookup I bet I could write a full PhD thesis on the complexity of Tinder users in Eastern Europe. You see, women here are not super comfortable with their sexuality like they are in the West. And don’t get me wrong, most of the time that is a good thing. Take Alina for example. She is a good friend of mine (or was a couple of years ago, I haven’t seen her too much recently and this article should be my cue to reconnect).

I know her from high school, a.k.a. from that awkward time we were all confused virgins but pretended to be super sexually forward. Anyhow, as is with most Eastern European girls, Alina did not want to hook up with a random guy, at least not for her first time.

It had to be special. She was dating a dude from school for a couple of months but that never led anywhere and then she had a super long single period.

Around two years into that Tinder rolled around. And she joined. This is already a desperate move. Don’t take it from me, take it from Alina herself whom I have never heard speaking about Tinder. In fact, I learned that she had it when I came across her profile. She had not swiped right on me. Either way, Alina did meet a cute guy on Tinder, he was a couple of years older, definitely not as hot as she was but I guess you don’t want to be a 20-year-old virgin (although, thinking back, that is not even that old… But we were all young and dumb at this point).

Long story short, they did the dirty and broke up shortly after. Not the cutest first-time story but whose is? Just a little disclaimer here, you might be wondering why I know so much about Alina. No, I did not have a secret crush on her. She just happens to be one of my sisters best friends plus we all went to high school together and were kind of in the same friend group. You know how gossip goes when you are a teenager… What Alina’s Story Should Teach You About Eastern European Dating have two major fears: • Being single.

• Appearing desperate. You can see how that is contradicting, right? I bet there is some psychological explanation to that, involving the superego and what not. Either way, the bottom line is you could use that to your advantage. If a woman is on Tinder, she is already settling (in her mind).

You would have to compensate that with interest. No, Eastern European girls don’t text first on Tinder or if they do they are probably really not cute. Remember, every sign of interest is a sign of desperation in her mind.

To ease her slightly damaged ego, work extra hard at romancing her. It will pay off sooner than you think and it is the best strategy for scoring girls way out of your league. And that is not just valid for Tinder… – Did You Say You Love Natashas? Russian Cupid is a Cupid Media site dedicated to connecting Russian singles (a.k.a. marriage-oriented single ladies) to Western men. It is the age-old story of girl meets exciting foreign man.

Women on Russian Date are hot. They are the epitome of Slavic beauty – long, silky-soft hair, huge eyes, sensual curves, always dressed to the 9’s.

Unlike other Eastern European dating sites, this one is almost scam-proof. But why choose Russian date (or Ukraine Date, which is our last pick for this article), over websites with a broader selection?

It’s a tough call. Niche dating and ‘broad spectrum dating’ both have their perks. What Makes Russian Cupid And Better Obviously, you have the safety and the no hidden costs perks. These hold true for Russian Date and Ukraine Date just as they do for International Cupid. After all, they belong to the same company.

But when it comes to niche dating, there are a couple of extra pros that you want to consider. First off, you do have a more limited selection but that could be a blessing in disguise. If you have your perfect type of girl crystal clear in your head, why waste time on women who don’t fit it.

Well, you never know, some might argue. And yes, if you have the slightest doubt about your type I would recommend going to a more broad spectrum Eastern European dating site. But if Russian or Ukrainian girls are what really light your fire, why waste time with other Eastern Europeans that maybe don’t share the same characteristics. Greece is Eastern Europe but they are not Slavic. If blond hair and blue eyes is your type, why not go to a site dedicated to that sort of girl?

Niche Dating And Likelihood Of Meeting Your Future Wife There are all sorts of Eastern European girls but the ones on dating sites have one thing in common: They are anxious to get into a relationship ASAP. Having a handsome foreign boyfriend (or fiancé, or husband) means huge bragging rights. and are particularly into that. Other places in Eastern Europe might be just as rich in hot women but standards are changing quick.

For instance, Romanian women are now much less likely to get married before getting their education and a head start on a career. Focusing on Eastern European dating might not be enough to meet marriage-minded women anymore. Russians and Ukrainians are still some of the most relationship-focused girls out there. I am not saying that is everyone’s cup of tea.

A smart, career-oriented girl can be nice. But if a future trophy wife is what you are after, it might be worth narrowing the Eastern European nations down a little bit. How To Make The Most Of Eastern European Dating In 2018? It all boils down to the cliché advice of being yourself. But really, Eastern European dating is a lot easier than dating in the West. There are less games and women take you for what you are. Maybe it is because you are a foreigner (in other words, successful and a ticket to a better life)—but I doubt it.

More likely, women in Eastern Europe have grown up with a different idea of what they should expect from a future partner. Stability and support are on the top of that list, not constant entertainment or being Chris Hemsworth-level buff. Whether you go to International Cupid, Russian Cupid or Ukraine Date to meet your future Eastern European girlfriend, remember to stay true to yourself and to embrace the process.

Best of luck and I am waiting for those field reports in the comments down below.


best dating europe manufacturing

best dating europe manufacturing - Dating in Europe


best dating europe manufacturing

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best dating europe manufacturing

This content applies to human and veterinary medicines. The European Medicines Agency's (EMA) provides answers to frequently asked questions on (GMP) and (GDP), as discussed and agreed by the .

The guidance provided by the working group in the form of questions and answers (Q&As) provides additional interpretation of the and published by the European Commission. The working group prepares these Q&As as the need arises. EMA may remove individual Q&As when the European Commission updates relevant . Code • H: applicable to human medicines • V: applicable to veterinary medicines The product review is expected annually.

Review timeframes can be appropriately adjusted based upon manufacturing and campaign duration with adequate justification. The timeframe criteria should be established in a SOP. The trending can include results gathered from the previous period to ensure its robustness. Even if no manufacturing has occurred in the review period, the quality and regulatory review should be conducted as per section 1.10 and include stability results, returns, complaints, recalls, deviations (including those arising from qualification and validation activities) and regulatory background.

The review of the last PQR should also be conducted. Metal could originate from raw materials as well as from equipment in manufacturing processes where metal parts could generate fragments due to the conditions of operation or damage to the equipment. It is recommended that metal detection is used for processes prone to this. In order to avoid routine use of metal detectors the company must demonstrate that it has identified and managed the risks such that the use of metal detectors for that particular process is not needed.

EU GMP guide part I: Basic requirements for medicinal products: Chapter 3: Shared manufacturing facilities 1. Implementation of risk based prevention of cross contamination in production and 'Guideline on setting health based exposure limits for use in risk identification in the manufacture of different medicinal products in shared facilities' H+V April 2... The document 'guidance on the occasions when it is appropriate for competent authorities to conduct inspections at the premises of manufacturers of used as starting materials', published as part of the , states that it is expected that manufacturing-authorisation holders will gain assurance that the they use are manufactured in accordance with GMP through audit of the active-substance suppliers.

Small manufacturers may not have the necessary expertise or resource to conduct their own audits. Section 5.25 of the requires starting materials to be purchased from approved suppliers and about whom the manufacturer has a particular and thorough knowledge. An audit conducted by the manufacturing-authorisation holder itself should be integral to the manufacturer's quality-assurance system and subject to the basic GMP requirements, i.e.

conducted by properly qualified and trained staff, in accordance with approved procedures. It should be properly documented. These aspects can be inspected as necessary by the competent authorities. If a third party is involved, the arrangements should be subject to chapter 7 of the . There should be evidence that the contract-giver has evaluated the contract-acceptor with respect to the aspects described above. All parties involved should be aware that audit reports and other documentation relating to the audit will be made available for inspection by the competent authorities if requested.

This should normally provide sufficient assurance that the results of an audit carried by the third party are credible, thus waiving the need for an audit conducted by the manufacturing-authorisation holder itself. However, it must also be satisfactorily demonstrated that there are no conflicts of interests. Conflicts of interests could arise for example from: • a commercial relationship between the organisation performing the audit and the organisation being audited; • a personal conflict on the part of the auditor where he / she has been employed by the organisation being audited in the recent past (i.e.

within the last three years) or has a financial interest in it. This topic should also be addressed in the technical contractual arrangements. Any measures taken by the contract-giver should be documented, e.g.

signed undertakings by the auditors. Similarly, the principles outlined above could be used to allow sharing of audit reports between different manufacturing-authorisation holders using the same supplier, provided that the scope of the audits can be shown to be applicable to the of mutual interest. 2. Is it possible to use multiple batch numbers in packaging of medicinal products? H+V January 2005 GMP inspectors have discussed the desirability of more than one batch number appearing on the packaging of .

It is normal practice for companies to use a bulk batch number that is different from the finished product batch when the bulk is packaged as several sub-batches. There is normally an element in the numbering format common to the bulk batch and finished product batches that clearly ties these together. The difference normally takes the form of a suffix, prefix or both. A matter of concern for the inspectors is when the bulk and finished product batch numbers are completely different and there is no obvious connection between the two.

Even though the manufacturer has a system of traceability, the inspectors agree that this is an undesirable practice and should be avoided. The main reasons for this are: • patients and healthcare professionals may mistakenly believe that there has been a packaging error; • hospitals often remove products from the outer packaging and traceability may therefore be lost; • confusion may occur in the case of recall, rendering such action potentially ineffective.

It is accepted that there may be exceptional cases where multiple batch numbers are displayed on a pack, such as in combination product packages. In addition, products that require relabelling following are expected to display the original manufacturer's batch number. Manufacturers are recommended to discuss individual cases with the relevant supervisory authority. In all cases, traceability must be maintained. 3. What are the expectations with regard to documentation and verification of the supply chain for active substances (ref.

Paragraph 5.29, Chapter 5 EU GMP Guide)? H+V August 2015 The supply chain for each must be established back to the manufacture of the starting materials. This should be documented and must be kept current. The risks associated with this supply chain should be formally documented.

Control of each incoming consignment of should include verification that it has been received from the approved supplier and approved manufacturer. The entire supply chain should be verified for a supplied batch periodically to establish a documented trail for the batch back to the manufacturer(s) of the starting materials. The frequency of this verification should be based on risk.

4. Is it acceptable to pack (primary and/or secondary packaging) multiple batches of the same product (e.g. tablets, capsules, lozenges) in order to obtain a single batch as a "super batch"? H+V July 2018 Normally, such an approach should be avoided as each batch is made from the same initial quantity of material and should remain as an individual batch of finished bearing a unique batch number. Therefore, any other approach should be thoroughly justified by applying the principles of Quality Risk Management (QRM) taking into account at least the following criteria: • length of time the equipment has been in use; • of the drug product that cannot be homogenised (tablet, capsules, etc); • expiry date of the drug products; • ongoing stability study design and results; • reference samples plan for each batch; • criticality of the drug product and the risk of shortage that may arise from any quality issue; • prior approval of the MAH.

Irrespective of the outcome of the QRM, such an approach can only be accepted if each individual batch of the combined "super batch" undergoes all the in-process control and finished drug product testing as specified in the dossier. In the event of a recall, the entire “super batch” should be recalled. Suspected product quality defects (e.g. product deterioration, packaging mix-up, among others) should be reported to the with responsibility for the manufacturing site (or importer where the manufacturer is located outside the EEA), and to the in each EEA market supplied.

In case of impact to EU , the EMA must also be notified. This notification should be prior to taking any market action, unless, as per paragraph 8.26 of Chapter 8, the need for market action is so serious as to warrant immediate action to protect patient or animal health. Confirmation of a quality defect does not require completion of the investigation. Reporting should be initiated when available information supports the detection of the issue and when the initial assessment of the potential risks presented to patients/animals indicates that it could result in market action.

Notification to competent authorities should typically take place within one working day of confirmation that reporting is required. In cases where a suspected quality defect involves multiple manufacturing sites, reporting responsibilities should be defined in a technical agreement.

It is normal expectation that the MAH and site of final EU batch certification should take the lead on reporting, unless otherwise justified. Manufacturers are encouraged to notify their (or EU Supervisory Authority for sites located outside the EEA) of confirmed serious GMP issues with the potential to lead to a suspected product defect requiring market action (e.g. media fill failure, serious equipment failure, etc.). Confirmation of a serious GMP issue does not require completion of the investigation; reporting should be initiated when available information confirms the detection of the issue.

Serious GMP issues which may result in an abnormal restriction in supply should be notified to the MAH and relevant competent authorities in accordance with legal obligations given in Art 23(2) of Directive 2001/83/EC, Art 27 of Directive 2001/82/EC, Regulation 726/2004 and EMA guidance 1: In the event that a which is the subject of a issued by an EEA authority, and which is marketed in another (or countries) then the shall forthwith inform the relevant EU of any prohibition or restriction imposed by the competent authorities of any country in which the is marketed and of any other new information which might influence the evaluation of the benefits and risks of the concerned (e.g recalls or serious GMP issues).

This is even if the particular batch subject to the prohibition or restriction is not marketed in the EEA. In cases where national competent authorities set additional national expectations regarding what quality defects should be reported and the timelines for reporting, these should be complied with.

1 2. For the purposes of product recall, at what stage in the supply chain is a product considered to be 'placed on the market' (ref: Chapter 8 paragraph 8.21)? A batch recall is defined in the Compilation of Community Procedures as "The action of withdrawing a batch from the distribution chain and users.

A batch recall may be partial, in that the batch is only withdrawn from selected distributors or users". This definition covers the entire distribution chain from all points following manufacture through to the end user, the patient. Also, it is possible that the MAH or its subsidiaries are actors in the supply chain, acting as the distributor in certain cases.

In such cases, the MAH or its subsidiaries should be regarded as also being part of the distribution chain. A batch of is considered to have been 'placed on the market' when one of the following takes place: • A batch has been Qualified Person (QP) certified and has been made available for sale on the stock management system of the pre-wholesaler/primary wholesaler, etc. • A batch has been QP certified and supplied to a facility where the manufacturer has no further control over when the product is transferred to saleable stock.

This applies even if within the pre-wholesaler/primary wholesaler network. • In the case of supply chain models where the manufacturer or primary wholesaler supplies direct to the customer (e.g. pharmacy), the batch has been placed on the market from the time of the first customer supply of product from the batch. National competent authorities should be notified of all recall action proposed after the product has been placed on the market.

In situations where the MAH can demonstrate that the batch is reconciled without issuing a recall notice, the may agree that public recall communication throughout the distribution network is not necessary. It is acknowledged that certain short expiry products (e.g. radiopharmaceuticals, , etc.) may be shipped under quarantine prior to certification. Retrieval of batches during this quarantine period may be managed within the pharmaceutical quality system. ( for veterinary ) states that manufacturing-authorisation holders are obliged to use, as starting materials, only that have been manufactured in accordance with the detailed on GMP for starting materials.

Thus the legislation puts the responsibility on the manufacturing-authorisation holders using the and does not foresee mandatory routine inspections of active-substance manufacturers. To provide guidance on how GMP compliance of active-substance manufacturers should be established, guidance documents have been published on this website, including the 'guidance on the occasions when it is appropriate for competent authorities to conduct inspections at the premises of manufacturers of used as starting materials' as part of the .

This document states that it is expected that manufacturing-authorisation holders will normally gain assurance that the it uses are manufactured in accordance with GMP through audit of the active-substance suppliers. In addition, a number of questions and answers on audits of active-substance manufacturers on this page provide further guidance.

2. Do I need to perform an audit of an active substance supplier if it has been inspected by an inspectorate from a European Economic Area (EEA) Member State and a valid GMP certificate is available? H+V July 2006 Manufacturing-authorisation holders sometimes confuse the role of inspectorates with their own obligations but nevertheless, when inspection reports or GMP certificates issued by European Economic Area (EEA) mutual-recognition-agreement (MRA) partners or other recognised authorities are available, these can provide useful information to manufacturing-authorisation holders.

However, these alone cannot fulfil the statutory obligations of the manufacturing-authorisation holder or the requirements of section 5.29 of the , but the results of inspections may be used together with other supporting information in a risk-based approach by the manufacturer in establishing priorities for its own audit programme of active-substance suppliers.

3. Is it acceptable to perform a remote assessment based on, for example, questionnaires, review of documents, Internation Organization for Standardization 9000 certification, results of analytical testing and historical experience with the supplier?... The EEA inspectorates are not generally in favour of 'paper-based audits' per se as they do not provide the same level of assurance as on-site assessments, but do accept that they have a part to play in a risk-based strategy.

They may be particularly applicable when recent positive inspection information is available and where satisfactory audits have been concluded in the past. They cannot replace on-site audits of active-substance suppliers but can be a useful interim and temporary measure within the manufacturer's audit programme. 4. How do the new requirements affect importers of medicinal products?

H+V July 2006 Importers are manufacturing-authorisation holders and so the obligations under Article 46f/50f of apply to them. For importers, the possibility of a second-party audit performed by the third-country manufacturer that uses the as a starting material may be a further option.

Importers are already obliged to ensure that the third-country manufacturer complies with standards of GMP equivalent to those of the European Community and should have established arrangements in line with chapter 7 of the . They should therefore be fully satisfied that the third-country manufacturer has adequately demonstrated that the it uses for products destined for the European Community have been manufactured in accordance with GMP.

Importers may of course choose to verify the standards of GMP at the active-substance suppliers themselves or through a third party. Whichever option is chosen, the questions and answers above are also relevant. 5. Is it possible to ask for a voluntary inspection of an active substance manufacturer? H+V February 2015 First, the responsibility for only using that have been manufactured in accordance with GMPs is placed on the holders of a manufacturing authorisation (MA). An inspection of the manufacturer by an EEA authority does not liberate a MA holder from this responsibility.

Article 111 (1f) of and Article 80(1) of , have provision for the of the Member State concerned to carry out inspections of starting material manufacturers at the specific request of the manufacturer. The request for the inspection should be made to the EEA where the site is located or, in case of sites located in third countries, to a where the starting material is used in the manufacture of . If this is not the case, any EEA authority can be approached.

There is no guarantee that such a request will be fulfilled since competent authorities primarily use risk-based principles to plan starting material inspections. Thus, when a starting material manufacturer applies for a voluntary inspection, this does not constitute an obligation for the to trigger an inspection.

6. The notice to applicants requires the submission of a declaration signed by the qualified person (QP) that the active substance used is manufactured in accordance with GMP.

The active substance in my product is widely used, but not normally as a p... Full compliance with GMP for finished products and is a legal obligation for manufacturing-authorisation holders.

It is recognised that for a small number of , the primary use of the is not in a and the producer may therefore not be aiming to meet the specific requirements of pharmaceutical customers that represent an insignificant volume of business. Alternative sources should normally be sought, but in exceptional cases the manufacturing-authorisation holder should assess and document to which extent GMP is complied with and provide a risk-based justification for the acceptance of any derogation.

The declaration provided by the QP should set out in detail the basis for declaring that the standards applied provide the same level of assurance as GMP. The European Medicines Agency will collect experience with this approach, which can be used as a basis for discussion on related amendments to in the future. 7. What kind of GMP documentation is needed for an active-substance manufacturer that performs sterilisation of an active substance?

July 2010 The GMP basic requirements for used as starting materials (EU part II) only applies to the manufacture of sterile up to the point immediately prior to the being rendered sterile. The sterilisation and aseptic processing of sterile are not covered by this and should be performed in accordance with GMP for (Commission Directive 2003/94/EC as interpreted in the basic requirements for including annex 1 of the EU part I).

This implies that for any active-substance manufacturer that performs sterilisation and subsequent aseptic handling of the , a valid manufacturing authorisation or GMP certificate from an EEA authority or from an authority of countries where MRA or other Community arrangements apply has to be submitted.

The active-substance manufacturer also has to submit data on the sterilisation process of the (including validation data) to the marketing-authorisation applicant or holder for inclusion in the dossier submitted for the finished product and approval by the licensing authorities.

8. During inspections, why do inspectors sometimes ask to see reports of audits of active substance manufacturers carried out by the medicinal product manufacturer? H+V May 2013 Inspectors may need to see audit reports during inspections as part of the assessment of the manufacturing-authorisation holder's systems for confirming GMP compliance of manufacturers or suppliers. Inspectors will expect to see the full details of these reports upon request, including responses received from the audited site, of closure of deficiencies raised or commitments made.

9. What expectations do inspectors have for the content of reports of audits of active substance manufacturers carried out by the medicinal-product manufacturer? H+V May 2013 As a minimum, the following is expected to be included in the report: • The full postal address of the site.

The auditors must be identified by full name and their employer recorded. If the audit is conducted on behalf of other parties this should be clear in the report. Where an audit report is obtained through a third party, the manufacturing-authorisation holder is responsible for ensuring the validity and impartiality of the audit report. The identity of key staff participating in the audit should be recorded along with their roles.The full contact details of the person through which the audit was arranged should be recorded including contact details (e-mail address, telephone number).

The dates of the audit should be recorded, with the full-day equivalents clarified if full days were not spent on site.

A justification should be recorded for the duration of the audit. If, in , the audit had to be restricted to fewer days on site than required by the scope of the audit, the reasons should be explained and the conclusions with respect to the GMP status of the site should be justified.ackground information on the manufacturer should be recorded; this should include the company ownership, the age of the site, the number of staff employed in total and for the specific products being audited.

The role of the site in manufacture of the being audited should also be clarified for each of the being audited, e.g. if the site performs the full manufacture or only part of the manufacture.

• The scope of the audit should be clearly stated e.g. what activities (against European Union GMP part II / International Conference on Harmonisation of Technical Requirements for Registration of Pharmaceuticals for Human Use () Q7 chapters) were covered. The activities which were not covered by the audit should also be clearly recorded. Auditors should identify the high risk areas for audit specific to the site or products being audited.

For example, these could include but not be limited to: • process, cleaning or validation; • risk of cross-contamination with other or other substances; • potential for generation of unknown impurities; • risk of mix-up of materials and products through materials handling or packing; • change control; • deviation recording or management; • security sealing of containers and security or temperature control of shipments.

• Subsequent audits conducted as part of the ongoing supplier audit program may have a reduced scope focusing on the highest risk areas. In such cases the highest risk areas should be identified and justified. • A list should be recorded of all directly included in the audit scope plus other or intermediates (or other products) manufactured at the site. There should be a clear record of the products, the stages of manufacture and the buildings audited.

If access was denied to any relevant areas of the site this should be recorded and explained. The list should clarify which of the in the scope of the audit are manufactured in multi-purpose equipment or buildings as either final product or any of the intermediate stages.

• Dates of any previous audit conducted by or on behalf of the same manufacturing-authorisation holder should be recorded. If any of the audits did not conclude with a positive GMP compliance status, a brief summary of the reasons for this should be recorded. • Each of the applicable sections of EU GMP part II should form sections of the report with a summary of what was examined, the key findings and compliance with the requirements of each section.

The report should clearly state findings against each activity audited with particular focus on the high risk areas. Any GMP deficiency identified during the audit must be clearly recorded with its criticality defined. An explanation should be given, in the report or in a supporting standard operating procedure, of the categorisation system used to classify deficiencies, e.g.

critical, major or minor. • Responses to the audit by the active-substance manufacturer should be reviewed by the auditors. Corrective and preventative actions and timescales for completion should be assessed by the auditors to establish whether these are appropriate to the findings. Further clarification or evidence of completion should be requested, commensurate to the risk. • A summary assessment of the status of corrective and preventive actions should be recorded by the auditors once these have been received and assessed.

An overall recommendation should be made in the final report. The summary should include whether the auditor regards the actions as satisfactory. The responsible QP should ensure that he or she, or someone to whom it is delegated, is in agreement with the overall recommendation of the final report. The QP must not release the relevant without knowledge of a positive recommendation from the auditors.

This recommendation should include the GMP compliance status of the site and whether any reduced controls on materials receipt at the finished product manufacturing site are supported by the auditors.

• A proposed re-assessment period should be recommended. • The final report should be signed and dated by, at least, the lead auditor. 10. How should active substance auditors be qualified? H + V May 2013 Auditors should have sufficient scientific, technical and other experience to enable them to perform an adequate and thorough audit of the manufacturer, as related to the planned scope of the audit.

Where a proposed auditor lacks an appropriate level of direct experience in the field of manufacture, he or she should undergo a documented training and assessment programme in the areas that are relevant to the audit, taking into account the auditor's anticipated role in the audit and the technologies that are likely to be encountered during the audit. Auditors must also be trained and assessed in their knowledge and understanding of EU GMP part II and in auditing techniques in general.

The training and assessment should be fully documented. The qualification and experience of contracted auditors are the same as the requirements for the manufacturing-authorisation holder's own auditors.

11. What is the frequency for the routine re-inspection of an active substance manufacturer? H+V February 2015 Article 111 (1b) of Directive 2001/83/EC requires that Member States have a system of supervision including inspections at an appropriate frequency based on risk, at the premises of the manufacturers, importers, or distributors of located on its territory. In line with the document “Model for Risk Based Planning for Inspections of Pharmaceutical Manufacturers” available in the Compilation of Union Procedures, sterile and biological are considered a relatively higher risk.

Consequently, competent authorities may decide to submit these substances to a higher or a set inspection frequency. 12. What are the GMP requirements to be applied to the formulation of biological active substances with excipients, when described in the active substance section of a registration dossier? H+V February 2017 The , address the exceptions where the formulation of an can be described under CTD section 3.2.S.

For the manufacture of biological , Part II and Annex 2 of the GMP apply. While quality risk management principles also apply to the formulation of a biological , some aspects of GMP part 1 as described below are more appropriate and are expected as a minimum: • Particular emphasis should be put on the management of the constitutive of the formulated . Specifications should be defined for according to GMP Part I., 4.14 and the monographs of the should be applied. The approval, maintenance and audit of suppliers should be based on quality risk management, in accordance with GMP Part I, 5.29 and the EU .

An agreement between the manufacturer and the manufacturer should be established in accordance with GMP Part I, 5.28. The sampling of used for the formulated should comply with GMP Annex 8 and retention samples of should be kept under the responsibility of the manufacturer (in accordance with GMP Part I., 1.9 (viii) and GMP Annex 19). used by the manufacturer of the formulated should be included in the Periodic Quality Review (in accordance with GMP Part I., 1.10 (i)). • Consideration should be given to the inclusion of batches of a finished manufactured from formulated , stored for the maximum holding time, in the ongoing stability program of the , in accordance with GMP Annex 2, 67 and GMP Part I., 6.28.

• When outsourced, the manufacture of a formulated should be managed in the same way as the outsourcing of the manufacture of an intermediate , through full application of the requirements of Chapter 7 of the GMP part I . Directives and , as amended, include obligations for manufacturing-authorisation holders only to use that have been manufactured in accordance with GMP.

Provision is also made for inspections of active-substance manufacturers but only under certain specified circumstances. IMPs are unaffected because the obligations of manufacturing-authorisation holders in this case are laid down in , which does not contain corresponding requirements for . Furthermore, this is made clear in the introduction to part II of the . Part II of the does include a short section on new to be used as starting materials for IMPs and these remain as recommendations with no mandatory force.

Nevertheless, used in the manufacture of marketed products are already required to comply with GMP irrespective as to whether they may also used in the manufacture of IMPs. Annex 1, paragraph 85 states, 'the integrity of the sterilised filter should be verified before use and should be confirmed immediately after use by an appropriate method such as a bubble-point, diffusive-flow or pressure-hold test.' The filter-sterilisation process may be physically stressful for the filter.

For example, high temperatures during the process may cause the filter to distort, potentially leading to fluid pathways that allow the passage of particles greater than 0.2 µm in size.

The performance of a filter can improve with use, as particles begin to block individual pathways and remove larger pathways that smaller particles could successfully navigate. For these reasons, filters should be tested both before use but after sterilisation and again after use.

Furthermore, testing should be performed in situ in order to verify the integrity of the filter complete with its housing. 2. What are the sampling requirements for sterility testing when a finished product batch of a terminally sterilised medicinal product is made up of more than one steriliser load?

H+V October 2008 The sampling plan for sterility testing should take account of the definition of a batch as stated in the glossary of the together with the recommendations of annex 1 section 93 (section 127 in the February 2008 revision). Each steriliser load is considered to be an independent sub-batch. Consequently, one sterility test should be performed per sub-batch. The number of samples per steriliser load should conform to requirements, section 2.6.1.3. Can there be any exceptions to this rule?

For large-volume parenterals where the sterilisation cycle has been qualified with an overkill level, an alternative sampling plan in accordance with a specific internal procedure agreed with the supervisory authority can be accepted (unless already specified in the ). This procedure should state the need to sample from each steriliser load including the coolest location identified during the steriliser qualification.

The number of samples per load should be defined based on a risk-based approach and the overall number of samples per batch should conform to requirements, section 2.6.1.3.

An alternative option, which would require a to relevant existing , would be to introduce a system of parametric release, thereby avoiding the need to carry out the sterility test. 3. What are the key changes in the 2008 revision of annex 1 of the EU GMP? H+V January 2010 The revision provides updated guidance on: • classification of the environmental cleanliness of clean rooms; • guidance on media simulations; • guidance on capping of vials; • bioburden monitoring prior to sterilisation.

4. The new revision to the annex includes a number of revised requirements. What steps are being taken by EU authorities to assure the consistent interpretation of the requirements of the revised annex by EU GMP inspectors during inspections? H+V Jan... GMP inspectors from the EU have worked together with inspectors from to prepare harmonised guidance on the interpretation of the revised annex to be used during the inspection of manufacturers by their Inspectors.

This document has subsequently been proposed and adopted as draft guidance by the (PIC/S): . 5. For an aseptically produced product, where should bioburden monitoring take place?

H+V May 2013 According to the EU (annex 1), the bioburden should be monitored before sterilisation and testing should be performed on each batch. For routine commercial manufacturing, bioburden testing should be performed on the bulk solution, immediately before its sterile filtration. If a presterilising filter is additionally installed, then sampling for bioburden testing may be performed prior to the prefiltration, provided that no holding time is scheduled for the solution between the two filtration steps.

6. What is the maximum acceptable bioburden level? H+V May 2013 The specification limits for bioburden should be NMT 10 CFU/100 ml, in line with the human and veterinary notes for guidance on manufacture of the finished dosage form ( and ).

When a prefilter is installed, unless otherwise justified, a bioburden limit of 10 CFUs/100 ml before first filtration is achievable in principle and is strongly recommended from a GMP point of view. Higher bioburden limits should not be justified by the high capacity of two consecutive bacteria retaining filters.

However, when appropriate justification is submitted (processes involving fermentation or other biological or herbal components, use of purified water for ophthalmic preparations, etc.), a bioburden limit of higher than 10 CFUs/100 ml before prefiltration may be acceptable. In such cases, it should be demonstrated that the first filter has the capability to achieve a bioburden prior to the last filtration of NMT 10 CFUs/100 ml, in line with the notes for guidance on manufacture of the finished dosage form (CPMP/QWP/486/95 and EMEA//126/95).

7. Do I need to follow the requirements of the updated ISO 14644 part 1 standard? Annex 1 of the EU GMP guide is currently under revision and will take account of the updated ISO standard. In the meantime, for qualification or re-qualification of clean room facilities, manufacturers may apply the updated ISO standard with reference to Annex C (counting of macroparticles), or may continue to follow the previous ISO standard. Routine monitoring, however, should continue to be carried out in accordance with the existing Annex 1.

8. Water for injection by reverse osmosis Traceability is the ability to retrieve the history of the manufacturing and distribution operations of a batch of a . The data recorded through the traceability system should allow efficient investigation in case an incident occurs and should allow recalls of (potentially) defective products.

In the case of packaged medicinal gases, the packaging components (shells and valves) are reusable. It is therefore necessary to record additional information, in particular in relation to the use and maintenance of these components. 2. Which items should be recorded in the case of medicinal gases filled into cylinders to enable traceability?

H+V July 2010 Packaging components (shells and valves) The cylinder is the combination of the shell and its valve.

Shell For safety reasons, shells are individually identified (specific reference). Individual traceability is therefore possible. The date of the last hydrostatic pressure test (or equivalent test) should be recorded. Valve Shells may be fitted with simple valves (e.g. pin-index valves) or integrated valves. Integrated valves are individually identified (individual identification reference). Individual traceability is therefore possible.

This is not the case for simple valves, which mostly have only a serial number corresponding to a group of valves. The design of integrated valves, which are medical devices, is complex. These valves are also subject to periodic preventive maintenance operations.

In terms of risk, more serious incidents have been reported with cylinders having this type of valve. Therefore: • in the case of simple valves, the type of valve should be recorded, as well as the name of the manufacturer and the serial number, if one is available; • in the case of integrated valves, traceability should be ensured for each valve. Records should include in particular the type of integrated valve (including the version), the individual identification reference of the valve, the name of the manufacturer, the date of the last (or next) preventive maintenance and details of any preventive maintenance performed on the valve.

Shell and valve Each shell-and-valve combination should be traceable. Finished product The manufacturing batch records should include the individual identification references of the cylinders of each batch of finished product (see EU annex 6, section 17, (g) and (m)).

Distribution The distribution records should include the individual identification references of the cylinders delivered to each customer. 3. What means should be implemented to ensure traceability? H+V July 2010 In practice, depending on the scale of operation, it may be difficult to ensure effective traceability without a computerised system. Use of bar codes or electronic chips on the cylinders may facilitate this. Any computerised system used to ensure traceability should conform to the requirements of annex 11 of the EU .

4. What should be possible through the system of traceability? H+V July 2010 Should a manufacturer of a medicinal gas receive a serious complaint relating to the quality of the medicinal gas itself or the packaging components, the system in place should allow the identification of the affected cylinders and, where necessary, the recall of any affected cylinders from the market.

A defect relating to packaging components may require identification of specific cylinders within a finished product batch or identification of cylinders present in a number of finished product batches in order to establish the extent of any recall required.

For example, an effective traceability system should allow effective recalls of cylinders fitted with defective valves based on: • specific type, version or manufacturer's batch for the valves; • maintenance and calibration operations for the valves during a specific time period.

There is a history of sporadic reports from around the world of supplies of glycerol contaminated with diethylene glycol (DEG) resulting in mortality and serious morbidity in patients receiving contaminated products. In late 2006, DEG-contaminated glycerol in cough syrup was the cause of about 50 deaths in Panama. DEG-contaminated glycerol in paracetamol syrup was also attributed to at least 80 deaths in a similar incident in Haiti in 1995-1996.

Other incidents have been reported in Argentina, Bangladesh, India and Nigeria and attributed to the deaths of hundreds of children. DEG was also responsible for a poisoning incident resulting in the death of 107 people in the United States in 1937, following ingestion of contaminated sulphanilamide elixir.

These incidents were related to both accidental cross-contamination of glycerol with industrial grade materials and, in some cases, to intentional substitution. Recent cases show the following similarities: • pharmaceutical manufacturers of products containing contaminated glycerol did not perform full identity testing or tests to determine DEG on the glycerol raw material; • pharmaceutical manufacturers of contaminated products relied on certificates of analysis (COAs) provided by the supplier; • the origin of glycerine was not apparent from the COA.

The COA provided with the glycerol raw material may have been a copy of the original on a distributor letterhead. The supply chain for glycerol was not readily known by the medicinal-product manufacturer because the glycerol may have been sold several times between its manufacture and the medicinal-product manufacturer. 2. How is the EU patient protected from similar contamination occurring in EU products? H+V December 2007 EU GMP requires all manufacturing companies to confirm that all its raw materials are checked on receipt to confirm their identity and quality.

Competent authorities expect product manufacturers to routinely ensure that incoming samples of glycerol are tested according to the monograph. The monograph for glycerol includes a specific limit test for diethylene glycol (0.1%). 3. Annex 8 of the GMP provides for derogations from the requirement for identity testing of every container where there is a validated supply chain.

Can I use this derogation for the glycerol I purchase? H+V December 2007 It is correct that annex 8 does provide for a relaxation of identity testing of every container, but it also states that this would not normally be possible if brokers or intermediates were involved in the chain of supply. Glycerol is a commercial article that is widely used in the food and other industries. Generally speaking, the supply chain for glycerol tends to be complex and lengthy. The involvement of brokers is common in the supply chain.

4. What steps are expected of manufacturers based in the EU when purchasing glycerol or of manufacturers based in third countries supplying glycerol-containing medicines? H+V December 2007 When designing supplier-assurance and incoming-goods-control programmes, companies should consider glycerol a higher-risk material. Companies should be able to exhibit a good knowledge of starting material supply chains and apply this knowledge and principles of quality risk management to their programmes for supply-chain management.

Inspectors will look to ensure that the basis for qualification of the supply chain is demonstrably robust for higher-risk materials such as glycerol. It is expected that identity testing and the limit test for DEG will be performed on each container as a matter of routine. 5. The European Pharmacopoeia limit test for DEG involves a gas chromatographic method, which may be difficult to perform on a large number of containers.

H+V December 2007 This point is acknowledged and currently, alternative tests are under consideration with a view to work up a possible change to the identity tests in the monograph. The DEG limit test remains the official method for confirmation of compliance with the monograph.

6. Are there any considerations applicable to the pharmaceutical assessment of marketing-authorisation applications? H+V July 2008 In application dossiers for new (MAs), or in case of relevant for existing MAs (for example, replacement of an with glycerol) for containing glycerol, confirmation of the tests applied on receipt of batches of glycerol to control the risk from potential DEG contamination in relation to the specific intended use of the product should be provided.

A test for DEG content should be conducted in addition to identity testing for glycerol. A suitable control for DEG is included in the monograph for glycerol. Sufficient information regarding satisfactory control of this risk will be required in the dossier before approval of the MA application or . For existing approved , no application is required, except for those few specific types of referred to in the first paragraph.

However, as a minimum, the specific control for DEG should be conducted along with the identity test at receipt of each batch of glycerol. The is required to comply with the current glycerol monograph, and as the specification approved in the dossier will have been that of the , the risk of DEG contamination will have been appropriately controlled.

Compliance with this requirement will be verified during GMP inspections. 7. My company manufactures products for external use. Does this guidance apply? H+V July 2008 EU GMP guide annexes: Supplementary requirements: Annex 8: Sampling of starting and packaging materials: Use of near-infrared (NIR) technology for container-wise identity testing 1. The registered specifications of our starting materials include conventional or pharmacopoeial methods for the confirmation of identity but we wish to use NIR to perform identity testing on each container of starting materials used in the manufact...

Annex 8 of the states that the identity of a complete batch of starting materials can normally only be ensured if individual samples are taken from all the containers and an identity test performed on each sample.

It is permissible to sample only a proportion of the containers where a validated procedure has been established to ensure that no single container of starting material has been incorrectly labeled. However, the annex goes on to say that it is improbable that a procedure could be satisfactorily validated for starting materials for use in parenteral products. Unless are submitted for all affected products, the registered method for confirming identity should be performed. However, there is no restriction on the performance of additional testing and the use of NIR to confirm container-wise confirmation of identity can provide useful information.

Under these circumstances, the requirements of the will be deemed to have been met by carrying out the registered method for confirmation of identity on a statistically representative composite sample when this is supplemented with NIR analysis of every container. The NIR method should be validated in line with the recommendations of the . Templates of spreadsheets help to avoid erroneous calculations from data remaining from previous calculations. They should be suitably checked for accuracy and reliability (annex 11 p7.1).

They should be stored in a manner which ensures appropriate version control (chapter 4 p4.1). 2. What type of accuracy checks (annex 11 p 6) are expected for the use of spreadsheets? H+V February 2011 Data integrity should be ensured by suitably implemented and risk-assessed controls. The calculations and the files should be secured in such a way that formulations are not accidentally overwritten.

Accidental input of an inappropriate data type should be prevented or result in an error message (e.g. text in a numeric field or a decimal format into an integer field). So-called 'boundary checks' are encouraged. 3. Are there any specific considerations for the validation of spreadsheets? H+V February 2011 Validation according to paragraph 4 of annex 11 is required at least for spreadsheets that contain custom code (e.g. Visual Basic for applications).

Formulas or other types of algorithm should be verified for correctness. 4. What measures are required to ensure data security of databases? H+V February 2011 Data security includes integrity, reliability and availability of data. During validation of a database-based or inclusive system, consideration should be given to: • implementing procedures and mechanisms to ensure data security and keeping the meaning and logical arrangement of data; • load-testing, taking into account future growth of the database and tools to monitor the saturation of the database; • precautions for necessary migration of data (annex 11 p17) at the end of the life-cycle of the system.

5. At which phases of the system life-cycle is risk management recommended? H+V February 2011 Risk management should be applied throughout the whole life-cycle. A first risk assessment should be performed to determine the GMP criticality of the system, i.e. does the system have an impact on patient safety, product quality or data integrity? User-requirement specifications are usually developed with consideration of potential risks and form the basis for the first formal risk assessment.

Complex systems should be evaluated in further more detailed risk assessments to determine critical functions. This will help ensure that validation activities cover all critical functions. Risk management includes the implementation of appropriate controls and their verification.

6. Are user requirements needed as part of the retrospective validation of legacy systems? H+V February 2011 The way to check whether a computerised system is fit for its intended purpose is to define user requirements and perform a gap analysis to determine the validation effort for retrospective validation. These user requirements should be verified. 7. When do I have to revalidate computerised systems? H+V February 2011 Computerised systems should be reviewed periodically to confirm that they remain in a validated state.

Periodic evaluation should include, where applicable, the current range of functionality, deviation records, change records, upgrade history, performance, reliability and security. The time period for revaluation and revalidation should be based on the criticality of the system.

8. What are the requirements for storage time of electronic data and documents? H+V February 2011 The requirements for storage of electronically data and documents do not differ from paper documents. It should be ensured that electronic signatures applied to electronic records are valid for the entire storage period for documents.

9. What are the relevant validation efforts for small devices? H+V February 2011 Small devices are usually off-the-shelf pieces of equipment that is widely used.

In these cases, the development life-cycle is mainly controlled by the vendor. The pharmaceutical customer should therefore reasonably assess the vendor's capability of developing software according to common standards of quality. A vendor assessment needs to be performed and the application needs to be verified against the requirements for the intended use. From the perspective of the regulated industry, the implementation of such a device is driven by an implementation life-cycle.

At minimum the following items need to be addressed: • requirement definition for the intended use including process limitations. This should also include a statement indicating whether data are stored or transferred to another system.

As per the definition of a small device, data are not stored permanently but temporarily and are not to be modified by a user. Therefore, limited user access handling is acceptable. It needs to be ensured that parameter data influencing the device's behaviour may not be altered without suitable permission; • risk assessment, taking into consideration the intended use and the risk to patients for associated with the process supported by the small device; • vendor assessment; • list of available documentation from the vendor, especially those describing the methodology used and the calculation algorithm, if applicable.

A vendor certificate or equivalent detailing the testing performed by the vendor may also be included; • calibration certificate, if applicable; • validation plan according to the risk-assessment results; • verification testing proving that the device fulfills the requirements for the intended use.

It may be equivalent to a PQ-phase. Small manufacturing devices are sometimes only equipped with microprocessors and firmware and are not capable of high-level administration functions. Moreover, data is often transient in nature in these devices.

Due to the latter there is no risk of inadvertently modifying data. An audit trail is therefore not necessary and user access may be limited to those functions of parameter control.

10. What alternative controls are accepted in case a system is not capable to generate printouts indicating if any of the data has been changed since the original entry? H+V February 2011 defines an IMP as 'a of an or placebo being tested or used as a reference in a , including products already with a but used or assembled (formulated or packaged) in a way different from the authorised form, or when used for an unauthorised , or when used to gain further information about the authorised form.' An would be considered an IMP if presented in a packaged form for use in a .

Any such packaging operation could only be carried out by a site holding an IMP manufacturing authorisation. Any form of mixing or processing the with other substances would also result in the need for a manufacturing authorisation for IMPs if the resulting product is to be used in a .

Physical processing such as milling of an active pharmaceutical ingredient would not constitute IMP manufacturing. The above does not refer to reconstitution. Separate guidance on this subject is under development. 2. How can the QP of a site assure compliance with the requirements of the clinical-trial application in situations where a QP may be required to certify a batch before the application is submitted to, or accepted by, the competent authority?

H June ... The QP of a site that is manufacturing a drug product intermediate should assure that the product is produced and controlled in compliance with the EU , in particular the requirements of annex 13. A product specification file should be developed with contributions from the QPs and other technical personnel of the sites involved with the other manufacturing activities of the IMP. The sponsor of the should also be involved in this process.

While this may be in a rudimentary form and contain little detail, it should be developed as knowledge of the product evolves and include specifications for critical parameters and controls. The product specification file should be updated and evolve in line with the product development as envisaged in annex 13. The development of the product specification file should be managed under a technical agreement or a number of technical agreements between the various manufacturing sites.

These should include the QP responsible for the final certification of the product and the sponsor, if the sponsor has already been appointed. In any event, final release of the product to trial sites should take place only when the sponsor has established that the product has been manufactured in compliance with the terms of the approved clinical-trial application (as required by annex 13.44). This is defined in annexes 13.40 and 13.44: 'The sponsor should ensure that the elements taken into account by the QP when certifying are consistent with the information notified pursuant to Article 9(2) of Directive 2001/20/EC.' 3.

Is it possible to perform packaging or labelling at the investigator site? H September 2007 This is normally possible only if a manufacturing authorisation has been granted to the site by the .

According to Article 9(1) of , the “authorisation, as provided for in Article 13(1) of Directive 2001/20/EC, shall be required for both total and partial manufacture of IMPs, and for the various processes of dividing up, packaging or presentation.” However, an exemption to this obligation is foreseen in Article 9(2) of : 'Authorisation, as provided for in Article 13(1) of Directive 2001/20/EC, shall not be required for reconstitution prior to use or packaging, where those processes are carried out in hospitals, health centres or clinics, by pharmacists or other persons legally authorised in the Member States to carry out such processes and if the IMPs are intended to be used exclusively in those institutions.' In addition, reference should be made to section 33 of annex 13 in respect of any re- to extend shelf life.

4. Who is responsible for the packaging or labelling activities carried out at the investigator site? H September 2007 The sponsor has the ultimate responsibility for all trial activities performed at the investigator site, but should seek the advice of the QP of the IMP manufacturer, if possible, or the clinical-trials pharmacist at the investigator site regarding: • adequacy of premises and equipment (storage conditions etc.); • adequacy of written standard operating procedures; • training of personnel involved, both on GMP requirements and any protocol specific requirements for the IMPs; • written instructions to perform activities; • forms to document the activities carried out; • checks to be done; • the keeping of retention samples; • record-keeping.

5. Who is responsible for the transport and storage conditions when an IMP is transported from the manufacturer to the distributor or investigator sites? H May 2009 The sponsor should exercise control over the entire chain of distribution of IMPs, from manufacture or importation into the EEA, through to supply to the investigator sites, so as to guarantee that IMPs are stored, transported, and handled in a suitable manner.

When an IMP originates from a , the importer is responsible for verifying that the transportation and storage conditions for the product are suitable. For products originating within the EEA, the manufacturer is responsible for transportation and storage conditions. The respective responsibilities of the sponsor, manufacturer, importer and, where used, distributor should be defined in a technical agreement.

6. What measures should be taken to ensure that the IMPs are kept under suitable conditions during transportation between the manufacturer or distributor and the investigator sites? H May 2009 Storage conditions during transportation should be validated or monitored using a suitable temperature-measuring device that is capable of showing fluctuations in temperature e.g.

Temperature Logger. The choice of method of transport should be influenced by the nature and sensitivity of the product and should ensure timely delivery of IMPs to the investigator sites. The outer packaging should be labelled showing the final destination, the name of manufacturer or sponsor and the storage conditions required.

7. What measures should be taken to ensure that IMPs are kept under suitable conditions during storage at the investigator sites? H May 2009 IMPs should be packaged to prevent contamination and unacceptable deterioration during storage. The sponsor should determine acceptable storage temperatures and any other required storage conditions for the IMPs (e.g.

protection from light). The sponsor should ensure that all involved parties (e.g. monitors, investigators, pharmacists, storage managers) are aware of these conditions and the actions to be taken in the event that the conditions are not met.

Where appropriate, there should be a restricted area for the storage of IMPs. The temperature of the areas and equipment used for the storage should be monitored using suitable means, such as a temperature recorder or, as a minimum, a record of the maximum and minimum temperatures, at a suitable frequency (for example, daily).

8. What written procedures should be in place at the investigator site regarding IMPs? H May 2009 The sponsor should ensure that written procedures include instructions that the investigator or institution should follow for the handling and storage of IMPs. The procedures should address adequate and safe receipt, handling, storage, where relevant any reconstitution process to be carried out before administration, retrieval of unused product from subjects, and return of unused IMPs to the sponsor (or alternative disposal, if authorised by the sponsor and in compliance with the applicable regulatory requirements).

Procedures should also give instructions on the actions to be taken when defined conditions are not met. 9. What records must be kept at the investigator site regarding the abovementioned procedures? H May 2009 Annex 16 of the EU gives guidance in relation to situations where different stages of manufacture of a batch take place at different manufacturing sites.

In such cases, the overall responsibility for correct manufacture of the batch lies with the QP performing final certification of the batch before release for sale. It is also possible that, at a single manufacturing site, different QPs could be responsible for certification of different stages of manufacture of the batch. However, as before, the QP performing final certification before release holds overall responsibility for manufacture of the batch in accordance with GMP and the .

3. In the context of handling unexpected deviations, what is included in the scope of registered specifications for medicinal products? / What is an 'unexpected' deviation? / Does Annex 16 permit QP certification of more than one batch affected by t... In the context of handling unexpected deviations, what is included in the scope of registered specifications for ?

In order to satisfy the criteria in Annex 16 section 3 for handling unexpected deviations, all registered specifications for , , packaging materials and must be met.

Registered specifications for include in-process, bulk and finished product specifications which have been included in the MA application. The criticality of registered in-process specifications may vary depending on the quality attribute tested, the impact to subsequent manufacturing processes and ability to test the quality attribute in the finished product. It may therefore be possible to accept deviation from an in-process specification where risk assessment confirms that there is no impact to manufacturing process or product quality.

Non-compliance with registered specifications (except where excursions from in-process specifications can be accepted based on quality risk management principles) therefore fall outside the scope of Annex 16 section 3, and the QP would not be able to certify the affected batches under the Annex 16 provisions for handling unexpected deviations.

What is an 'unexpected' deviation? The process itself should be designed to comply with the registered requirements (fit for purpose).

A deviation can be considered as 'unexpected' until the time of discovery. Where the relevant authorities have confirmed the need to avoid supply disruption, repeat deviations thereafter are no longer 'unexpected' but may be considered for QP certification and accepted while corrective and preventive action is in progress and where the provisions of Annex 16 paragraph 3.1 are met.

Planned deviations or deviations that are caused by incorrect communication between (MAH) and manufacturers (e.g. if the MAH fails to notify the manufacturer of relevant changes to the MA) are outside the scope of the paragraph 3.1.

The should submit an application for a to the , if needed. Does Annex 16 permit QP certification of more than one batch affected by the same unexpected deviation? If more than one batch has already been manufactured and/or tested at the time of discovery of the unexpected deviation, then it is acceptable to consider QP certification of all these batches under the provisions of Annex 16 section 3.

Following discovery, repeated deviations from the manufacturing process and/or analytical control methods should be considered changes, and to the affected must be submitted. In to avoid disruption to supply, it may be possible to continue QP certification while corrective and preventive action is in progress; see Q&A on what is 'unexpected' deviation above. For retention purposes, it is not necessary to keep the full number of samples required in table 2.6.1.3 of the sterility test monograph to repeat the sterility test performed for release purposes, but only a sufficient quantity to allow the carrying out, on two occasions, of a confirmatory test using the minimum quantities described in table 2.6.1.2 of the monograph.

2. In which cases does the exemption for a fully packaged unit as retention sample apply as referred to in section 2.1 of EU GMP Part I, annex 19: “There may be exceptional circumstances where this requirement can be met without retention of duplicat... Firstly, the supervisory authority should grant such an exemption upon request from the manufacturer.

The relevant authority may agree to this when one or more of the following criteria are met: • A batch size of less than 50 units; • High value/low volume and the high value price of the as determined by each individual ; • Large size of one packaged unit e.g. some veterinary pre-mixes or hospital packages. Parallel imported/distributed will not be granted an exemption from keeping a fully packaged unit if the products have been re-packaged.This is because the exemption refers to “duplicate samples”, and in these cases no reference sample is required to be kept by the parallel distributor/importer.

On the other hand, where the secondary packaging of the source product is not opened by the parallel importer/distributor only samples of the additional packaging material used needs to be retained. 3. In those cases where the supervisory authority agrees that the criteria mentioned in the answer to question 1 are met, what should be retained instead of a fully packaged unit?

H+V December 2013 The original batch specific primary packaging material with print/imprint, if any, all the original batch specific secondary packaging materials e.g. labels and leaflets with print/imprint including Braille, and dosing aids, if any, must be kept. The use of photocopies of the fully packaged unit to replace the retention sample are not acceptable as some details e.g.

braille and holograms may not show correctly. 4. Do different requirements for reference and retention samples apply for some medicinal products?

H+V December 2013 EU GMP principles and are laid down in (human medicines) and (veterinary products). These principles and are subject to further detailed guidance in the form of the EU with its annexes. WHO publishes its own GMP guidance documents.

Although EU and WHO GMP guidance documents do differ in some details, the main principles remain the same. EU requirements fulfil all the recommendations of WHO.

Documents appearing in the EudraGMDP database are uploaded by the national competent authorities through a secure network guaranteeing their authenticity.For submissions to EU authorities paper documents are not required as a reference can be made to the EudraGMDP database. EU authorities are aware that these documents are also used to support regulatory submissions in third countries and that various additional requirements, including apostilled copies are sometimes expected.

In view of the integrity of entries in the EudraGMDP database, EU authorities strongly encourage reliance on the database. Any concerns about a certificate/authorisation in the database should be addressed to the issuing authority.

2. What is a GMP certificate and what is the difference between GMP certificates, certificates of medicinal product (CMPs, also called certificates of pharmaceutical products, CPPs) and certificates of suitability to the monographs of the European Ph...

A GMP certificate is a certificate issued following a GMP inspection, by the responsible for carrying out the inspection, to confirm the GMP compliance status of the inspected site. GMP certificates are site-specific, but can be restricted to particular activities depending on the scope of the inspection (e.g., manufacturing activities related to a specific product).

Directives and , as amended state that after every GMP inspection, and within 90 days of the inspection, a GMP certificate shall be issued to a manufacturer, if the outcome of the inspection shows that the manufacturer complies with GMP.

CMPs are product-specific certificates issued by the that granted the . The European Medicines Agency issues CMPs on behalf of the European Commission for . CMPs are issued in the context of the World Health Organization certification scheme on the quality of pharmaceutical products moving in international commerce, to confirm the marketing-authorisation status of the products.

These certificates also confirm the GMP compliance status of the manufacturing sites. CMPs are mainly used by companies to support applications to export their pharmaceutical products to countries with less-developed regulatory systems.

CEPs are certificates issued by the (EDQM) to confirm that a certain is produced according to the requirements of the relevant monograph of the or of the monograph on transmission spongiform encephalopathies. CEPs can be used by companies when submitting an application for , and replace much of the documentation required for the in the marketing-authorisation dossier. GMP inspections of active-substance manufacturers can be requested by EDQM in the context of the CEP certification scheme.

3. Does the Agency issue GMP certificates? H+V July 2006 All EU and EEA national competent authorities conducting inspections are obliged to enter GMP certificates in the EudraGMP database. Hence, any GMP certificate appearing in the database is mutually recognised and the database authenticates the certificate.

If a certificate cannot be found in the database, the issuing authority should be contacted. 5. How can a GMP non-compliance statement be lifted? September 2017 In principle, a GMP non-compliance statement can only be lifted following a new inspection by an EU authority that results in the issue of a GMP certificate. In practice, this can present difficulties for manufacturers located in third countries. For sites located in third countries the GMP non-compliance statement may mean that the site is no longer listed in or applications and therefore there will be no reason for a new EU inspection.

However, EU inspectorates acknowledge that the manufacturer may subsequently take remedial measures to bring the site into an acceptable level of compliance. As there is no intention to convey that the site continues to operate to an unacceptable level of non-compliance and given the absence of a new inspection trigger, the issuing authority will add a clarifying remark where a non-compliance statement appears in EudraGMDP over a prolonged period of time.

The Agency does not perform inspections. They are carried out on its behalf by the national competent authorities of the member states of the EEA, in connection with products under the centralised marketing-authorisation procedure. 2. If a site in a third country has plans to export products to the EEA, is it possible to apply for a GMP inspection on a voluntary basis? H+V July 2006 Normally, the need for inspection under these circumstances is triggered by an application for a .

It may be possible to request an inspection on a voluntary basis, but as the competent authorities will have other priorities, there is no guarantee that such a request will be met. To explore this possibility, the authorities of the Member State into which the product will be imported into the EEA should be approached. In any case, applicants are encouraged to approach the relevant authority in advance of submission in order to facilitate third-country inspection planning.

3. When a new application is submitted in the EEA and a GMP inspection is deemed necessary, which competent authority carries out the inspection? H+V July 2006 If the site is located in the EEA, the of the Member State where the site is located carries out the inspection. For sites located in countries outside the EEA, the responsible authority for inspection (the 'supervisory authority') is the authority in whose territory the importing site is located. If the supervisory authority is not able to carry out the inspection for any reason, it can be delegated to another EEA .

If there is a (MRA) in place between the countries where the site is located and the European Community, the results of GMP inspections carried out by the MRA partner authority are normally recognised by the EU authorities. Data integrity enables good decision-making by pharmaceutical manufacturers and regulatory authorities.It is a fundamental requirement of the pharmaceutical quality system described in EU GMP chapter 1, applying equally to manual (paper) and electronic systems.

Promotion of a quality culture together with implementation of organisational and technical measures which ensure data integrity is the responsibility of senior management. It requires participation and commitment by staff at all levels within the company, by the company's suppliers and by its distributors. Senior management should ensure that data integrity risk is assessed, mitigated and communicated in accordance with the principles of quality risk management.

The effort and resource assigned to data integrity measures should be commensurate with the risk to product quality, and balanced with other quality assurance resource demands. Where long term measures are identified in order to achieve the desired state of control, interim measures should be implemented to mitigate risk, and should be monitored for effectiveness. The following questions and answers describe foundational principles which facilitate successful implementation of existing guidance published by regulatory authorities participating in the PIC/S scheme.

It should be read in conjunction with national guidance, medicines legislation and the GMP standards published in . The importance of data integrity to quality assurance and public health protection should be included in personnel training programmes.



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