|
GMP is a term that was introduced in 1962
by the US Food and
Drug Administration
(FDA). The term is synonymous for a collection of behaviour
measurements and instructions that have to be taken
into consideration during the production and handling
of certain products (e.g. pharmaceuticals, food products,
cosmetic products and veterinary medicines etc.) with
the main goal being that these products are reproducible
and reliable in the desired quality.
The obligation to follow the GMP guidelines
comes from various laws (e.g. the German Medicines Act)
or through intergovernmental agreements (e.g. PIC
= Pharmaceutical Inspection
Convention = agreement
between former EFTA members).
In the European guide for pharmaceutical
products, III/2244/87, Rev. 3, Jan. 1989, valid since
1992 Good Manufacturing Practice, GMP, is defined as:
" that part of Quality
Assurance which ensures that products are consistently
produced and controlled to the quality standards appropriate
to their intended use and as required by the Marketing
Authorisation or product specification."
As regards content the GMP guidelines
deal with the demands of
(see table of content of ICH Q7a GMP guidelines)
- Quality Management (quality unit, audits,
quality reviews,
)
- Personnel (qualification, education,
hygiene,
)
- Buildings and facilities (design, sanitation,
maintenance,
)
- Process equipment (design, cleaning,
calibration,
)
- Documentation and Records (master instructions,
batch records,
)
- Materials Management (receipt, quarantine,
testing,
)
- Production and In-Process Controls (sampling,
blending,
)
- Packaging, Labelling (packaging material,
procedures,
)
- Storage and distribution (warehouse
procedures,
)
- Laboratory Controls (analytical procedures,
)
- Validation (equipment qualification,
process validation,
)
- Change Control (major changes, minor
changes,
)
- Rejection (reprocessing, reworking,
)
- Complaints and recalls
-
Two major difficulties
arise in the application of GMP guidelines:
1. There is not one GMP rule but
rather numerous GMP rules plus additional and supplementary
guidelines and literature.
Whether, or which, GMP rule applies depends
on
- the type of product (final pharmaceutical
substance, active or inactive pharmaceutical ingredient,
food product etc.)
- form of administration (oral, parenteral,
)
- product specification (sterile, low
germ content, unsterile,
)
- the development stage (development or
production)
- the process step (critical, non-critical)
- the country of distribution (Europe,
USA, Japan)
Only if all these questions are answered
is one able to choose the correct GMP guidelines.
2. GMP guidelines say what has
to be done or complied with, but not how.
One of the most frequent requirements of
GMP is that something should be designed, constructed
and erected in such a way that any kind of cross-contamination
with other products is avoided under all circumstances.
How this aim is achieved depends on the experience of
the individual project leader. Exactly this point led
to a great deal of discussion in the past because it
often led to the relevant activities being carried out
excessively.
In conclusion: GMP guidelines
must be chosen, interpreted and implemented with the
necessary experience on a case-by-case basis.
and this is exactly where
we want to help you.
|