The Quality System for Drugs in Germany
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1 The Quality System for Drugs in Germany Prof. Dr. Harald G. Schweim Head of Department for Drug Regulatory Affairs Institute for Pharmacy, University of Bonn Former President of the German Federal Institute for Drugs and Medical Devices (BfArM) Former Director of the German Institute of Medical Documentation and Information (DIMDI)
2 Steps for a quality system Decision for a quality system Quality Management Manual: 17 guidelines Draft documents for a Quality Assurance System in GMP Approval of Quality Policy Implementation and Test Phase First Revision of Documents; ongoing Extension of System planned for supervision of - GCP - veterinary medicinal products - wholesalers - pharmacies
3 Underlying standards 1. PIC/S: Recommendations on quality system requirements for GMP inspectorates (PH 7/94; current updated version 2. European Norms EN (1995) EN (1989) 3. DIN/ISO Norms ISO 9002 (1994) 4. Compilation of community procedures on administrative collaboration and harmonisation of inspections (2001) (
4 EU- Compilation of Community procedures cover... Training of inspectors Manufacturing authorisations Inspection planning Inspection performance, follow-up Inspection report Action in cases of non-compliance/ defect products (RAS*) Sampling Internal Audits *Rapid Alert System
5 Structure of Quality System Policy Statement Quality Management Manual (QMM) Statement for quality policy 17 Qualityguidelines Quality Assurance Manual (QAM) SOPs AIMs
6 QM-Manual: Quality Guidelines Frame conditions for a detailed quality system (responsibilities, organisation and management, personnel, documentation, change control, inspection systems, equipment, quality manuals, transparency, audits, complaint handling, sub-contracting, cooperation, sampling and testing, certificates) Decided and approved on political level
7 Quality Guidelines (1) 1. Responsibility of the upper management 2. Administrative provisions 3. Organisation and management 4. Personnel 5. Documentation 6. Change control 7. Inspection procedures 8. Required equipment / resources 9. Quality assurance manual 10. Confidence building and transparency
8 Quality Guidelines (2) 11. Internal quality audit and regular checks (management review) 12. Administrative actions for deficiencies and defects 13. Handling of mistakes, complaint management 14. Delegation of tasks 15. Licensing 16. Cooperation 17. Testing of samples
9 QA-Manual: SOPs /Aide mémoires 32 SOPs (Standard Operating Procedures) (qualification and training of inspectors, manufacturing / import authorisation, inspection performance, inspection planning, certificates,...) 8 Aide mémoires (sterile drugs, biotechnology, computerized systems, blood products, active ingredients,...) Developed on an expert level
10 Specific Procedures Staff training and designation of GMP inspectors appointment of QA responsibilities avoidance of conflict of interest ongoing training job descriptions assessment and maintenance of qualification
11 Inspections inspection plan conduct of inspections inspection report Site Master File teams sampling Aides memoire
12 Aides mémoire for Inspections inspection of manufacturers biotechnology qualification and validation inspection of blood banks manufacturers of sterile products computerised systems API manufacturers
13 Quality Defects management of drug risks/ incidents, consumer complaints, other complaints corrective action in case of defects and deficiencies evaluation of deviations, deficiencies and defects
14 Authorisations/Certificates manufacturing authorisation WHO certificate certificate for API import authorisation certificate acc. section 72a AMG
15 Drug Testing official testing of samples OOS results validation of analytical procedures
16 Training and Designation of GMP Inspectors 1. Basic qualification: pharmacists veterinarian (only for vet. prod.) 2. Baseline Training: 2 years in an inspectorate of which 6 months may be in OMCL, Länder ministry, Federal Ministry, quality lab (ZLG) 3. Theory: as in Compilation of community procedures Practical training: at least 10 joint inspections with senior inspector 5. Final exam inspection 6. Formal designation
17 Ongoing Training 1. At least 10 days per year, e.g.: Conferences (e.g. PIC/S, commercial conferences) German annual conference Expert group trainings Joint inspections/ joint visits Local SOP training sessions 2. Formal documentation in personal file
18 Assessment and Maintenance of Qualification Every 5 years by head of inspectorate Assessment may be covered by: - Quality audit - Evaluation of inspection reports - participation in inspections Possible actions: - specific training - participation in inspections in other inspectorates - suspension or revocation of designation
19 SOP : Sampling Sampling plan by OMCL in cooperation with inspectorate Analytical evaluation of risk products within 5 years after approvals Risk products : New chemical entity API with narrow therapeutic range API with low stability Dosage form with specific technological properties/ problems
20 Audit Systems : Audits 1. Subject: Inspectorates 2. Biannual cycle: Organisation Procedures Quality System 3. Auditors: at least 2 at least 1 GMP inspector 4. Corrective Action : to be proceeded to management to be evaluated by auditors
21 Inspections of API* manufacturers in Germany Legal requirements: Under scope of centralised procedure National level: only APIs of human and animal origin; biotec APIs After publication of Ordinance: all APIs Practical implementation Voluntary inspections of API manufacturers Voluntary 3 rd country inspections * Advanced Pharmaceutical Industry
22 Conclusions: What we learnt about the process... to give enough time for discussions on all levels to make sure that all parties involved have enough time to make contributions to make sure that contributions are clearly evaluated to allow for 70 % accuracy at the beginning to allow for a pilot phase in order to collect practical experiences to intensively monitor the implementation phase to adjust immediately where necessary
23 Thank you for your attention!
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