Six Sessions
Get You Better at PIC/S GMP
Session 2
8:30 – 10:00
Registration
10:00 – 10:15
Opening Session by GP Farmasi
10:15 – 11:45
Materials Presentation
11:45 – 12:00
Break
12:00 – 12:50
Q & A
12:50 – 13:05
Quiz
13:05 – 13:20
Explanation of Quiz Answer
13:20
Closing Session
◎Presenter
Dr.GTakahashiG(Q&A)G Mr.GTahara Ms.GLanny
Agenda
Session 1. Introduction & GMP Guide Part I (Chapter 1 & 2)
Session 2. PIC/S GMP Guide –Part I (Chapter 3 & 4)
Session 3. PIC/S GMP Guide –Part I (Chapter 5 & 6)
Session 4. PIC/S GMP Guide –Part I (Chapter 7 to 9) and Basic of Site Master File
Session 5. PIC/S GMP Guide –Annex 1 Manufacture of Sterile Medicinal Products
Session 6. PIC/S GMP Guide –Annex 15 Qualification and Validation
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Todayʼs Topics
1. A Quick Recap of Our Previous
Session
2. PIC/S Part I - Chapter 3
Premises and Equipment
1.G
A Quick Recap of Our Previous Session
Commenced operating on 2 Nov. 1995
History of PIC/S
http:// .pi s he e.o g/
Numbers on PIC/S
48 Members in the world
7 Members in Asia (Singapore, Malaysia, Indonesia,
Taiwan, Japan, Korea, Hong Kong)
4 Partner Organizations
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1. A Quick Recap of Our Previous Session
EU legal enforcement system
• Regulation The most significant
enforcement. Directly applied in preference to national law in EU Member States.
• Directive The applicable enforcement by sector. It must be replaced to national law amended or enacted within 3 years.
• Decision Directly binding while just targeting some specific requirements in a more detail manner.
• Recommendation Not legally binding, but it encourages EU Member States to amend or enact the legislation.
• Opinion To express the current thinking the EU Commission in a particular theme.
PIC/S GMP PIC/S
1. A Quick Recap of Our Previous Session
Mutual Recognition Arrangement (MRA)
MRA MRA
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1. A Quick Recap of Our Previous Session
PIC/S GMP GUIDE PART I:
BASIC REQUIREMENTS FOR MEDICINAL PRODUCTS
Chapters
Part I
Chapte Chapte Chapte
Chapte Chapte Chapte Chapte Chapte Chapte
1.QMS
2. Personnel
3. Premises/equipment 4. Documentation
5. Production 6. QC
7. CMO
1. A Quick Recap of Our Previous Session
Regulatory Compliance
T a a a a a y a a
, a a a a .
PIC/S GMP has been becoming a global standard
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1. A Quick Recap of Our Previous Session
Quality Management System (QMS)
= Quality System = Quality Assurance
Recap of Chapter 1: Quality Management
QMS
Continuous improvement throughout the life cycle
GMP
Quality assurance in
day-to-day production activities
Quality
1. A Quick Recap of Our Previous Session
GMP QC
PQR
Ma k
Pete
Tho as Bill
Mi hael
Ri ha d
QRM
PQR
To ensure that the medicinal products produced are;
fit for their intended use,
comply with the requirements of the market authorization,
do not place patients at risk
due to inadequate safety, quality or efficacy.
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1. A Quick Recap of Our Previous Session
Method
Recap of Chapter 2: Personnel
a ade uate u e
of pe so el & p a ti al e pe ie ee essa ualifi atio s itte jo des iptio s
Ma k
Pete
Tho as Bill
Mi hael
Ri ha d
1. A Quick Recap of Our Previous Session
QA relies upon correct manufacture (4Ms), which rely upon
people .
Principle
Pe so el
P o ess
Validatio
Sa pli g
Re o d Release
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Todayʼs Topics
1. A Quick Recap of Our Previous
Session
2. PIC/S Part I - Chapter 3
Premises and Equipment
2. Chapter 3: Premises and Equipment
Premises and equipment must be located, designed,
constructed, adapted and maintained to suit the operations to be carried out.
The layout and design must aim to minimize the risk of errors and permit effective cleaning and maintenance in order to avoid cross-contamination, build up of dust/dirt and any adverse effect on the quality of products.
Itʼs about design + engineering
Hi
d Pharmaceutical industry
provides unique
challenges No
o specify criteria or numerical for premises and
equipment W
hs Your ingenuity will be
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PRINCIPLE
Premises and equipment must be located, designed, constructed, adapted and maintained to suit the operations to be carried out. Their layout and design must aim to minimize the risk of errors and permit effective cleaning and maintenance in order to avoid cross-contamination, build up of dust or dirt and, in general, any adverse effect on the quality of products.
Premises should be carefully maintained, ensuring that repair and maintenance operations do not present any hazard to the quality of products. They should be cleaned and, where applicable, disinfected according to detailed written
procedures.
.
2. Chapter 3: Premises and Equipment
2. Chapter 3: Premises and Equipment
A typical flowchart in facility project case:
Feasi ilit
Co eptual de elop e t
P oje t
pla i g Basi desig + DQ
Detailed desig + Spe ifi atio
Supplie
sele tio Co st u tio+ i stallatio
IQ/OP/PQ
P odu tio + ai te a e
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Risk Co t ol
*De easi g Risk *Risk A epta e
Fish Bo e, FMEA et . UR
6
ISP
I
ia
PUR
*P odu t Qualit *CQA *CPP,GMP GUR
*P odu t Capa it Et .
Co eptual Desig
Risk Assess e t
*Spe if Risk *Risk A al sis
SIA
*Risk Assess. Desig Co ept Desig data et .
URS PUR
*P odu t Qualit *CQA *CPP,GMP
GUR
*P odu t Capa it Et .
C iti al Aspe ts *Fa ilit /S ste Spe ifi atio
Basi
Desig Detail Desig DQ *Self I spe tio
Co e ial
Qualifi atio
Co issio i g
Choose proper clean class for each process!
Example of Aseptic process ISPE Baseline Guide Vol.3, Jan 1999
G Grade Grade
Grade
Min.
Intervention FillingGProcessCleanGBench
NoG
Intervention Critical portionGfor sterile
Grade C
Garment FormulationG etc.
WashingGToolsGetc.
Machine room,GOut side.
Co t olled ot lassified
2. Chapter 3: Premises and Equipment
Clean Garment
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2. Chapter 3: Premises and Equipment
Whether a new or existing facility, clarify the concept first.
Be certain it can be explained by you.
What do you want the premises to do?
U
Mountains of
books QRM app
oa
h Scientific evidences
Good qualification practice Knowledge management Use of quality risk management (QRM) approach
Implementation of DQ/IQ/OQ/PQ
Make all records comprehensible to any personnel.
Turn your mountains of books into the best practice
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2. Chapter 3: Premises and Equipment
Situated in a suitable environment
Carefully maintained ensuring the cleanliness
Appropriate lighting, temperature, humidity and ventilation
Designed as to afford protection against the entry of insects
Steps taken to prevent the entry of unauthorized people
General requirements for premises
Lighting, temperature, humidity and ventilation should be appropriate and such that they do not adversely affect, directly or indirectly, either the medicinal
products during their manufacture and storage, or the accurate functioning of equipment.
Premises should be designed and equipped so as to afford maximum protection against the entry of insects or other animals.
.
2. Chapter 3: Premises and Equipment
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2. Chapter 3: Premises and Equipment
GeneralSteps should be taken in order to prevent the entry of unauthorized people,
Production, storage and quality control areas should not be used as a right of way be personnel who do not work in them.
.
CleanG Corridor
Process RoomGB Process
RoomGA Process
2. Chapter 3: Premises and Equipment
Dedicated and self-contained facilities for medical hazard
Zoning and layout
Flow of material and product to prevent mix-ups
Interior surfaces (walls, floors and ceilings) consideration
Good M/E work
Adequate size of drains
Effectively ventilated with air control facilities
Separated weighing room for starting materials
Specific provisions taken for where dust is generated
Packaging rooms to avoid mix-ups or cross-contamination
Adequate room brightness
In-process controls may be conditionally carried out within the production area
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Production Area
In order to minimize the risk of a serious medical hazard due to
cross-contamination, dedicated and self-contained facilities must be available for the production of particular medicinal products, such as highly sensitizing materials (e.g. penicillins) or biological preparations(e.g. from live micro-organisms).
The production of certain additional products, such as certain antibiotics, certain hormones, certain cytotoxics, certain highly active drugs and non-medicinal
products should not be conducted in the same facilities. For those products, in exceptional cases, the principle of campaign working in the same facilities can be accepted provided that specific precautions are taken and the necessary validations are made. The manufacture of technical poisons, such as pesticides and herbicides, should not be allowed in premises used for the manufacture of medicinal products.
.
2. Chapter 3: Premises and Equipment
Dedicated and self-contained facilities for medical hazard
Highl se sitizi g ate ials
e.g. pe i illi d ugs
Biologi al p epa atio s
e.g. li e i o‐o ga is s
o tai e t
isolato
A epta le Dail E posu e ADE O upatio al E posu e Li its OEL
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2. Chapter 3: Premises and Equipment
SegregationGofGHazardousGFactory
2. Chapter 3: Premises and Equipment
Air Lined Suit
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Where starting and primary packaging materials, intermediate or bulk products are exposed to the environment, interior surfaces (walls, floors and ceilings) should be smooth, free from cracks and open joints, and should not shed particulate matter and should permit easy and effective cleaning and, if necessary, disinfection.
Pipe work, light fittings, ventilation points and other services should be designed and sited to avoid the creation of recesses which are difficult to clean. As far as possible, for maintenance purposes, they should be accessible from outside the manufacturing areas.
.
2. Chapter 3: Premises and Equipment
Production Area.
Clean room
Drains should be of adequate size, and have trapped gullies. Open channels should be avoided where possible, but if necessary, they should be shallow to facilitate cleaning and disinfection.
.
2. Chapter 3: Premises and Equipment
Production AreaPIC/S GMP Annex 1
50. Sinks and drains should be prohibited in grade A/B areas used for aseptic
manufacture. In other areas air breaks should be fitted between the machine or sink and the drains. Floor drains in lower grade clean rooms should be fitted
with traps or water seals to prevent backflow.
Pure Steam
Air Brake
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Productions areas should be well lit, particularly where visual on-line controls
are carried out.
.
2. Chapter 3: Premises and Equipment
Production AreaIn cases where dust is generated (e.g. during sampling, weighing, mixing and processing operations, packaging of dry products), specific provisions should be taken to avoid cross-contamination and facilitate cleaning.
.
Premises for the packaging of medicinal products should be specifically designed and laid out so as to avoid mix-ups or cross-contamination.
.
FDA CGMP § 211.44 - Lighting.
2. Chapter 3: Premises and Equipment
Good M/E work Adequate size of drains
Separated weighing room for starting materials
• Avoid creation of recesses • Accessible from outside
I depe de t u it
T apped d ai /slope Eas to lea
Stati diffe e tial Ai flo
e haust
MAU
e haust
F esh ai
A essi le f o outside
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2. Chapter 3: Premises and Equipment
Effectively ventilated with air control facilities
Ai flo patte
DB ℃ RH%
+ p essu e
HVAC a d
Mo ito i g
Mai te a e
Co t ol fa ilit
Clea li ess
A comprehensive system
2. Chapter 3: Premises and Equipment
Interior surface (wall, floor and ceiling) consideration
• Smooth surfaces
• Free from cracks/open joints
• Permit easy and effective cleaning
Mate ials
Co st u tio
Co figu atio
• Co osio
• Peeli g • Diffi ult to lea• Residual dete ge t
E
uip
e
t
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2. Chapter 3: Premises and Equipment
Specific provisions taken for where dust is generated
i di atio
Level 1
Spa e + i di atio
Level 2
Light pa titio
Level 3
Lo ked
Full isolatio Sepa ate HVAC
Level 5
Lo ked
Pa titio all
Level 4 With eili g Haza d t pe
2. Chapter 3: Premises and Equipment
Packaging rooms to avoid mix-ups or cross-contamination
P odu t B
Ca to o es fo B P i a pa kage
P odu t A Ca to o es fo A
Se o da pa kage
Sepa ated pa titio s Sepa ated
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2. Chapter 3: Premises and Equipment
In-process controls may be conditionally carried out within the production area
Adequate room brightness
Productions areas should be well lit, particularly where visual on-line controls are carried out.
Slightly different between cGMP and EU-GMP
e.g. on particle sizes:
5μm is not applicable.
both 0.5 & 5μm are applicable.
on continuing monitoring requirement
remote monitoring is not a mandate.
remote monitoring is not a mandate for Grade B area, but a mandate for Grade A.
The a i u allo a le pa ti les u e /
At rest In operation Grade 0.5μm 5.0μm 0.5μm 5.0μm A (ISO 5) 3,520 20 3,520 20
B (ISO 7) 3,520 29 352,000 2,900
C (ISO 8) 352,000 2,900 3,520,000 29,000
D 3,520,000 29,000 - -
Reference: EU-GMP Glasses of air cleanliness (2008)
cGMP
EU GMP
cGMP
2. Chapter 3: Premises and Equipment
Sufficient capacity to meet various storage needs
Storage condition considerations (temperature, humidity)
Receiving/dispatch bays and receptions areas
Quarantine status considerations
A separate sampling area for starting materials
・・・・・・・
Storage area (Section 3.18 to 3.25)
QC
La Ma ufa tu i g a ea
Wa ehouse
Re ei i g a Dispat h a
Qua a ti e Sa pli g
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Storage areas should be designed or adapted to ensure good storage
conditions. In particular, they should be clean and dry and maintained within
acceptable temperature limits. Where special storage conditions are required (e.g. temperature, humidity) these should be provided, checked and monitored.
2. Chapter 3: Premises and Equipment
.
There should normally be a separate sampling area for starting materials. If
sampling is performed in the storage area, it should be conducted in such a way as to prevent contamination or cross-contamination.
.
Storage Area
Printed packaging materials are considered critical to the conformity of the
medicinal products and special attention should be paid to the safe and secure storage of these materials.
2. Chapter 3: Premises and Equipment
Normally, QC lab should be separated from production area.
QC lab should have Sufficient space to avoid mix-ups and cross-contamination
Sensitive instruments need to be protected in separate
rooms from vibration, electrical interference, humidity, etc.
・・・・・・
Quality control area (Section 3.26 to 3.29)
QC
La Ma ufa tu i g a ea Wa ehouse
Re ei i g a Dispat h a
Qua a ti e Sa pli g
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Normally, Quality Control laboratories should be separated from production
areas. This is particularly important for laboratories for the control of biologicals, microbiologicals and radioisotopes, which should also be separated from each other.
2. Chapter 3: Premises and Equipment
Quality Control Area
2. Chapter 3: Premises and Equipment
Rest and refreshment rooms should be separate from other areas.
Facilities for gowning, washing purposes to be easily accessible and appropriate for the number of users.
Maintenance workshops to be as far as possible separated from production areas.
Whenever parts/tools are stored in production area, to be kept in rooms or lockers reserved for that use.
・・・・・・・
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2. Chapter 3: Premises and Equipment
Facilities for changing clothes, and for washing and toilet purposes should be easily accessible and appropriate for the number of users. Toilets should not directly communicate with production or storage areas..
.
Ancillary Area
Example of Aseptic process ISPE Baseline Guide Vol.3, Jan 1999
G
Machine room,GOut side.
Co t olled ot lassified
Clean Garment No
2. Chapter 3: Premises and Equipment
Designed/located/maintained to suit its intended purpose.
Maintenance should not present hazard to product quality.
Equipment should be easily/thoroughly cleaned.
………
Measuring/control equipment should be calibrated and checked at defined intervals. Records of such tests should be maintained.
………
Requirements for equipment (Section 3.34 to 3.42)
P
Ope ati g I st u tio
Re o d Data ase
P og a
T
Co puti g Computerized system validation
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Manufacturing equipment should be designed so that it can be easily and thoroughly cleaned. It should be cleaned according to detailed and written procedures and stored only in a clean and dry condition.
Washing and cleaning equipment should be chosen and used in order not to be a source of contamination.
.
2. Chapter 3: Premises and Equipment
.
Equipment
Measuring, weighing, recording and control equipment should be calibrated and checked at defined intervals by appropriate methods. Adequate records of such tests should be maintained.
.
Fixed pipework should be clearly labelled to indicate the contents and, where applicable, the direction of flow.
2. Chapter 3: Premises and Equipment
PIC/S does not specify criteria or
numerical for premises and equipment, Your ingenuity will be everything.
Summary of this Chapter:
Premises
design + engineering
Expertise in all stages from design concept to production
Production area
Classified area & zoning
Flow & anti-cross-contamination
QC laboratory
Storage area
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Todayʼs Topics
1. A Quick Recap of Our Previous
Session
2. PIC/S Part I - Chapter 3 Premises
and Equipment
Good documentation constitutes an essential part of the quality assurance system and is
key to operating in compliance with GMP requirements. The various types of documents
and media used should be fully defined in the manufacturer's Quality Management
System. Documentation may exist in a variety of forms, including paper-based, electronic or photographic media. The main objective of the system of documentation utilised must
be to establish, control, monitor and record all activities which directly or indirectly impact
on all aspects of the quality of medicinal products. The Quality Management System
should include sufficient instructional detail to facilitate a common understanding of the requirements, in addition to providing for sufficient recording of the various processes and evaluation of any observations, so that ongoing application of the requirements may be demonstrated.There are two primary types of documentation used to manage and record GMP compliance: instructions (directions, requirements) and records/reports. Appropriate good documentation practice should be applied with respect to the type of
document.Suitable controls should be implemented to ensure the accuracy, integrity,
availability and legibility of documents. Instruction documents should be free from errors
and available in writing. The term ‘written’ means recorded, or documented on media from which data may be rendered in a human readable form.
.
3. Chapter 4: Documentation
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3. Chapter 4: Documentation
Documentation is the material that provides official information or evidence or that serves as a record.
Documentation is the process of classifying and annotating texts, photographs, etc.
What is documentation?
Mate ial
P o ess
Do u e tatio
Offi ial i fo atio
•App o ed & dated
•Regula l e ie ed
•Re isio o t ol
3. Chapter 4: Documentation
Unlike other industrial products, you cannot test each finished drug on your production line end.
All concepts of GMP, SOP and Validation have been
introduced to address the issues on drug manufacturing.
Notably, all these concepts are based on documentation and by documentation.
Why documentation is essential?
GMP
≠
G
et
M
ore
P
aper
But, pape eall does atte
The truth about GMP
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3. Chapter 4: Documentation
For example: FDA Inspection Observation Summaries by frequency
Cited ef. # Sho t des iptio Lo g des iptio FY FY FY
CFR . d P o edu es ot i iti g, full follo ed The espo si ilities a d p o edu es appli a le to the ualit o t ol u it a e ot [i iti g] [full follo ed]. Spe ifi all , ***
CFR . I estigatio s of dis epa ies, failu es
The e is a failu e to tho oughl e ie [a
u e plai ed dis epa ] [the failu e of a at h o a of its o po e ts to eet a of its a d p o ess o t ols desig ed to assu e that the d ug p odu ts ha e the ide tit , st e gth, ualit , a d pu it the pu po t o a e ep ese ted to possess. Spe ifi all , ***
CFR
. S ie tifi all sou d la o ato o t ols
La o ato o t ols do ot i lude the esta lish e t of s ie tifi all sou d a d
app op iate [spe ifi atio s] [sta da ds] [sa pli g pla s] [test p o edu es] desig ed to assu e that [ o po e ts] [d ug p odu t o tai e s] [ losu es] [i ‐p o ess ate ials] [la eli g] [d ug p odu ts]
o fo to app op iate sta da ds of ide tit , st e gth, ualit a d pu it . Spe ifi all , ***
Procedures not in writing, fully followed
3. Chapter 4: Documentation
Good documentation constitutes an essential part QAS.
It is key to operating in compliance with GMP
requirements.
Types of documents should be fully defined in QMS.
To establish, control, monitor and record all activities which directly or indirectly impact on the quality of products.
There are two types of documentation used to manage and record GMP compliance: instructions and
records/reports.
Suitable controls should be implemented to ensure the accuracy, integrity, availability
and legibility of documents.
Six key points for documentation
Ele t o i ase data ase dataPape
Ele t o i ase data ase dataPape
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3. Chapter 4: Documentation
Required GMP documentation (two primary types)
Site Master File
Specifications Manufacturing Formulae
Processing
Instructions Procedures Packaging/
Testing Instructions
Protocols
Records
Certificates of Analysis Reports
Instruction type
Record/Report type
3. Chapter 4: Documentation
Definitions of each material:
Instructions type:
Specifications: Describe in detail the requirements with which the products or materials have to conform as a basis for quality evaluation.
Manufacturing Formulae, Processing, Packaging and Testing Instructions:
In detail all the starting materials, equipment and all processing, packaging, sampling and testing instructions.
Procedures: Also known as SOPs, give directions for performing certain operations.
Protocols: Give instructions for performing and recording certain discreet operations.
Record/Report type:
Records: Provide evidence of various actions taken to demonstrate compliance with instructions .
Certificates of Analysis:
Provide a summary of testing results together with the evaluation of compliance to a stated specification.
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KindGofGDocumentGinGPIC/SGGMP SectionG4 PIC/S GMP Part I
1. QMS
Site Master File
Instruction type
All types of document should be defined and adhered to. The requirements apply equally to all forms of document media types. Complex systems need to be understood, well documented, validated, and adequate controls should be in place. Many documents (instructions and/or records) may exist in hybrid forms, i.e. some elements as electronic and others as paper based. Relationships and
control measures for master documents, official copies, data handling and records need to be stated for both hybrid and homogenous systems.
Appropriate controls for electronic documents such as templates, forms, and master documents should be implemented. Appropriate controls should be in place to ensure the integrity of the record throughout the retention period.
.
3. Chapter 4: Documentation
GENERATION AND CONTROL OF DOCUMENTATION
Y
a
a
a
a
,
a
y
a
a
y
a
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Documents containing instructions should be approved, signed and dated by
appropriate and authorised persons. Documents should have unambiguous
contents and be uniquely identifiable. The effective date should be defined.
.
3. Chapter 4: Documentation
GENERATION AND CONTROL OF DOCUMENTATION
Documents containing instructions should be laid out in an orderly fashion and be easy to check. The style and language of documents should fit with their intended use. Standard Operating Procedures, Work Instructions and Methods should be written in an imperative mandatory style.
Documents should not be hand-written; although, where documents require the
entry of data, sufficient space should be provided for such entries.
Handwritten entries should be made in clear, legible, indelible way.
.
3. Chapter 4: Documentation
GOOD DOCUMENTATION PRACTICES
Any alteration made to the entry on a document should be signed and dated; the alteration should permit the reading of the original information. Where appropriate, the reason for the alteration should be recorded.
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3. Chapter 4: Documentation
Generation and control of documentation
Define the document type and adhere to it. Electronic base vs. Paper base
Master documents vs. Official copies Comply with the relevant parts of;
Product Specification Files
Manufacturing and Pre-Market Authorization
PSF
MA
PMA
Ele t o i
ase data ase dataPape
Maste
file Offi ial op
I st u tio s Re o ds
Be approved and regularly reviewed Lay out in an orderly fashion
3. Chapter 4: Documentation
Good documentation practice Be clear, legible, indelible for hand-writing
Records to made completed at the time each action is taken and in such a way that all significant activities are traceable. Alteration made to the entry on a document to be signed and
dated; and to permit the reading of the original information.
Re o d
Sig ; S.Taha a
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3. Chapter 4: Documentation
Retention of documentsRetention period
Batch documentation must be kept for 1 year after expiry of the batch, or at least 5 years after the batch release, whichever is the longer.
For investigational drugs, the batch documentation must be kept for at least 5 years after the last clinical trial.
Critical documentation, relating to validation or stability, etc. which supports information in the MA should be retained whilst the MA remains in force.
It is acceptable to retire certain documentation if the data has been superseded by a full set of new data, after doing the followings;
• document the justification,
• consider the requirements for retention of batch documentation.
For example, in the case of Process Validation:
3. Chapter 4: Documentation
Example of instruction type documentSpecifications for starting/packaging materials
a
• Des iptio of the ate ials• Di e tio s fo sa pli g a d testi g
• Qualitati e a d ua titati e e ui e e ts ith a epta e li its
d
• Sto age o ditio s a d p e autio sCop ight© CM Plus Co po atio . All ights ese ed®
3. Chapter 4: Documentation
Example of record type documentReceipt for starting/packaging materials
a
• The a e of the ate ial o the deli e ote; • The "i ‐house" a e a d/o ode of ate ial;• Date of e eipt;
d
• Supplie ’s a e a d a ufa tu e ’s a e;e
• Ma ufa tu e ’s at h o efe e e u e ;f
• Total ua tit a d u e of o tai e s e ei ed;3. Chapter 4: Documentation
Summary of this Chapter:
Site Master File
Specifications MFG Formulae
Certificates of Analysis Reports
Instructions
Turn your mountains of books into the best