Essential Documentation

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    ESSENTIAL

    DOCUMENTATION

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    Essential Documentation

    Objectives

    To review specific requirements for

    essential document.

    To list other types of GMP documents.

    GMP rules on documents.

    Documents are historical records of how

    we practice GMP in pharmaceutical factory.

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    Essential Documentation

    PURPOSE OF DOCUMENTATION:Essential statutory requirement

    To be clear of what is to be done

    To keep records of what has been done

    To provide audit trials for complaint

    investigation.

    To help us decide and take corrective actionin case of quality problem.

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    DOCUMENTATION LEVELS :

    The hierarchy of documents is defined

    in

    Category1

    Category2

    Category3

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    Category1:The document which are the apex

    documents of the pyramid, based on which

    the other documents shall be prepared.The category 1 documents include:

    Site Master File [SMF].

    Quality Manual [QM].

    Training Programes [TP] .

    Validation Master Plan [VMP].

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    Category2:The documents which are prepared for the

    actual execution of the activity.

    Standard Operating Procedures [SOPs].

    Protocols.

    Qualification Documents.

    Master Formula Records.

    Batch Manufacturing & Packing Records.

    Specifications and method of analysis

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    Category3:

    The documents which are the recording

    formats.

    The category 3 documents includes

    Formats & Reports.

    Logbooks.,

    Technology transfer records

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    Essential DocumentationBASIC DOCUMENTSProduction Related:

    Batch Manufacturing records (BMR)

    Batch packaging records (BPR)

    These are der ived from: -

    Master formulae records (MFR)

    To operate equipment and processes we need-

    Standard operating procedure (SOP).

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    Essential DocumentationBASIC DOCUMENTS

    Quality Control Related:

    Material specifications.

    Product specifications.

    Analytical method & procedures.

    Calibration procedures for instrument.Operating procedures for instrument.

    Microbiological procedures.

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    Essential Documentation

    OTHER DOCUMENTS:

    Housekeeping & sanitation logs.

    Equipment & instrument logs.

    Validation documents.

    Annual product reviews.

    Maintenance & machine history card.

    Complaint records.

    Training records.

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    Essential DocumentationPRODUCTION DOCUMENTS:

    MFR: is essentially a specific guide detailingmanufacturing and packaging process for aproduct. It includes instructions on inprocess

    controls and sampling during the productionprocess. Usually prepared by R & D or ParentCompany.

    BMR/BPR: is an extract from the MFR whichgives stepwise instruction on how to process aproduct. It includes tables and blank spaces tobe filled in with observations as the product is

    processed in the factory.

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    Essential DocumentationBMR INCLUDES AT LEAST THE FOLLOWING

    DATA:

    Product name/batch number/batch size/lot sizetheoretical & expected yields.

    Actual quantities of each raw material issued andchecked.

    Step wise processing data with time/signature ofresponsible person for each operations.

    Key equipment used in the process.Area clearance/equipment cleanliness checks.

    Environmental checks (temperature/humidity)

    Inprocess checks.

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    Essential DocumentationBPR INCLUDES AT LEAST THE FOLLOWINGDATA

    :Product name/batch number/pack size/quantitypacked.

    Label type and overprinting details approval

    (specimen).Reconciliation of materials used in packaging.

    Issue/ return of material to store.

    Details of packing operation with time/ signature of

    responsible person for each operation.Inprocess controls (volume/ weight/ quantity percontainer)

    Line clearance.

    Outer pack and shipper packing details.

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    Essential Documentation

    Standard Operating Procedures

    WHAT IS AN SOP?

    These are written and authorized guidelineswhich describe / tell how to perform certain

    activities. It defines scope and responsibility of

    both operator and officer, carrying out these

    activities. It also warns of consequences of failureto follow the guidelines

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    Standard Operating Procedures:

    Who should prepare?

    Expert/experienced person knowing theoperation.

    Who should check?

    Department head or manager

    Who should approve?

    Q A or designated person

    Where should the SOP be stored?Original with QA

    Controlled copy with department

    Display copy displayed at the work place.

    Essential Documentation

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    Standard Operating ProceduresActivities which require SOPs?

    Receipt of all material deliveries

    Internal labelling, quarantine and storage ofmaterials

    Operation, maintenance and cleaning of all

    instruments and equipment

    Sampling of materials

    Batch numbering systems

    Material testing at all stages of production

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    Standard Operating ProceduresActivities which requi re SOPs?

    Batch release or rejection.

    Storage and distribution procedures.Equipment assembly and validation

    Calibration and operation of analytical apparatus

    Maintenance, cleaning and sanitation procedure.

    Personnel recruitment, training,

    clothing and hygiene

    Environmental monitoring

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    Essential DocumentationPROTOCOLS:

    These are also procedures to perform validation

    activities.

    A protocol may include formats/ tables for

    filling information during the validation activity.

    Alternatively the protocol may indicate

    preparation of reports in other standard

    formats available for the validation activity.

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    Essential DocumentationQUAL ITY CONTROL DOCUMENTS:

    Material & product specifications

    List of test to be done with acceptance limits for

    compliance

    Analytical methods & procedure :Detailed instruction on analytical test procedures

    Same test procedures may have pharmacoepial

    references.Calibration procedures for instrument

    Detailed test to be performed to ensure correct

    calibration status.

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    Essential DocumentationQUALITY CONTROL DOCUMENTS:

    Microbiological procedures

    Sterility testing method

    Bio assay proceduresTotal viable count and microbial limit test

    procedure.

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    Essential DocumentationOTHER RELATED DOCUMENTS:Log books:

    Required for each equipment/ instrument to

    enumerate what product was processed or

    tested.

    Idle time and cleaning time details.

    Specific break down and repair entries.

    X- check entries in BMR/BPR etc.

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    Essential DocumentationVALIDATION DOCUMENTS:

    Equipment qualification

    URS/DQ/IQ/OQ/PQ

    Process validation

    Cleaning validation

    Aseptic media fill validation

    Analytical method validation.

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    Essential DocumentationANNUAL PRODUCT REVI EW:

    Key record to check on-going product

    performance batch wise details of product yields

    and key quality parameters.

    MAINTENANCE & MACHINE HISTORYCARDS:

    List of periodic preventive maintenance, major

    repairs carried out on each machine.

    Setup and modification on machine operation.

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    Essential DocumentationCOMPLIANT RECORDS:Details of market complaints received.

    Investigation and findings and process

    improvements.TRAINI NG RECORDS:

    Individual training of pharmacist/ chemist/stores and maintenance persons

    GMPwater / air systems / shopflooractivitiesworkmen training on hygiene &gowning.

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    STOCK CONTROL DOCUMENTS:

    Responsibility of stores:

    Receipt, Issues in stock registers/ computers

    The records include batch numbers, status,

    quantities and expiry date

    Required for:

    Production planning

    Purchasing activity

    Ensuring orderly usage of material FIFO to

    EEFO.

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    Essential Documentation

    DISTRIBUTION RECORDSFor distribution, there should be one recordper batch of product. It should contain the

    batch number, quantity and destination ofeach delivery.

    Why are these records important?

    In the case of a product recall, theinformation on distribution can be obtainedrapidly from a single source.

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    REVIEW OF DOCUMENTATION:

    Specifications and SOPs.

    Done by concerned department at periodic

    intervals12/24 months

    OR

    After any significant change is made.Product BMR/BPR are reviewed by QA prior

    to each batch release.

    Essential Documentation

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    Documentation & Control Storage / Destruction

    Retrieval

    Distribution

    Training

    Authorization

    Approval

    Review

    Prepare

    Design

    Good documentation

    systems

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    Essential DocumentationOther documentation:

    Labels are also part of documentation

    Internal labelsstatus/ identity

    External labelproduct labels

    LABELS:IDENTITY:

    Placed on containers, vessels, equipment toIDENTIFY the MATERIAL that is inside.

    STATUS:

    Placed on containers, vessels and equipment toindicate CURRENT STATUS of MATERIAL that isinside

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    Documentation & Control

    LabelsWhat must be labelled?

    What must be on the label?

    Who has responsibility for labelling?

    The identification affixed to the recipients,

    equipment, and facilities and on products

    should be clear, without ambiguities.

    Different colors indicating its conditions

    might be used (e.g.: in quarantine,

    approved, rejected, clean).

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    Finished Product Label

    NameActive ingredients and amounts

    Batch number

    Expiry date

    Storage conditions

    Precautions if necessary

    Directions for useEarnings

    Name and address of manufacturer

    The approved master of a

    label need not to be a label

    itself but may consist of a

    approved set of relevant

    data used by or sent to a

    label printer. A 0-copy of the

    label may be filled together

    with the batch record as

    proof of compliance of the

    master.

    Reference 19

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    Rules About Making Records

    Always make record, or enter signature etcwhen (or immediately after) the action or

    reading has been taken, or the check has

    been made.Records should always be made as things

    happen. NOT at the end of the shift, day or

    week they are about current events, nothistory.

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    Rules About Making Records

    A person entering a second check signature or

    initials is confirming that he or she actuallysaw what was done (for example, a weighing)and has personally checked that everythingwas correct (product, material, batch, quantity,reading or whatever).

    It is NOT good enough, and it could be verydangerous, to just trust your mate to have got

    it right, and write in second checkinitials/signatures at the end of the day. These,too should be entered as things happen, whenthey have been seen to happen.

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    Rules About Making Records

    Records should always be NEAT andCLEAR. They do not have to be beautiful, butremember, other may need to read them infive or more years time.

    If you make a mistake when making an entryon a document. It is not a crime. But if you domake a mistake, do not obliterate it or cover it

    up, cross it out neatly (so that it can still beread), make the correction and sign/initial andadd the date (with any explanation necessary)